Complaints about advertising: what's really happening?

Debra Harker

Introduction
Wherever you live in the world, whether it be Europe, America or Australia, you will be aware of advertising; it is ubiquitous and virtually unavoidable for the average consumer. As the most visible part of the marketing communications mix (Boddewyn, 1989), advertising has often been accused of being pervasive (Drake, 1988), intrusive (Blakeney and Barnes, 1982) and pernicious, and purveyors of the art have been known to be mischievous in their attempts to reach and persuade their target markets (Mittal, 1994). It is estimated that the US$270 billion spent on advertising worldwide (Petty, 1997) has been ``growing faster than the world gross product'' (Mooij and Keegan, cited in Agrawal, 1995), with the big players of the United States of America (nearly 40 per cent) and Europe (25 per cent) dominating (Petty, 1997). Globally, developed and developing societies are bombarded by ``several hundred millions of different advertisements'' which are published and broadcast each year (Boddewyn, 1992, p. 22). On the one hand, these figures are testament to the importance of this element of the marketing mix (Boddewyn, 1989, p. 22), however they can also be viewed as further evidence that some members of society may need to be protected as some advertising can be harmful. Thus, when advertising does offend, mislead or is untruthful, a structure needs to be in place in order to provide some protection. Developed countries have established such programs of regulation and, in the main, these programs are set up on a self-regulatory basis, where the industry is responsible for controlling the conduct of its own members (Harker, 1998). However, there is some concern in the literature that the rival advertisers are beginning to dominate the complaint process (Boddewyn, 1992; Harker, 1998). The recent breakdown in Australia of one of the world's longest established advertising self-regulatory systems highlights the problems associated with providing effective protection for society from unacceptable advertising (Media Council of Australia, 1996; Strickland, 1996). The effectiveness of advertising selfregulatory systems has been debated in the leading academic journals for more than 20 years. This extant literature can be classified

The author Debra Harker is Lecturer in Marketing in the Faculty of Business, University of the Sunshine Coast, Queensland, Australia. Keywords Advertising, Marketing research, Qualitative techniques, Regulations, Australia Abstract As the most visible element of the marketing communications mix advertising has had its critics over the years and developed countries usually opt for a selfregulatory approach to deal with unacceptable advertising. The recent breakdown of one of the world's longest established advertising self-regulatory programs in Australia has reopened the 20 year-old debate that has taken place in the leading academic and business journals concerned with improving the effectiveness of such regulatory systems. One of the key changes in this area is the increasing dominance of the rival advertisers in the complaints process. This article presents a model of effective advertising self-regulation and reports on the key findings of an Australian study. The empirical work, utilising a mix of qualitative and quantitative data collection techniques, succeeds in making both a practical and theoretical contribution to this important area. Electronic access The current issue and full text archive of this journal is available at http://www.emerald-library.com

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . pp. 198206 # MCB University Press . ISSN 1352-2752

198

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

into two distinct groups; descriptive and prescriptive. The former provides a significant body of knowledge of advertising selfregulation (ASR) in general, for example dealing with how various schemes function around the world (Neelankavil and Stridsberg, 1980; Miracle and Nevett, 1987; Boddewyn, 1988, 1992). However, there is a dearth of literature concerned with the latter, especially developing and testing models of effective ASR (La Barbera, 1980, p. 34). The main objective of this article is to describe the process of complaint acceptance and enforcement implemented by Australia's Advertising Standards Council, and identify forces affecting that process.

