Purpose of this document
Society has a right to information based on truth, freedom, justice and solidarity. Our media entities, presently 103 Malta’s Heart and Newsbook.com.mt are important players in the media ecosystem of Malta.
To cover our costs we seek advertising. We acknowledge that this has a profound impact on how people understand life, the world and themselves, especially in regard to their values and their ways of choosing and behaving.
Importance of Commercial Activity: Advertising and sponsorship are important to any commercial service. If executed well, they provide funding and can enhance a consumer’s experience by adding to the content proposition. However, if executed badly, they can be a reputational risk and cause future commercial relationships to be put in jeopardy.
This document seeks to provide guidelines to our staff on how to discern between advertising and/or sponsored content which is acceptable and advertising and/or sponsored content which would be ethically unacceptable to our media organisations and shareholding entities.
Advertising has two basic purposes: to inform and to persuade, and — while these purposes are distinguishable — both very often are simultaneously present.
Advertising is not the same as marketing (the complex of commercial functions involved in transferring goods from producers and consumers) or public relations (the systematic effort to create a favourable public impression). In many cases, though, it is a technique or instrument employed by one or both of these.
In general we recognise the following forms of advertising:
- Economic advertising: advertising that informs our audience of the availability of rationally desirable new products and services and improvements in existing ones, helping them make informed prudent consumer decisions.
- Political advertising or Cause related advertising: advertising that contributes to democracy by informing our audience about proposals, policies or candidates for political organisations or promotes causes and issues of interest to lobbies and special interest groups.
- Cultural advertising: advertising which educate and motivate people in a variety of matters relating to human intellectual achievement.
General ethical and moral principles
- It is unethical to promise editorial favours in return for advertising. Consequently advertisers will not be given special editorial treatment because they are advertisers.
- Truthfulness in Advertising: Generally speaking, the problem of truth in advertising is not that advertising says what is overtly false, but that it can distort the truth by implying things that are not so or withholding relevant facts. As Pope John Paul II points out, on both the individual and social levels, truth and freedom are inseparable; without truth as the basis, starting point and criterion of discernment, judgment, choice and action, there can be no authentic exercise of freedom. This advertising content should be communicated honestly and properly. To be sure, advertising, like other forms of expression, has its own conventions and forms of stylization, and these must be taken into account when discussing truthfulness. People take for granted some rhetorical and symbolic exaggeration in advertising; within the limits of recognized and accepted practice, this can be allowable. But it is a fundamental principle that advertising may not deliberately seek to deceive, whether it does that by what it says, by what it implies, or by what it fails to say.
- Dignity of the Human Person: Advertising can violate the dignity of the human person both through its content — what is advertised, the manner in which it is advertised — and through the impact it seeks to make upon its audience. This problem is especially acute where particularly vulnerable groups or classes of persons are concerned: children and young people, the elderly, the poor, the culturally disadvantaged.
- Advertising and social responsibility: Social responsibility is a broad concept, nevertheless we shed light on some common elements thereof. The ecological issue is one such element. Advertising that fosters a lavish lifestyle which wastes resources and despoils the environment offends against important ecological concerns. Advertising that reduces human progress to acquiring material goods and cultivating a lavish lifestyle expresses a false, destructive vision of the human person harmful to individuals and society alike.
- Advertisers’ responsibility: Advertisers are responsible for ensuring that their adverts comply with all applicable laws, regulations, and guidelines. While the content of advertising does not reflect the views of BMG —if it comes to the attention of BMG that an advert, contains demonstrably false or unlawful content, BMG will refuse to publish the advert, or shall remove the advert in whole or in part.
- Discretion: BMG may exercise its discretion to refuse or remove any advertising that is inconsistent with, or may tend to bring disparagement, harm to reputation, or other damage to BMG’s brand. Such discretion will be exercised following review by BMG’s Registered Editor and CEO. The latter will obtain input from the Sales Representative concluding the business, but are not bound by such input.
This section of the document is to be updated from time to time by Beacon Media Group’s editorial board and in turn, approved by its Board of Directors. It will contain specific, pragmatic guidance on advertising:
- Legal: All advertising on our media must be legal. It must follow applicable advertising laws and regulations – this is not merely an ethical requirement but a formal one to abide by the Broadcasting Act. Our advertising booking forms will contain a clause in which the Advertiser confirms that the product/service being advertised complies to all required legislative standards and that Beacon Group is held harmless against any claim or damage which could potentially arise from such advertising.
- Clear and non–misleading content: Advertising must not be misleading, harmful or offensive. Generally acceptable standards must be applied to the content of all advertising materials so as to provide adequate protection for members of the public from the inclusion of offensive or harmful material.
