On our 10-minute drive to school through Melbourne’s leafy Eastern suburbs recently, my daughter and I saw billboards advertising the “World’s Thinnest Condom” and “Melbourne’s Best Brothel”. It made us both feel uncomfortable, but I naturally wondered whether other consumers react the same way.

Apparently many do. According to a pre-Christmas news release from the Advertising Standards Bureau, the Advanced Medical Institute’s garish posters for premature ejaculation were the second most-complained-about ads of 2007. More than 140 consumers complained to the Bureau, but the Advertising Standards Board dismissed the complaint.

In fact, the ASB’s website lists eight different AMI ads – outdoor and radio – that were the subject of complaints during 2007 and a total of more than 20 separate determinations by the Board following consumer complaints about AMI ads going back to 2001.

So who’s complaining? Is it moral crusaders or little old ladies? The ASB provides a selection of quotes from complaints received in each case, and they mainly seem to be rational and based around practical parenting issues, not morals:

These ads are not suitable for children to be hearing… These ads are being played all through the day and I am now having to explain to my young daughters what an erection is and what is ejaculation… I understand these companies have a right to advertise, I also have a right to choose when I speak to my children about adult conditions.

In 2004, the Bureau received a complaint about an AMI billboard that carried the words “Stronga, Longa, Donga!” and the call to action “Improve your s-x life”:

I have a six year old daughter who is avidly learning to read at the moment and loves to try to read signs, billboards, number plates, and so on, as we drive along. I did not appreciate having to try and explain to her what it said and what it meant.

Other complaints have addressed the confronting nature of the ads and their inappropriateness for an outdoor advertising context:

The advertiser has aimed to attract attention by being jarringly crude…

Suffering from erectile dysfunction is a complicated issue which should be discussed with a doctor not on a roadside billboard.

But all of the complaints about AMI’s billboards have been dismissed by the Board. Why?

Only one complaint about an AMI radio ad has been upheld, and this related specifically to the euphemistic use of the term “special cuddles” and its possible effects on children. Yet in 2006 the Board considered that “most people” would not find the words “shagging”, “bonking” and “horizontal folk dancing” offensive in a radio commercial. A confident AMI did not even submit a response to that complaint.

When AMI does submit a response, it usually takes the line that the language is not s-xually explicit and does not breach the Code of Ethics.

 On one occasion, in February 2007, AMI actually tendered in support of its position the views of prominent adolescent psychologist Dr Michael Carr-Gregg who, it claimed:

…is of the view that you should start s-x education confrontation (sic) of this subject as early as possible. It is in no way suggested that AMI is part of this education personally but rather that it is naïve and unrealistic to think that young teenagers (8-14) are unaware of the subject nor should they be guarded from it.

Does Dr Carr-Gregg really believe that it’s OK for AMI to effectively force parents to confront “this subject” – which, in context, can only be taken to mean premature ejaculation, not more general s-x education – with 8-year-olds? This seems incongruous, especially given that his own website carries links to various articles and resources about cyber-safety and adult content web filters, with the recurring theme of parents being aware of what their children are doing, and being exposed to, online.

In the latest issue of the ASB’s “AdStandards News“, Board member and retired Uniting Church Minister Ann Drummond notes that “in the end the Board is only as good as the Codes it upholds and I think that there are some areas of the Codes which could be reviewed to reflect new and growing community concerns and standards.” But which community standards?

Late in 2007, the ASB released – in a 2-page flyer – an outline of the findings of extensive consumer research especially commissioned on its behalf. Interestingly, the research found that “when compared to the Board, the community is more conservative in their attitude towards s-x, s-xuality and nudity”. The report goes on to say that “Board members have embraced the community feedback”.

Former Federal Tourism Minister John Brown gives some indication that he and fellow Board members may be taking notice of complaints when he acknowledges in “AdStandards News” that billboards may be a special case:

They differ to other forms of advertising because they’re permanent structures and people are forced to look at them constantly. People feel they have little control over what is shown on a billboard…

However, as to community standards on s-xual matters, it seems John Brown thinks it’s all in our dirty little minds and we’re all a lot of wowsers, i.e., that the “community” has actually got it wrong:

I’m staggered by the way some people can see s-xual innuendo in everything. I’m not sure why this type of complaint is becoming more prevalent, could it be that society has become more voyeuristic, and moralistic in their outlook, and it would seem, lacking in humour?

Alison Abernethy, ASB Communications Manager, wasn’t able to tell me whether these comments were made before or after John Brown “embraced” the community feedback. But she did emphasise that – even though he was quoted in the Bureau’s own newsletter – Mr Brown was speaking for himself and not on behalf of the Board.

The Advertising Standards Board justifies many of its decisions on how it feels “the majority of people” would react. But is this the right approach when a sizeable minority express significant concerns and the majority couldn’t give a rat’s if they never saw another “longer lasting s-x” ad again? The majority of us don’t make official complaints about spam emails, either, but we’ll pay extra for a decent spam filter.

It’s well accepted in marketing that actual complaints represent only the tip of the iceberg. Firms are urged to assume that for every customer who does complain, there are hundreds or even thousands who didn’t complain but were nonetheless disappointed, offended or made uncomfortable.

Ethical, market-oriented organisations ignore customer feedback at their peril, recognising that “a complaint is a gift“. The ASB would be well advised not to keep looking this particular gift horse in the mouth.

Peter Fray

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