The need to regulate

Regulation is used by government to support, or to obtain the collaboration or assistance of business, as well as to control it (Byrt, 1990). It is also used in a social sense to regulate conduct and behaviour, for example ensuring through statutory law that citizens drive on the left-hand side of the road in Australia or the United Kingdom, or urging Australian beach-goers to swim between the flags for their own safety. Indeed, there are few activities in Australia that are not subject to government regulation, either directly or indirectly (Pincus and Withers, 1983). When regulation of an industry is contemplated, the regulatory options are wide, ranging on a continuum from none to full government involvement (Figure 1). Whilst the practice of advertising originates in the business world, the results are often located in the public domain and this places
Figure 1 The regulatory spectrum

advertisers in a peculiar position when it comes to regulating their conduct or behaviour in view of the activity, its impact on society, and undoubted ability to offend, mislead or deceive those exposed to the messages. A ``knee-jerk'' reaction from many industries when faced with the prospect of government regulation is to opt for selfregulation in an attempt to stave off what is seen as ``interference'' in the marketplace by government bodies. Canada, New Zealand, the United Kingdom and the United States of America are good examples of ASR in action on the global stage (Harker, 1998). However, whilst the advertising industry in Australia had observed the disciplines of self-regulation for more than 60 years (Australian Advertising Industry Council, 1989), it is currently in a state of flux.

The Australian context

During 1995 and 1996 a number of significant events took place in Australia which ultimately resulted in the industry being charged with producing a new system of ASR. First, the Australian Competition and Consumer Commission (ACCC) revoked the Media Council of Australia's accreditation system for advertising agencies because the benefit to the public from the system was insufficient to outweigh the associated anticompetitive detriment. In March of 1996 this decision was unsuccessfully appealed and effectively meant that the system of ASR in Australia had no means of enforcing decisions advertisers could not be forced to withdraw offending advertisements. Next, in August of the same year the ACCC announced a review of advertising standards in Australia, encompassing both the codes of conduct and the complaint handling body, the ASC. Thirty days later the Media Council of Australia declared its intention to disband at the end of 1996, leaving Australian society open to unacceptable advertising until a new ASR system was established (Harker, 1997). The ACCC went ahead with its review despite the demise of the Media Council and found that a material change of circumstance had occurred since 1988 in regard to five key areas[1]. In terms of direct ASR activity, there were two main players in Australia the Media Council of Australia and the Advertising

199

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

Standards Council. The Media Council was formed in 1967 as an unincorporated voluntary association of virtually all mainstream commercial media (MCA, 1994). The MCA brought together the various arms of media to ensure a uniform method of extending credit to advertising agencies, and to implement a system for the regulation of advertising content published or broadcast by its members through development of five codes of advertising practice (MCA, 1994). In 1974 the Advertising Standards Council was established by the Media Council of Australia (the media), the Advertising Federation of Australia (the agencies), and the Australian Association of National Advertisers (the advertisers) as a ``strictly independent and autonomous'' complaint handling body for the advertising industry (ASC, 1993, p. 1). The principal role of the ASC was to handle and determine complaints made about advertising in Australia. The Media Council of Australia and the Advertising Standards Council were the two major casualties of the collapse of the Australian ASR system in 1996.

the process, should not be established because the system that ``focuses the complaints to be handled also narrows the dissatisfactions that can be recognised'' (Moyer and Banks, 1977, p. 193). A ``systematic monitoring'' system covering advertising in all media should be in place in order to generate complaints about advertising which may be potentially unacceptable to society (La Barbera, 1980, p. 33). Code enforcement With tightly written codes in place and complaints encouraged and accepted from all sources, a ``grievance committee'' should be established to schedule hearings to deliberate on complaints made (La Barbera, 1980, p. 33). In terms of the composition of the committee, the most effective ``mix'' is an equal number of representatives from industry and the public (La Barbera, 1980, p. 33) and, perhaps, representatives from government and consumer organisations (Moyer and Banks, 1977, p. 194). To improve effectiveness of ASR systems, due process should be incorporated into the enforcement process. In particular, parties should be given reasonable notice of the charges, and the hearing; they should have the right to confrontation and cross-examination; an opportunity to refute the charges; and a hearing before an unbiased tribunal (La Barbera, 1980, p. 33). It is also suggested that ``involving alleged offenders'' in the enforcement process also strengthens it and, at the very least, advertisers should be informed of all complaints made against their advertising in order to open the lines of communication (Moyer and Banks, 1977, p. 198). ``Immediate economic incentives'' to comply with decisions made by the complaint handling body are seen as essential, rather than relying solely on the goodwill of recalcitrant advertisers (La Barbera, 1980, p. 33). An appeals procedure is also recommended (La Barbera, 1980, p. 34). Where the ASR scheme incorporates a national tripartite system (Boddewyn, 1992, p. 9; Sinclair, 1992, p. 3) and the advertisers, agencies and media are involved in the process, the chances of compliance are greatly enhanced as the complaint handling bodies are given ``teeth'' and independence.

