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Policy substitution

Policy substitution here refers to actions taken by alcohol industry actors, independently of government regulation, that are ostensibly for the social good. There are two main types of activity that fall under this heading: corporate social responsibility and industry self-regulation.

Corporate Social Responsibility

Different definitions of Corporate Social Responsibility (CSR) reflect the range of opinion on how it should be understood. Some definitions interpret CSR in ethical terms – according to Yoon and Lam, “In its original sense, the term CSR is defined as a moral and stakeholder obligation, emanating from a notion that business is responsible to society in general and thus corporations should be answerable to those who directly or indirectly affect or are affected by a firms activity”.[1] By contrast, Babor and Robaina offer a more functional definition of CSR in terms of its benefits for the company engaging in it: “We define CSR as business practices that help companies manage their economic, social, and environmental impacts as well as their relationships in key areas of influence”.[2]

In practice, alcohol industry CSR covers a range of activities, including public awareness campaigns and educational programmes on the harms of alcohol, voluntary ethical codes on activities such as marketing and retail, research grants, sponsorship schemes and charitable activities. Individual firms have their own projects, but the Beer, Wine and Spirits Producers’ Commitments to Reduce Harmful Drinking, agreed in 2012 by 12 of the largest global drinks companies,[3] provides an overarching framework, collating a number of these initiatives around five key themes:[4]

  1. Reducing underage drinking e.g. working with governments to assist in the enforcement of minimum purchase age regulations, raising awareness of underage drinking, age verification schemes and server training
  2. Strengthening and expanding marketing codes of practice e.g. voluntarily reducing the exposure of children to alcohol advertising and limiting underage access to online marketing materials
  3. Providing consumer information and responsible product innovation e.g. specialist websites to provide information on ‘responsible drinking’; labeling that discourages drinking and driving, underage drinking and consumption by pregnant women
  4. Reducing drinking and driving e.g. educational campaigns, driving school curricula, legislative efforts, sobriety checkpoints
  5. Enlisting the support of retailers to reduce harmful drinking e.g. discouraging ‘irresponsible’ promotions, guidelines and training to avoid serving underage or heavily intoxicated drinkers

There is substantial debate about the motives behind the alcohol industry’s CSR initiatives. Babor and Robaina identify three different types of reasons for embarking on CSR projects:[5]

  1. Altruistic – Actions which are pursued for ethical reasons, and not because of any benefit to the company (besides, perhaps, incidental benefits to reputation and image). Indeed, altruistic CSR activities often carry a cost to the business.
  2. Risk management – Actions taken because they are mandated by law, or because they help companies to resist statutory regulation. Most prominent among these are voluntary industry regulatory codes (see figure 3). For example, AB InBev has stated that its internal marketing guidelines are a pre-emptive attempt to “protect our business from future regulatory restrictions to our current marketing and advertising freedom”.[6] Similarly, it has been alleged that participation in the UK Government’s Responsibility Deal pledges has been used by alcohol companies to undermine stricter state action.[7]
  3. Strategic – Strategic CSR aims to promote the business (primarily financial) interests of a company. For example, CSR activities contribute to the ‘framing’ of social issues around alcohol. It has been accused of normalising the consumption of alcohol and increasing its psychological availability. By regularly referring to alcohol as a normal part of a healthy lifestyle, ‘responsible drinking’ messages may undermine the status of abstinence as a legitimate choice.[8] CSR materials have also been found to emphasise the importance of personal responsibility and individual judgment in consuming alcohol.[9] This frame allows the industry to insist that alcohol harm is an issue only for a small minority of drinkers, and so to resist broader, structural population-based measures, such as raising alcohol taxes, which affect all drinkers. Another potential benefit of CSR for companies is that it can improve brand awareness and reputation. CSR can be used as a form of marketing to create positive associations with drinks companies in the minds of consumers. This is well exemplified by sponsorship of the arts and culture. Alcohol companies frequently provide endowments and scholarships to young artists, and help organise events and exhibitions.[10]

These three motives are not mutually exclusive: CSR can in principle be a ‘win-win’ activity, benefiting businesses and their wider community. Nevertheless, non-altruistic motives bring the possibility that companies will prioritise CSR activities that benefit themselves, rather than those they purport to help.

