What you need to know about compliance with the Advertising Standards Authority guidelines 2023
Introduction to ASA guidelines "Advertising Standards Authority"
Are you a marketer or advertiser who wants to ensure that your campaigns comply with the standards set by the Advertising Standards Authority (ASA)? If so, then this article is for you! The ASA is an independent regulator in charge of enforcing advertising rules and guidelines across various media platforms. In this blog post, we'll be discussing everything you need to know about complying with the ASA's guidelines. From understanding their remit and governance to learning about sanctions and complaints procedures, as well as exploring examples of previous rulings - we've got it all covered! So let's dive into the world of advertising compliance together.
Remit and Governance of ASA
The Advertising Standards Authority (ASA) is an independent organization that regulates advertising in the UK. Their remit is to ensure that all advertising is legal, decent, honest and truthful. This means that they monitor ads across various media platforms, from television commercials to print advertisements.
As part of their governance structure, the ASA has a board of directors who are responsible for setting strategy and monitoring performance. They also have a council which makes final adjudications on complaints made against ads.
In addition to this, the ASA operates under a code of conduct which outlines specific rules around advertising content. For example, certain products such as alcohol or gambling may be subject to additional restrictions.
One important aspect of the ASA's governance is its ability to enforce sanctions on advertisers who breach their guidelines. These can range from informal agreements with companies to remove or amend ads, through to formal investigations and rulings.
The remit and governance of ASA play an important role in ensuring ethical advertising practices across multiple industries. By upholding high standards for ad content and enforcing penalties when necessary, they help protect consumers from misleading or harmful marketing messages.
Sanctions and Complaints Procedures
The ASA has the power to impose sanctions on advertisers who breach their guidelines. These sanctions can range from a simple reprimand to legal action. The severity of the sanction will depend on the nature and seriousness of the offence.
In addition to imposing sanctions, the ASA also has a complaints procedure in place for consumers who wish to make a complaint about an advertisement they have seen or heard. Complaints can be made via their website or by post, and must include details such as where and when the advertisement was seen, what medium it was advertised in, and why it is believed to be misleading or offensive.
Once a complaint has been received, it is assessed by one of the ASA's specialist teams who determine whether there are grounds for further investigation. If so, an investigation will take place which may involve contacting relevant parties including advertisers and media owners.
If an advertiser is found to have breached ASA guidelines following an investigation, they will be asked to amend or withdraw their advertisement. Failure to comply with this request could result in further sanctions including referral of non-compliant advertising material directly to Ofcom (the UK’s media regulator) for regulatory action.
It's important for advertisers and agencies alike to take these procedures seriously as non-compliance not only damages reputation but also results in significant financial loss due punishments like fines imposed by independent regulators such as Ofcom.
Types of Media and ASA guidelines
The ASA guidelines are applicable to different types of media, including print media, broadcast media, direct marketing, internet advertising, and sales promotions. Each has its own specific requirements that must be met in order to comply with the ASA rules.
Print Media such as newspapers and magazines should ensure their advertisements are clearly identifiable as such and don't resemble editorial content. Advertisers must also ensure their claims can be substantiated and avoid misleading consumers.
Broadcast Media includes TV commercials or radio ads that must adhere to timing restrictions set by Ofcom. Any inappropriate language or imagery is strictly prohibited on these platforms while ensuring commercial messages remain clear.
Direct Marketing includes phone calls or texts that cannot be made without prior permission from the recipient. Emails sent for promotional purposes are required to have an unsubscribe option included within them.
Internet Advertising covers website banners and social media adverts where advertisers need to make sure they do not use false information when promoting products/services online which could mislead people into buying merchandise they might not receive or may differ from advertisement images.
Sales Promotions include contests and sweepstakes that require clear instructions on how participants can enter alongside any terms & conditions included at every stage of the promotion process.
It's essential for all advertisers who want a successful campaign run across multiple channels - print, digital, television - alike must follow all guidelines provided by ASA for effective results
Print media has been a traditional form of advertising for many years, and it remains an important part of the marketing mix. However, with advances in technology, print ads have become more sophisticated and targeted. In order to comply with ASA guidelines, advertisers need to ensure that their print ads are truthful and not misleading.