Effective advertising self-regulation

The literature suggests a conceptual model of effective ASR, comprising seven key components that should be addressed in order to improve overall effectiveness of the system (see Figure 2). All studies in this area used the ``complaint handling body'' as the unit of study as this body is the interface between the public/ industry and the regulators. Whilst it is important to address all seven components when attempting to achieve effective ASR, for the purposes of this paper, the interface between the components of complaint acceptance and code enforcement is the focus. Complaint acceptance An independent code administrator must be established to receive and handle complaints about unacceptable advertising (La Barbera, 1980, p. 33) from ``consumers and competitors'' (Boddewyn, 1985, p. 129) and all sources (Moyer and Banks, 1977, p. 194; La Barbera, 1980, p. 33). Screening systems that might filter out certain complaints and, thus, not reflect the concerns of those who use

200

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

Figure 2 The seven key components of effective ASR

Research design
The main purpose of this study was to describe the process of complaint acceptance and enforcement implemented by Australia's Advertising Standards Council, and identify forces affecting that process. Findings from this study contribute to a theoretical framework that is found in the body of knowledge concerned with improving the effectiveness of ASR. The choice of Australia is particularly relevant as the ASR system in place there since 1974 has recently been dismantled and the industry is in the process of reformulating a replacement system; hence, there is a lot to be learnt from failure. Although work in the area of effective ASR has been significant, none of the researchers has so far penetrated an ASR body in order to conduct research in a meaningful way; incorporating not only analysis of records, but also more qualitative insights into the issue of effectiveness. Unless access to the regulating body is achieved much process research will remain pure conjecture, and the goal of placing ourselves in the ``temporal and contextual frames'' (Van de Ven, 1992,

p. 181) of respondents will continue to elude us. Thus, ``access'' was vital to this research. Quantifiable numbers of complaints about advertising were submitted to the Advertising Standards Council (ASC) each year, subjected to an administrative process, culminating in a measurable outcome. Complaints made were either upheld, which meant that a breach of a particular code had occurred (a ``breach'') or not, in which case the advertising could continue. However, the effectiveness of the Council's regulatory efforts was unknown and was best revealed by a combined research design that incorporated both qualitative and quantitative approaches. Apart from being appropriate for this piece of research, different data sources also provided ``triangulation''[2], and between methods triangulation was utilised in order to improve external validity (Jick, 1979). First non-participant observation (Easterby Smith et al., 1993) was conducted by the researcher through attendance at two threehour monthly Council meetings in November and December 1995, and during six days spent in the Secretariat offices, where complaints were processed. Second, semistructured depth interviews were conducted