It has been suggested that these mixed motives lead to ineffective CSR programmes. Early findings of an analysis of over 3,500 industry initiatives has found that only 8% were considered as ‘evidence-based’ (i.e. likely to have significant positive effect on alcohol-related harm) by experienced public health experts. By contrast, 52% were rated as likely to cause harm, for example by increasing alcohol consumption. 40% were seen as likely to promote a brand or product.[11] This analysis indicated that the vast majority of CSR activities in the UK and US are best seen as risk management, with relatively few purely altruistic activities:[12]

 

The Public Health Responsibility Deal

The most prominent CSR initiative in the UK today is the Public Health Responsibility Deal (RD), a Government scheme under which businesses are encouraged to make voluntary pledges to take action to reduce public health harms. The RD was launched in 2011, and at present (December 2015), consists of 11 different pledges, each attracting a different set of signatories. Of these the most prominent are:[13]

Pledge A1: 80% of products in the off-trade will have labels with clear unit content, NHS drinking guidelines and warnings about drinking during pregnancy

Pledge A4: Action to reduce underage sales through the ‘Challenge 21’ and ‘Challenge 25’ programmes

Pledge A5: Financial support for the charity Drinkaware

Pledge A6: Restrictions on marketing, including a commitment not to advertise within 100 metres of schools, and a code for sponsorship

Pledge A8(a): The removal of 1 billion units of alcohol from the UK market by December 2015

The RD has been the subject of substantial criticism from academics and the public health community. Despite being designed as a partnership, a number of leading bodies, including the IAS, the British Medical Association and the Royal College of Physicians, boycotted the initiative, citing concerns that industry representatives were unduly influencing the process.[14] In 2013, most of the remaining public health organisations (including Cancer Research UK and Alcohol Research UK), as well as Prof Nick Sheron, co-chair of the Responsibility Deal Alcohol Network (RDAN), withdrew when the Government reversed its plans to introduce a minimum unit price for alcohol.[15] Consequently, the core remaining group of the RDAN is dominated by the alcohol industry, which provides 12 of the 15 representatives.[16] Moreover, of the three nominally independent NGOs involved, two (Addaction and Mentor UK) receive significant funding from the alcohol industry.[17]

The substance of the RD has also been criticised, with a Department of Health-funded independent review finding that most of the RD pledges “fall into the category of ‘probably ineffective’ or ‘no/poor/inconclusive evidence’”.[18] For example, it found little evidence to suggest that warning labels and responsible drinking messages have a significant impact on alcohol consumption. Conversely, the study claimed that “the most effective evidence-based strategies to reduce alcohol-related harm are not reflected consistently in the RD alcohol pledges. The evidence is clear that an alcohol control strategy should support effective interventions to make alcohol less available and more expensive”.[19]

Evaluation of the implementation of the RD pledges has often been controversial, due to the ambiguity of some the goals and issues around reporting practices. For example in 2014, the Department of Health suggested that the industry had met its commitments under pledge 8(a), and removed 1.3 billion units from the market due by formulating and promoting lower strength products.[20] However, this conclusion has been challenged by independent academic researchers, who claim it rests on unreliable data, an over-simplified model of consumer choice, and does not account sufficiently for confounding factors. Most significantly, they argue that the official evaluation does not distinguish the impact of industry action from other factors and underlying trends. This has led to calls for the Department of Health to withdraw the evaluation report, and to cease making references to the results until they can stand up to scrutiny.[21]