One area where advertisers often fall foul of the ASA is in using exaggerated claims or unverifiable statements. For example, a cosmetic company might claim that their product can reduce wrinkles by 50%, without any scientific evidence to support this claim. This could be seen as misleading and result in sanctions being imposed.
Another area where print ads can cause problems is in making comparisons between products. Advertisers must ensure that any comparison made is fair and accurate, otherwise they risk being accused of making false claims.
It's important for advertisers to bear in mind the sensitivities around certain topics such as gender stereotypes or body image when creating print ads. The ASA has increasingly cracked down on these issues over recent years so it's essential for marketers to stay up-to-date with evolving guidelines.
While print media remains an important part of the advertising landscape, compliance with ASA guidelines is crucial if brands want to avoid reputational damage or legal action from consumers or competitors alike.
Broadcast Media is an important advertising channel that reaches a wide audience. However, it comes with its own set of regulations and guidelines from the ASA. These rules apply to all types of broadcast media including television, radio, cinema and video-on-demand services.
One key aspect of compliance in broadcast media is ensuring that advertisements are clearly distinguishable from editorial content. This means making sure that adverts are not presented as news or other forms of programming.
Another crucial rule for advertisers to follow in their broadcast media campaigns is avoiding promoting harmful or offensive content. Offensive material must be avoided at all costs, whether it's related to race, gender identity, religion or sexual orientation.
Broadcasters need to ensure they adhere to rules around scheduling ads during certain times such as children’s programming where certain products may not be advertised during these time slots.
It's critical for advertisers using Broadcast Media channels to understand the various regulations and guidelines set forth by ASA governing body before launching any campaign on this medium.
Direct marketing is a powerful advertising tool that targets specific groups of consumers through mail, email, or phone calls. However, it must comply with ASA guidelines to avoid misleading claims or aggressive tactics that may result in complaints.
To ensure compliance with these guidelines, direct marketers should clearly indicate the identity and contact details of the sender on all communications and provide an opt-out option for recipients who do not wish to receive further messages.
Moreover, marketers should avoid making exaggerated or unsubstantiated claims about their products or services to avoid misleading customers. It's also important to respect consumer privacy by obtaining consent before collecting personal data and using it responsibly according to data protection laws.
Direct marketing can be an effective way to reach out to potential customers if done ethically and legally within ASA guidelines.
The internet has become an integral part of our daily lives, and advertising on the internet is a common practice. However, advertisers need to be aware of the ASA guidelines when it comes to online advertising.
Any advertisements on websites or social media platforms must be clearly labeled as such. This means that consumers should easily recognize them as advertisements and not mistake them for organic content.
In terms of influencer marketing, influencers must disclose any commercial relationships with brands they are promoting. This includes putting #ad or #sponsored in their posts.
Advertisers cannot make claims that are misleading or unsupported by evidence. They also cannot use language that could be considered harmful or offensive towards certain groups of people.
Data protection is crucial when it comes to online advertising. Advertisers need to ensure that they comply with GDPR regulations and obtain consent from users before collecting their data for targeted ads.
Compliance with ASA guidelines is important in all forms of advertising - including online advertising - to maintain consumer trust and avoid sanctions from regulatory bodies like the ASA.
Sales promotions are a popular way for businesses to increase sales and attract new customers. However, it is important to ensure that any promotional material adheres to the guidelines set out by the Advertising Standards Authority (ASA) in order to avoid potential sanctions.
When it comes to sales promotions, there are several key areas where companies should pay particular attention. Promotions must be clear and transparent about what is being offered and how consumers can take advantage of it. Misleading or false claims could result in complaints being made against the company.
Promotions should not encourage irresponsible behaviour such as excessive spending or drinking alcohol excessively. This includes ensuring that any prizes or rewards associated with the promotion do not promote harmful behaviour.
Businesses must ensure that they have adequate resources and procedures in place for handling any complaints related to their sales promotions. This includes having a dedicated customer service team who can respond promptly and effectively to any issues raised.
While sales promotions can be an effective marketing tool for businesses, it is important that they are conducted responsibly and within compliance of ASA guidelines.
