Media Enquiry terms of reference: cross-media promotion E-mail
Written by Jonathan Hardy   
Sunday, 10 July 2011 18:37

There has been much recent comment about cross-promotion by media companies. The most pressing concern has been how Murdoch’s takeover of BSkyB would increase enormously the already close synergy and cross-promotion between News International’s media holdings. But cross-media promotion is not limited to Murdoch’s New Corporation, of course. Since he acquired Channel Five in July 2010, Richard Desmond’s Northern and Shell has heavily cross-promoted Express newspapers, OK magazine and TV, and the Five’s TV channels.  Uniquely, media reform is now at the top of the political agenda. Cross-promotion is an important component of the central issues that arise: reform of press regulation; the News Corp-BSkyB acquisition; media ownership regulation; media power. The terms of reference for an enquiry into media standards, regulation and ownership needs to include cross-media promotion. We have weak, discrete, analogue-era rules. There needs to be thorough review and overhaul to provide regulation for a fast-evolving, converged, multimedia environment.

The current regulatory framework for cross-promotion has origins in the Sadler Enquiry into Standards of Cross-Media Promotion (1991), triggered by News International’s cross-promotion of Sky and denigration of its then competitor British Satellite Broadcasting. For the press, the outcome was a weak voluntary code drawn up by publishers in 1994.


In 1991, shortly before the PCC drew up its first code, the Sadler Enquiry recommended that a code of practice on cross-media promotion should be incorporated into both the PCC code and the British Code of Advertising Practice. His report (Sadler 1991: 1–2) stated this should cover both advertising and editorial content and contain provisions relating to:

(i) access to and prices for advertising space
(ii) the distinction of advertisements from editorial copy and disclosure in advertisements of ownership links;
(iii) disclosure in the editorial content of newspapers of their owner’s or associates’ other media interests;
(iv) the application of professional journalistic standards to editorial content concerning matters in which the newspaper or an associate has an interest.

(Hardy 2010: 165-6, Cross Media Promotion, New York: Peter Lang)


The code was a careful effort in minimising obligations. It added nothing to existing rules for press or advertising and merely encouraged publishers to draw up individual in-house guidelines. On the key matter of editorial disclosure it stated that ‘substantial news and comment in a publication referring to an associate should normally include a statement about any relevant owner- ship link’. This fell short of Sadler’s recommendation that that newspapers should publish at regular intervals a list of significant media interests of its associates (Sadler 1991: 40). The PCC code itself was not amended… (Hardy 2010: 174)


For broadcasting, Sadler influenced greater restrictions on cross-promotion of commercial services and on BBC promotions. With increasing competition over digital TV services in the late 1990s, the ITC drew up rules on cross-promotions affecting promotional time and advertising, together with rules on commercial references within programmes. These were revised, and liberalised, by Ofcom (2006) although detailed regulation remains in place.  The present situation then is a weak, voluntary code for newspapers, a legacy of the early 1990s, no PCC attention, a television code, and almost nothing else except for the recent, interesting Office of Fair Trading action against online bloggers who endorse products and companies without clearly stating their relationship with the brand (see http://www.guardian.co.uk/technology/2011/jan/09/oft-clampdown-covert-twitter-endorsements). Regulation remains set for an analogue era and has failed to tackle the converged world of contemporary multimedia.


A media ownership, regulation and standards enquiry needs to address cross-media promotion. This might begin by considering some of Sadler’s recommendations. Sadler (1991:1) proposed that in addition to structural regulation of cross-media ownership, ‘newspapers and television programmes should disclose clearly to their readers and viewers their other media interests, both specifically when reporting or commenting on media issues and generally on a regular basis’. A starting point for reform would be to establish such disclosure requirements and to extend transparency standards as far as possible across all media. Where media companies, or individuals, are promoting products, services or channels in which they have an interest such interests should be declared, or be otherwise explicit, so that users/viewers may make their own assessment of the value and integrity of the information provided.


This needs to be accompanied by rules that prohibit or set limits to cross-promotions. Cross-promotions need to be governed by a regulatory framework that considers fair dealing for competitions (with appropriate exemptions for public service media), transparency and disclosure, editorial justification, creative integrity, the amount and scheduling of promotions, consumer benefits and consumer disbenefits, including promotional clutter.


Third, there needs to be updated rules on the identification and separation of media content (‘editorial’) and advertising, and special rules and safeguards on cross-promotion (and commercial references) for public communications that do merge content and advertising.


Corporate integration by firms vastly increased the scope and reach of cross-media promotion. I am not advocating (return to) a mono-media landscape, but the implications of convergence for cross-promotion needs to be addressed in regard to key values and objectives: media pluralism; cultural diversity; editorial integrity; consumer protection; democratic accountability.




Hardy, J. (2010) Cross-Media Promotion, New York: Peter Lang.

Newspaper Publishers’ Association, Newspaper Society, Scottish Daily Newspaper Society, Scottish Newspaper Publishers’ Association and Periodical Publishers Association (1994) Cross-Media Promotion Code, London: Newspaper Society.

Ofcom (2006) Cross-promotion Code, London: Ofcom.

Sadler, J. (1991) Enquiry into Standards of Cross Media Promotion: Report to the Secretary of State for

Trade and Industry, Cm1436. London: HMSO.