Objections have also been raised about the industry’s conduct in the official RD monitoring process. In 2013, Prof Mark Bellis, the public health Chair of the RDAN Monitoring and Evaluation (M&E) Group, resigned his position, claiming that “transparency and trust in the process has been eroded by data being delivered inappropriately to the industry’s Portman Group who not only failed to inform me that they had the data but also unilaterally asked for it to be revisited at least twice”.[22]

Pledge A1 has received the most extensive evaluation, with both an industry-funded review[23] and an independent Department of Health-funded academic study[24] of progress against labelling commitments. Both reports found that the industry has fallen short of its commitment of 80% compliance on labelling standards. However, it is clear that labelling has improved in some respects: the proportion of containers carrying pregnancy information has risen from 18% to 93%; the proportion carrying drinking guidelines has risen from 6% to 83% and the proportion carrying unit content has risen from 56% to 87%.[25] At the same time, only 47% of labels have been found to reflect what is considered ‘best practice’ by industry-agreed standards.[26] The average font size for health information on labels is 8.17, below the 10-11 point size that is optimal for legibility. 60% of labels display health information in smaller font than the main body of information on the label, contrary to official industry guidance. Pregnancy warning logos are significantly smaller on drinks targeted at women than those aimed at men. Moreover, they are frequently grey in colour, with only 10% in red, limiting the visibility of the warnings.[27]

The RD has also faced allegations that it has obstructed statutory regulation of the alcohol market. In his resignation letter, Mark Bellis claimed that “an industry representative even made it clear that their continued contributions to the deal were dependent on a minimum unit price not being implemented”. More generally, he believes “I have seen the Deal turned by industry into a tool to avoid actions that would improve people’s health”.[28]

 

Drinkaware

Pledge A5 of the RD commits to funding Drinkaware, an industry-supported charity[29] that provides information and advice on alcohol to consumers. Drinkaware pre-dates the RD, originally established by the Portman Group as a website, but spun off into a separate entity in 2007.[30] The Portman Group’s Code of Practice continues to suggest that producers should, wherever possible, feature the website address on brand labels, though this is just a recommendation rather than a formal part of the code.[31] Though Drinkaware insists that it is autonomous in its operations,[32] there is significant scepticism on this point. A 2013 independent review found there is “A perception of industry influence resulting in a suspicion that Drinkaware is not truly independent of the alcohol industry”.[33] A 2012 report of the UK Parliament’s Health Select Committee concluded that “if Drinkaware is to make a significant contribution to education and awareness over the coming years its perceived lack of independence needs to be tackled”.[34]

The efficacy of Drinkaware’s activities in countering alcohol harm is also disputed. The independent review found that the charity had met with some success in “building awareness of the Drinkaware logo and brand, gaining better understanding of marketing and behaviour change, piloting interesting initiatives and achieving some success with its parents and adults programmes”.[35] Its website received 8.3 million unique visitors in 2014, and its annual report cites self-reported anecdotal and survey evidence of people reducing their drinking as a result of its programmes.[36] However, the review criticised Drinkaware for its lack of measurable objectives and robust independent evaluation. It noted “The lack of an evidence base, both to inform what Drinkaware does and to evaluate how it does it”.[37] This criticism was accepted by the Drinkaware board, which has promised more academic evaluation in future[38] (for example, evaluation of the Drinkaware app was due to be submitted to a peer-reviewed journal in 2015).[39]

A common theme of critiques of Drinkaware, and industry educational initiatives more generally, is their ‘strategic ambiguity’: the possibility that their message may be interpreted differently by different audiences, and in some cases may actually encourage drinking.[40] For example, in October 2012, Drinkaware’s twitter account tweeted the message: “Want to make it to the witching hour and avoid feeling like a zombie tomorrow? Read our Halloween party tips…”. Content of this type has been criticised because it “normalizes alcohol use and provides cues to drink on occasions when it may not be planned” – in this case, because “there is no British tradition of Halloween parties involving alcohol”.[41]

Similarly, the Drinkaware campaign ‘You wouldn’t sober, you shouldn’t drunk’ has drawn objections for tacitly accepting drunkenness and emphasising individual self- control, without acknowledging the importance of context (e.g. intoxication) in limiting self-control.[42]