Time Limits and Data Protection
As an advertiser, it's important to know that the Advertising Standards Authority (ASA) has strict guidelines regarding time limits and data protection. In terms of time limits, advertisers must ensure that their ads are up-to-date and relevant at all times. This means that if an ad contains a specific date or deadline, it must be removed after this has passed.
Additionally, advertisers must also adhere to data protection laws when collecting personal information from consumers for advertising purposes. The General Data Protection Regulation (GDPR) requires companies to obtain explicit consent from individuals before collecting their personal data, and they must also provide clear information about how this data will be used.
In some cases, advertisers may need to seek legal advice on how best to protect consumer data while still meeting their marketing goals. It's essential that any personal information collected is stored securely and only used in accordance with GDPR regulations.
Compliance with time limits and data protection regulations is crucial for maintaining consumer trust and avoiding potential legal issues down the line. As such, it's vital that businesses understand these requirements fully before embarking on any new advertising campaigns.
Investigations and Appeals Procedure
The ASA is responsible for investigating complaints and breaches of its guidelines. When a complaint is made, the ASA will consider whether an ad has breached its guidelines and if further action needs to be taken.
If a breach is found, the advertiser may be asked to withdraw or change their ad. If they refuse or are unable to do so, sanctions such as publication of an adjudication against them may be imposed. In extreme cases, legal proceedings could also follow.
However, advertisers have the right to appeal against any decision made by the ASA. This can take place through an independent review conducted by the Independent Reviewer appointed by CAP (Committee of Advertising Practice). The process involves submitting written evidence and presenting arguments in front of an independent panel.
It's important for advertisers to understand that while investigations and appeals processes can seem daunting, they exist to ensure compliance with advertising standards and protect consumers from misleading or harmful content.
Therefore it's crucial that advertisers make sure their ads meet all requirements set out in the ASA guidelines before releasing them publicly. By doing this they can avoid costly sanctions or legal actions which could damage their reputation and brand image.
Noteworthy Rulings and Bad Publicity
The Advertising Standards Authority has made several noteworthy rulings over the years, some of which have resulted in bad publicity for the companies involved. One such example is the infamous "beach body ready" campaign by Protein World, which received a barrage of complaints and negative press due to its use of an allegedly unrealistic body image.
Another prominent case was that of Paddy Power's controversial ad featuring Olympic athlete Oscar Pistorius with the tagline "money back if he walks". The ad was deemed offensive and insensitive following Pistorius' murder trial, resulting in widespread criticism and calls for it to be banned.
In recent years, there has been increased scrutiny on gender stereotyping in advertising. In 2019, a Volkswagen ad featuring men engaged in adventurous activities while women sat passively was banned after receiving numerous complaints about perpetuating harmful stereotypes.
It is essential for advertisers to stay up-to-date with ASA guidelines and ensure their campaigns do not breach them. Not only can non-compliance result in sanctions and reputational damage but also potential legal action from consumers or competitors who may feel aggrieved by an advertisement.
Copy Advice and CAP Compliance Team
Copy Advice is a free service provided by the Advertising Standards Authority (ASA) to help advertisers and marketers comply with their regulations. The Copy Advice team provides guidance on whether an ad complies with the UK advertising codes, which includes detailed advice on how to make changes to ensure compliance.
The ASA's Committee of Advertising Practice (CAP) Compliance Team works closely with the Copy Advice team to provide support for businesses seeking advice or facing enforcement action. CAP also offers training courses for businesses and agencies looking to improve their understanding of the rules.
The Copy Advice team can be contacted via email or phone, and typically responds within two working days. They offer pre-publication advice as well as post-publication advice if required. This service is especially useful for small businesses who may not have access to in-house legal teams or extensive marketing departments.
It should be noted that while following copy advice does not guarantee an ad will comply with all regulations, it does demonstrate a good faith effort towards compliance which may be taken into consideration during any investigations or complaints procedures.
Other Regulatory Bodies and ASA
The Advertising Standards Authority (ASA) is not the only regulatory body that oversees advertising in the UK. Other organizations, such as the Office of Fair Trading (OFT), Ofcom, and local trading standards offices also have a role to play.
The OFT has powers under consumer protection law to take action against businesses who engage in misleading or aggressive commercial practices. They can investigate complaints from consumers and take legal action if necessary.