- Participation of our staff: Presenters, journalists or reporters employed by Beacon would not normally be permitted to take part in any advertisements for third parties unless specifically authorised by the CEO. The degree to which they are regarded as an objective journalist will affect decisions as to whether any outside promotional work is permissible.
- Use of our brand: We should ensure that the Beacon Media Group brand and its sub-brands (Newsbook.com.mt, 103) are not used to endorse outside companies or organisations. We can achieve this by ensuring commercial advertising, promotion and press releases by outside companies do not give the impression of our endorsement, and advertising does not “pass off” as our brand or brand programmes or content.
- Timing of on-air adverts: Fine judgements may need to be made about the suitability of advertising. A critical factor may be the timing of an advertising campaign in relation to the scheduling of our programmes. We may decide that such advertising or promotions are only acceptable if there is a suitable time period between an advertising campaign and a specific time-band, or the start and finish of a specific transmission of these programmes and any related Beacon marketing activity.
- Prohibited content: We shall prohibit the advertising of adult products and services, tobacco products (or e-cigarettes), and weapons. We shall also prohibit advertising which blatantly highlights, perpetuates or exploits any stereotype. Any advertising which relates to iGaming or gambling shall be prohibited. Should this relate to a Maltese lottery which is offered by a registered entity regulated by the national authority, it will be allowed subject to review by the CEO and the Registered Editor.
- Advertising content which requires senior approval: Advertisements including sponsored content in the following categories must be approved by the CEO and the Registered Editor before they can be accepted for broadcast or publication:
- political advertising (on services where this is permitted)
- advertising by governments and government agencies which may be perceived to contain political content
- advertising by lobby groups and trade unions
- advertising for any product or service which shares a name or trademark with a prohibited product or service, sometimes referred to as ‘Surrogate advertising’
- advertisements that deal with a controversial subject that is a matter of public policy
- advertisements which could compromise the BMG’s editorial integrity or which have received consistent and manifest criticism by the Church.
- Format: Advertising should not appear in a similar style to the editorial content to which it is adjacent so that consumers can clearly distinguish between editorial content and advertising. Advertising should not emulate Beacon Media Group’s editorial content.
- There several descriptions of what constitutes sponsored content. This policy considers two types.
Type A: “Sponsored content is editorial content produced by the news organisation that an advertiser pays to associate with. The content is commissioned by the organisation’s editorial teams and is independent of the sponsor.
Type B: Sponsored content is material in an online publication which resembles the publication’s editorial content. Its content is influenced, or determined by the advertisers who pays for same content with the intention of influencing audiences and promoting the advertiser’s product.
- Type A. Beacon’s editorial team takes produces or commissions the content which is not influenced or determined by the advertiser. In such cases the item should be placed in the category it fits into for example culture, lifestyle etc. At the end a one liner is added: “This series produced by Newsbook.com.mt is made possible thanks to a grant by ** ** ***.)
Type B. This has to be appropriately marked in such a way that a person of ordinary attention even before clicking on the article notices that this is not material produced by Beacon but is an advert. At minimum, there should be a very clear marking ‘Sponsored Content’ as the category of the content. If one clicks on the article than one finds the words ‘Sponsored content’ at the top-end of a feature or video-clip. Such content will be posted in a section titled “Sponsored content.”
For those who wish to learn more, at the end of the article/feature (perhaps on a separate page) there should be an explanation such as “This sponsored content was supplied by ***”
Sponsored content should not occupy the foremost featured-item space.
Similarly when a programme has product placements, this must be obvious to the public. A disclaimer should be done before or after programme stating this.
- Clarity: Advertisers should clearly disclose all material conditions, such as payment or receipt of a free product, affecting endorsements, as well as the identity of endorsers, all in the interest of full disclosure and transparency.
- Privacy: Advertisers should never compromise consumers’ personal privacy in marketing communications, and their choices as to whether to participate in providing their information should be transparent and easily made
It is likely that staff at Beacon Group may have questions, from time to time, about this policy and its applicability to specific requests. In such situation we propose the following escalation path:
- If sales staff have queries, these should be addressed to Sales Manager
- If the Sales Manager has any queries, these should be addressed to the CEO and the Registered Editor. It there is disagreement the issue would be referred for the consideration of the Chair of the Board of Directors and the Chair of the Editorial Board. The Chair of the Board of Directors shall be tasked with taking a final reasoned decision following due consideration of the Chair of the Editorial Board. The Chair of the Board of Directors shall be tasked with providing a reasoned decision which will be registered in the subsequent Minutes of the Board.
In providing advice, any person or entity above will provide reasoned guidance for the decision taken and will document the same for transparency and future reference.