201

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

with members of the Council, the regulators and administrative staff member. Table I displays these respondents. To add rigour to the research design, and fully understand the process, the Chairman and Executive Director were interviewed twice. After the first interview, the transcripts were sent back to the two regulators to ensure accuracy of response and as preparation for the next interview conducted one month later. For the purposes of this research a face-toface, semi-structured, indirect approach was selected as most appropriate. The flexibility of the structuring was felt to best suit the respondents, allowing more or less detail on individual topics relative to each person, and the level of directness allowed questions that the respondents might otherwise have difficulty in answering. An interview schedule was developed with topics reflecting the needs of the research and grounded in the literature, however the sequencing and wording of questions was flexible to allow respondents freedom of expression. All interviews were tape-recorded, transcribed and returned to the respondents for verification. Finally, analysis of historical data and documentation was undertaken, where more than 10,000 complaints and 2,000 breaches over a tenyear period were analysed in aggregate form. The types of documents analysed in this process included annual reports, policy statements, media releases and memorandums. In terms of data analysis, where possible observations were ``counted'' in order to operationalise concepts and thus produce a measure of different features of the phenomenon. For example, how long was spent at Council meetings discussing each advertisement? Was the time spent in
Table I Semi-structured interviews Available respondents Chairman 1 Deputy chairmen 2 Council members: public 6 Council members: public alternate 5 Council members: industry 6 MCA: observer 1 Executive director 1 Secretariat assistant 1 Total Interviews achieved 2 2 5 3 6 1 2 1 22[6]

deliberation longer for different sources of complaints? The depth interviews were taperecorded, transcribed and the content analysed with the aid of the computer package NUDIST[3]. Regression and correlation analyses were used to measure the extent, and nature of, the relationship between variables for the historical data (Weiers, 1988). The degree of confidence for this analysis, the probability level, was set at 0.05 (or 95 per cent) in order to filter out weak correlations. Unlike other studies that have compared and evaluated qualitative and quantitative approaches (Nancarrow et al., 1998), and made significant contributions in this way, this design was selected as being the best to find the truth in this instance.

Findings[4]
Trends in who complains In terms of complaints made, the ASC complaints process was dominated by the public who accounted for three-quarters (75 per cent) of all complaints received by the Council over the period. However, a significant change was the increased use of the process by the industry, the rival advertisers. Figure 3 shows how, over the period, rival advertisers significantly increased their usage of the complaints process (r = 0.68), whilst the lobby groups reduced their share (r = 0.78). The competitors did not erode the public's use of the ASC process; rather their increased use was at the expense of the lobby groups. Figures 4 and 5 show, respectively, the significant increase in numbers of competitors' complaints (r = 0.79), and
Figure 3 Complaints (%)

202

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

Figure 4 Complaints by competitors

Figure 6 Breaches achieved by the public

Figure 7 Breaches achieved by competitors

Figure 5 Complaints by lobby groups

decreased use of the process by lobby groups (r = 0.80) over the period. The public (r = 0.68) and competitors (r = 0.80), again, significantly increased breaches found from their complaints over the period (Figures 6 and 7). A key finding from this research is that the competitors, the rival advertisers, became adept at using the ASC complaint process over the period, evidenced by increased levels of both complaints made and breaches found. Lobby groups, on the other hand, often established to protect consumer and social interests, used the process less. There was no change in levels of complaints from the public, although they achieved significantly more breaches over the period, as more complaints from that section of the community about unacceptable advertising were upheld. Thus, historical records showed that rival advertisers were using the ASC complaints process significantly more over the period. What was not known from this quantitative data was why?

The increase in competitor activity why? Depth interviews were conducted with regulators, administrators and Council members to add richness to the historical, quantitative, data. The increase in competitors' complaints was a trend noted by almost everyone interviewed. One reason as to why competitors were using the ASC process more was that it was a form of litigious reconnaissance, with two key advantages. First, it provided a quick and efficient legal alternative to using the courts:
silk is $6,000 a day and huge, huge costs and it might take you a year or two years ... competitive advantage is lost (I5 406) to litigate against a competitor is quite an expensive exercise, so they'll go to Paul Toose's[5] body to get it resolved (I7 351)

Second, it proved to be an effective testing ground for possible litigation:

if you're Johnson and Johnson and you've got something against your competitor and you can get the Council to say, ``hey you're right'', then that might spur you on to go into court with ``look what the ASC said'' (I4 194)

