As a minimum our businesses are expected to comply with all laws, regulations and codes of marketing practice. Our Code of Business Conduct states: that we will not knowingly create work that contains statements, suggestions or images offensive to general public decency; and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, colour, gender, sex or sexual orientation, gender identity or expression, age or disability.
Supporting marketing standards
Many professionals from within WPP companies play an important part in developing and revising industry codes in sensitive areas such as advertising to children and the marketing of food and pharmaceutical products.
Most of the campaigns we produce for clients do not cause complaint, but occasionally complaints do occur relating to matters of taste or fact. In most countries these are arbitrated by government or industry organisations. Our Corporate Responsibility Report contains details of infringements in countries where these are available, and we intend to extend the scope of this.
Privacy is particularly relevant for our digital, market research and direct marketing companies which collect data on consumers, or study lifestyles and purchasing habits, in order to better target marketing campaigns. Our operating companies comply with national data protection laws and marketing codes of practice such as the UK Data Protection Act and the EU Data Protection Directive.
During 2007 WPP set up a working group to review the significance of privacy for our companies and to identify any potential risks arising from the collection or storage of data within the Group. The working group will also consider the opportunities presented by becoming a leader in improving practices of transparent marketing.
Ethical issues in client work
Sometimes the nature of the clients approaching WPP or the type of work we are asked to undertake on their behalf can give rise to ethical issues. To raise awareness of this risk, the following clauses have been added to WPP's Code of Business Conduct.
- We will consider the potential for any new client or new commission from an existing client to have a negative impact on the reputation of WPP or the long-term interests of our share owners.
- We will not undertake work designed to mislead in any regard.
Risk areas include, but are not restricted to: sensitive or controversial products; and work in countries subject to sanctions or where government advises against doing business there.
We recognise that some decisions in this area require judgement. Therefore, in cases where there is a potential risk to WPP's reputation we will elevate the decision first to the most senior person in the relevant office and then to the most senior executive of the WPP business in the country concerned, who will decide if further referral to a WPP director is required. We are developing appropriate training for our employees.