 

One experimental study found that people tend to drink more alcohol in the presence of a Drinkaware poster than without it”.[43] Drinkaware has acknowledged this research, and claims to have reviewed its approach in light of these findings.[44]

 

Self-regulation

The other significant form of policy substitution is industry self-regulation – voluntary codes of conduct agreed by companies as an alternative to legally binding government requirements. For example, the pledges included in the Public Health Responsibility Deal, particularly those relating to labelling, can be seen as an attempt to avoid statutory labelling requirements.

In the UK, self-regulation is most developed with respect to marketing. As mentioned previously, the industry-funded Portman Group is responsible for overseeing the Code of Practice on the Naming, Packaging and Merchandising of Alcoholic Drinks. This lays down standards for forms of promotion other than advertising (which is regulated by the merchandise and sampling.[45] For example, the code forbids marketing material which incorporates images of under-25s, suggests drinking is associated with social success, emphasises the strength of a drink or encourages “irresponsible or immoderate consumption”, or which is placed in media where over 25% of the audience is under 18.[46] According to the Portman Group, it is “widely credited with raising standards of marketing responsibility across the industry”.[47]

Yet contrary to these guidelines, analysis of industry documents as part of the House of Commons Health Select Committee inquiry into alcohol has shown that these restrictions regularly fail to restrain marketers, finding:[48]

  • Evidence of targeting of children, with market research conducted on 15–16 year olds, Lambrini referred to as a “kids’ drink”, and WKD being targeted at “new 18-year-olds”
  • Brands such as Smirnoff evading the restrictions on emphasising strength, noting “potency can be communicated in a number of ways”, such as making reference to the drink being “ten times filtered or triple distilled”, which “both result in increased purity and therefore increased strength”
  • Brands neglecting rules against linking drinking with social success – for example, Carling sought to “own sociability”, while Lambrini was described as a “social lubricant”  
  • Marketing tactics associating brands with sexual attractiveness – such as Smirnoff Black’s attempt to present itself as “urbane”, “masculine” and “charismatic” and Lambrini’s campaign to find the “Lambrini girl” with the “UK’s sexiest legs”.

 

Hastings et al conclude that existing regulators fail to address the sophisticated strategies of marketers, which exploit the ambiguities in the current code. They conclude that independent regulation is necessary to avoid such lapses.[49]

 

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[1] Yoon, S. & Lam, T-H. (2013), The illusion of righteousness: corporate social responsibility practices of the alcohol industry, BMC Public Health 13:630.

[2] Babor, T. & Robaina, K. (2013), Public Health, Academic Medicine, and the Alcohol Industry’s Corporate Social Responsibility Activities, American Journal of Public Health 103, pp. 206–14.

[3] Beer Wine Spirits Producers’ Commitments Website, About the Commitments [Accessed 18 December 2015].

[4] Beer Wine Spirits Producers’ Commitments Website, Commitments [Accessed 18 December 2015].

[5] Robaina, K et al (2014), Effectiveness and Strength of Evidence of the Alcohol Industry’s ‘Industry Actions to Reduce Harmful Drinking’, American Public Health Association 142nd Annual Meeting & Expo, November 19th, New Orleans.

[6] Yoon & Lam, op. cit.

[7] Institute of Alcohol Studies Freedom of Information Request. [Accessed 18 December 2015].

[8] Babor, T., Robaina, K. & Jernigan, D. (2015), The influence of industry actions on the availability of alcoholic beverages in the African region, Addiction 110, pp. 561–71.

[9] Yoon & Lam, op. cit.

[10] Ibid.

[11] Robaina, K. et al (2014), op. cit.

[12] Ibid.

[13] Department of Health, Pledges [online]. [Accessed 14 March 2016]

[14] Royal College of Physicians (2011), Key health organisations do not sign responsibility deal. [Press release]. [Accessed 21 October 2015].