203

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

However, the reason most often suggested and discussed by respondents was that competitors used the process as a component of their competitive marketing strategy, either to damage or slow down other competitors:
they [competitors] think, if I don't complain and people stop buying this vehicle, the opposition will go up in marketing (P2 203) if they can damage a competitor through us ... (I4 200)

for competitors (Council meetings). Bombarding the Council, with copious amounts of paper, regarding highly technical issues, often confounded the situation, making it almost impossible, at times, for the members to adjudicate fairly. This practice is best conceptualised as obscurantism whereby the minority prevents, or obscures, inquiry or enlightenment from the majority:
it makes it difficult for the Council members to adjudicate on who's telling the truth (I3 164) lots of pie charts, diagrams ... quite minuscule scientific explanations (P8 74) everyone starts playing with figures and somehow everyone's right! (P8 159)

Or in forcing rivals to publicly defend their advertising, to gain market intelligence:

competitors are often seeking market advantage ... or confidential information (ED 233)

However, some respondents suggested that industry use of the process was perhaps more cynical and this was conceptualised as a form of industrial grandstanding. Some advertisers, usually promoting a specific idea or event, such as an issue of a magazine, deliberately air or publish controversial advertising just after an ASC monthly meeting, secure in the knowledge that they will have at least four weeks of relative freedom before the next meeting. The advertisers use the system in the prescribed way but the unintended consequences are that interest is generated in their controversial advertising:
it's over, it's been on, the complaint's come in, it's finished, it won't happen again until their next but one issue, or five issues down the track, but it will happen (I4 331) they really know that they will get off before anybody can do a thing about it (ED 682) they [advertisers] laugh doing it ... it's a bit of a farce, by the time the complaints have come in and they're handled, it's after the event (P5 173) by the time the Council comes to deliberate the campaign is finished anyway ... it's a bit of a nonissue (I2 108)

The high technical content meant that an inordinate amount of time was spent at Council meetings determining competitor complaints and, therefore, the process was laboured. For example, whilst accounting for an average of only 9 per cent of complaints, the time spent determining competitor issues was 25 per cent of total time (Council meetings). This lengthy time spent determining such a small proportion of complaints inevitably meant that complaints from other sources did not receive a fair, or even equal, hearing:
the ASC should be dealing with complaints from citizens rather than try to solve the legal problems of competitors (P4 41)

``Better'' complainants There was agreement, amongst Council members who expressed an opinion, that rival advertisers were ``better'' at submitting a complaint, compared to other complainants. The public complaints were perceived as emotive in nature and amateurish in terms of quality of their submission:
the individual's really just saying, ``hey, I don't like this, I think it's wrong'' (I4 237) I can't see how you could ever have equal competence in complaining between those who are operating the market and those just merely in the marketplace (P5 129) the public probably don't know how to put facts and figures before a body (P6 122)

The ASC itself had the power, through the office of the Chairman, to call a special meeting to consider potentially contentious complaints swiftly. However the, then, Chairman recalled this action being taken only once during his 15-year association. Finally, in most competitor versus competitor cases evidence was often written by solicitors, or the company's own legal section (I2 163), and was highly technical, or at least presented in a highly technical way by the protagonists. For example, one submission from competitors regarding an advertisement totalled 46 pages, whilst the average number of pages of evidence for public complainants was 4.3 pages and 11.6

However, the competitors were perceived as knowledgable about the system and professional in terms of preparing a thorough submission to put before the Council:
they're more aware of the system ... constantly on the look out (I2 162) you do see the same names coming over; they've prepared their case, know the rules, quote the clause in the codes (I4 232)

204

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

you're talking about professionals compared with amateurs (P5 133)

One Council member expressed the opinion that the Council as a whole was swayed by the quality of the complaint:
some complainants do express themselves more persuasively than others and we are swayed by that (P10 51)

In summary, whilst there was no significant change in the numbers of complaints made by the public, as the years elapsed, they did achieve more breaches from their complaints. However, the ASC process, initially established to protect the public, was increasingly used by the industry, the competitors, at the expense of lobby groups, and this was proved statistically. In terms of answering the important ``why?'' question, depth interviews with Council members, regulators and administrators suggested that four concepts could explain this change: . litigious reconnaissance, . a component of a competitive marketing strategy, . industrial grandstanding, and . obscurantism.