[15] Cancer Research UK, Faculty of Public Health, UK Health Forum & Sheron N (2013), Joint statement by Cancer Research UK, Faculty of Public Health, UK Health Forum and Nick Sheron, Responsibility Deal Alcohol Network Co-Chair, Head of Clinical Hepatology, University of Southampton [Press release]. [Accessed 2 November 2015].

[16] Department of Health, Alcohol network’s core group [online], [Accessed 14 March 2016].

[17] Lyness S.M. & McCambridge, J. (2014) The alcohol industry, charities and policy influence in the UK. European Journal of Public Health 24, pp. 1–5.

[18] Knai C., Petticrew M., Durand M. et al (2015). Are the Public Health Responsibility Deal alcohol pledges likely to improve public health? An evidence synthesis. Addiction 110, p. 1,236.

[19] Knai et al, op. cit., p. 1232.

[20] Health Improvement Analytical Team (2014), Responsibility Deal: Monitoring the number of units of alcohol sold – second interim report, 2013 data. London: Department of Health.

[21] Holmes J. et al (2015) UK alcohol industry’s “billion units pledge”: Interim evaluation flawed. BMJ 350.

[22] Institute of Alcohol Studies Freedom of Information Request.

[23] Campden BRI (2014) Audit of compliance of alcohol beverage labels available form the off-trade with the Public Health Responsibility Deal Labelling Pledge, p. 23.

[24] Petticrew, M. et al (2015) Health information on alcoholic beverage containers: has the alcohol industry’s pledge in England to improve labeling been met? Addiction 110, doi: 10.1111/add.13094.

[25] Campden BRI (2014), op. cit, p. 5.

[26] Campden BRI (2014), op. cit., p. 23.

[27] Petticrew et al, op. cit.

[28] Institute of Alcohol Studies Freedom of Information request. 

[29] Drinkaware, Information about our supporters [online]. [Accessed 14 March 2016].

[30] Portman Group, Timeline [online]. [Accessed 16 March 2016].

[31] Portman Group (2013), Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks. [Accessed 14 March 2016].

[32] House of Commons Health Committee (2012), Written evidence from Drinkaware. [Accessed 16 March 2016].

[33] Asscher, J. et al (2013), Independent review of The Drinkaware Trust (2006-2012), p. 12.

[34] House of Commons Health Committee (2012), Government’s Alcohol Strategy Third Report of Session 2012-13, HC 132.

[35] Drinkaware (2015), Drinkaware Annual Report. For the year ended 31st December 2014. [Accessed 16 March 2016].

[36] Ibid.

[37] Asscher et al, op. cit., p. 11.

[38] Drinkaware (2013), Response of the Board of The Drinkaware Trust to the Drinkaware Audit Recommendations 2013. [Accessed 14 March 2016].

[39] Drinkaware (2015), Drinkaware Annual Report. For the year ended 31st December 2014. [Accessed 16 March 2016].

[40] Smith S. W. et al (2006), Are ‘drink responsibly’ alcohol campaigns strategically ambiguous?, Health Communication 20:1 pp. 1–11.

[41] McCambridge et al, Be aware of Drinkaware, op. cit.

[42] Institute of Alcohol Studies (2015), Dead on Arrival? Evaluating the Public Health Responsibility Deal for Alcohol. [Accessed 18 March 2016].

[43] Moss A., Albery I., Dyer K. et al. (2012) The effects of responsible drinking messages on attentional allocation and drinking behavior. Addictive Behaviors 44.

[44] Asscher et al, op. cit., p. 62. 

[45] Portman Group, Timeline [online]. [Accessed 16 March 2016].

[46] Portman Group (2013), Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks. [Accessed 14 March 2016].

[47] Portman Group, Timeline [online]. [Accessed 16 March 2016].

[48] Hastings, G. et al (2010), Alcohol advertising: the last chance saloon, BMJ 340, pp184–6.

[49] Ibid.