Conclusions
Like many developed countries, Australia's advertising industry opted for a selfregulatory approach to deal with complaints. In order to be effective as a scheme, the literature tells us that the ``grievance committee'' (La Barbera, 1980, p. 33) should accept complaints from all sources (La Barbera, 1980; Moyer and Banks, 1977). However there was concern expressed in the leading journals that rival advertisers were beginning to dominate these complaint processes around the world (Boddewyn, 1992; Harker, 1998). Thus, this research was concerned with addressing this issue; who complains to Australia's Advertising Standards Council? Findings from this study suggest that, over an 11-year period, rival advertisers learnt to use the ASC's complaint process to their advantage and this was evidenced by increased levels of both complaints made about advertising and breaches found by that group. Lobby groups, however, often established to protect consumer and social

interests, were found to be using the process significantly less. In terms of complaint proficiency, then, it was not surprising to find that competitors were perceived by Council members to be better than other complainants in terms of knowledge and professional approach to complaining, whilst the public were seen as emotive and amateurish. Whilst the rival advertiser complaints accounted for a small proportion of total complaints, it would appear that the advertisers have become adept at tying up Council time for their own ends, whatever these might be. Some suggestions from those closest to the process were that the industry uses the complaints process to decide on litigation against rivals; to gather market intelligence or wound rivals as part of their marketing strategy; to create interest in controversial advertising; or to use up Council time, at the expense of other groups. Utilising a mixed approach whereby both qualitative and quantitative data were collected in order to find the truth in relation to who complains to the ASC, this article has reported on the findings of an Australian study into effective ASR. The choice of the mixed approach has produced work that is both rigorous and relevant to the phenomenon under study, indeed to have chosen one approach above the other would not have uncovered the truth in this instance. In conclusion, prompted by the recent demise of the ASR system in Australia, this article sought to highlight the importance of research into effective ASR with a view to providing a robust framework for regulators and practitioners to adopt. This article set one key objective: to describe the process of complaint acceptance and enforcement implemented by Australia's Advertising Standards Council, and identify forces affecting that process. The conclusions that have been drawn take the debate a step further in this important area.

Notes
1 See Harker (1997) for further discussion. 2 The term triangulation is a metaphor from navigation and military strategy that uses multiple reference points to locate an object's exact position (Smith cited in Jick (1979) p. 602). 3 Non-numerical unstructured data indexing searching and theorizing.

205

Complaints about advertising: what's really happening?

Debra Harker

Qualitative Market Research: An International Journal Volume 3 . Number 4 . 2000 . 198206

4 Where direct quotations are made from respondents, the reference is given as ``industry'' (I), ``regulator'' (R), ``public'' (P) and a number assigned for each person. The figure after the colon in each case is the number of the line in the original transcript for each respondent. 5 The, then, Chairman. 6 A total of twenty people were interviewed during November and December, 1995; two members did not respond to letters and telephone calls, and one was overseas.

References
Advertising Standards Council (1986-1994), Annual Reports, Sydney. Advertising Standards Council (1993), About the ASC, July, Sydney. Agrawal, M. (1995), ``Review of a 40-year debate in international advertising'', International Marketing Review, Vol. 12 No. 1, pp. 26-48. Armstrong, G.M. and Ozanne, J.L. (1983), ``An evaluation of NAD/NARB purpose and performance'', Journal of Advertising, Vol. 12 No. 3, pp. 15-52. Australian Advertising Industry Council (1989), Advertising: Consumers Have Their Say, AAIC June, Sydney. Blakeney, M. and Barnes, S. (1982), ``Advertising regulation in Australia: an evaluation'', The Adelaide Law Review, Vol. 8 No. 1, February, pp. 29-60. Boddewyn, J.J. (1985), ``Advertising self-regulation: private government and agent of public policy'', Journal of Public Policy and Marketing, Vol. 4, pp. 129-41. Boddewyn, J.J. (1988), Advertising Self-Regulation and Outside Participation: A Multinational Comparison, Quorum Books, CT. Boddewyn, J.J. (1989), ``Advertising self-regulation: true purpose and limits'', Journal of Advertising, Vol. 18 No. 2, pp. 19-27. Boddewyn, J.J. (1992), Global Perspectives on Advertising Self-Regulation, Quorum Books, Westport, CT. Byrt, W. (1990), Business and Government in Australia, Macmillan, Australia. Drake, R. (1988), ``The portrayal of women in advertising'', Consuming Interest, December, p. 21. Easterby-Smith, M., Thorpe, R. and Lowe, A. (1993), Management Research: An Introduction, Sage, London. Garvin, D.A. (1983), ``Can industry self-regulation work?'', California Management Review, Vol. 25 No. 4, Summer, pp. 37-52. Harker, D. (1997), ``The control of advertising in New Zealand and Australia: learning from success and failure'', Policy, Organisation and Society, Vol. 14, Winter, pp. 57-81. Harker, D. (1998), ``Achieving acceptable advertising: an analysis of advertising regulation in five countries'',

International Marketing Review, Vol. 15 No. 2, pp. 101-18. Harker, D. and Graham, P. (1999), ``Effective advertising self-regulation: furthering the debate'', Policy, Organisation and Society, No. 18, Summer. Jick, T.D. (1979), ``Mixing qualitative and quantitative methods: triangulation in action'', Administrative Science Quarterly, Vol. 24 No. 4, pp. 602-11. La Barbera, P.A. (1980), ``Analyzing and advancing the state of the art of advertising self-regulation'', Journal of Advertising, Vol. 9 No. 4, pp. 27-38. Media Council of Australia (1994), The Media Council of Australia, Sydney. Media Council of Australia (1996), Media Release, September 27, Sydney. Miracle, G.E. and Nevett, T. (1987), Voluntary Regulation of Advertising: A Comparative Analysis of the UK and US, DC Heath, MA. Mittal, B. (1994), ``Public assessment of TV advertisements: faint praise and harsh criticism'', Journal of Advertising Research, Vol. 34 No. 1, pp. 35-53. Moyer, M.S. and Banks, J.C. (1977), ``Industry selfregulation: some lessons from the Canadian advertising industry'', in Thompson, D. (Ed.) Problems in Canadian Marketing, AMA, Chicago, IL, pp. 185-202. Nancarrow, C., Wright, L.T. and Woolston, C. (1998), ``Pretesting international press advertising: the need for informed consensus on methodology'', Qualitative Market Research: An International Journal, Vol. 1 No. 1, pp. 25-38. Neelankavil, J.P. and Stridsberg, A.B. (1980), Advertising Self-Regulation: A Global Perspective, Communications Arts Books, New York, NY. Petty, R.D. (1997), ``Advertising law in the United States and European Union'', Journal of Public Policy and Marketing, Spring, Vol. 16, pp. 2-13. Pincus, J.J. and Withers, G.A. (1983), ``Economics of regulation'', in Gruen, F.H. (Ed.), Surveys of Australian Economics, Vol. III, pp. 9-76. Sinclair, J. (1992), ``Globalisation and national culture: structure, regulation and content in the advertising industry in Australia'', Policy Research Paper No. 24, Centre for International Research on Communication and Information Technologies, June. Strickland, K. (1996), ``Tasteless ads code to vanish'', The Australian, p. 5, September 28-29, Sydney. Van de Ven, A.H. (1992), ``Suggestions for studying strategy process: a research note'', Strategic Management Journal, Vol. 13, pp. 169-88. Weiers, R.M. (1988), Marketing Research, (2nd ed.), Prentice Hall, Englewood Cliffs, NJ. Wiggs, G. (1992), ``Self-regulation a mix of judicial and marketing principles'', unpublished essay, Advertising Standards Complaints Board, New Zealand.

206