Ofcom regulates broadcast media, including TV and radio advertising. They ensure that advertisements comply with broadcasting codes and do not cause harm or offence to audiences.
Local trading standards offices work to protect consumers from unfair trading practices by enforcing consumer protection legislation. They investigate complaints about false or misleading advertising claims made by businesses operating within their jurisdiction.
While these bodies may have different remits than ASA, they all work towards ensuring fair advertising practices are upheld across various industries and mediums in the UK.
Office of Fair Trading
The Office of Fair Trading (OFT) was a regulatory body that played a crucial role in the UK's consumer protection landscape. It operated between 1973 and 2014, when it merged with other organizations to form the Competition and Markets Authority (CMA).
During its time as an independent regulator, the OFT had overlapping responsibilities with ASA; both bodies were tasked with ensuring businesses advertising their products or services met certain standards. However, while ASA focused on specific advertising content, OFT examined wider commercial practices such as pricing strategies.
The OFT also enforced competition law by combating anti-competitive behaviors including price fixing and abusing market power. The regulator had powers to fine companies up to 10% of their annual turnover for violating these regulations.
Although the OFT no longer exists as an individual entity, its legacy lives on through CMA which continues to regulate competition law within the UK.
Ofcom, or the Office of Communications, is a regulatory body in the UK that oversees telecommunications and broadcasting. While ASA focuses on advertising standards, Ofcom ensures compliance with all regulations related to media communications.
One of Ofcom's major responsibilities is ensuring fair competition among companies within its remit. This includes regulating activities such as mergers and acquisitions to ensure they do not harm consumers.
Another important aspect of Ofcom's work involves promoting diversity and accessibility in media content. This means ensuring that broadcasters are providing programming that meets diverse audience needs and interests.
In addition, Ofcom has been particularly active in addressing issues around online safety for children. The agency has introduced strict measures aimed at protecting minors from harmful content online.
It’s worth noting that while ASA operates independently from the government, Ofcom receives funding directly from parliament. As a result, there may be additional political considerations involved when it comes to how this regulatory body enforces its rules and guidelines.
Examples of Previous Rulings
The Advertising Standards Authority has made several noteworthy rulings over the years. These serve as a guide for advertisers looking to promote their products or services while adhering to ASA guidelines.
One of the most high-profile cases was the advertising campaign by Shell, which claimed that they were investing in renewable energy sources. The ASA ruled that these claims were misleading and exaggerated, as only a tiny fraction of Shell's total investment went towards renewable energy.
Another significant ruling involved gender stereotyping in advertising. In 2019, the ASA banned gender stereotypes in advertisements after receiving numerous complaints about ads perpetuating harmful stereotypes.
Misleading claims are also common issues addressed by the ASA, with companies often exaggerating product benefits or making false promises. Misleading claims can be particularly prevalent in health and beauty advertising, where companies may make unrealistic promises regarding weight loss or anti-aging benefits.
Online advertising is another area where regulations are often violated. Influencer marketing campaigns have been under scrutiny by the ASA due to influencers failing to disclose sponsored content properly.
Previous rulings show that adherence to Advertising Standards Authority guidelines is crucial for businesses who want their advertisements to be compliant and avoid sanctions from regulatory bodies like OFCOM or CAP Compliance Team.
Advertising in the Energy Sector
Advertising in the energy sector is an area that has come under close scrutiny by the ASA due to concerns over misleading claims. The aim of these guidelines is to ensure that all advertising materials are truthful, accurate, and not misleading, so as not to deceive consumers.
One key issue for companies in this sector is ensuring that their claims about environmental benefits or energy savings are substantiated with robust evidence. If such claims cannot be backed up with reliable data, advertisers risk being found in breach of the rules.
Another important factor for companies operating within the energy sector is making sure they do not exaggerate their products' capabilities or make false comparisons with other products on the market. Advertisers must avoid using superlatives such as "the best" without providing clear justification for such statements.
In addition, advertisers should take care when presenting information relating to pricing and tariffs. They must ensure any advertised prices are transparent and accurately reflect what customers can expect to pay.
It's essential that advertisers working in this field operate ethically and responsibly while promoting their goods and services. By adhering closely to ASA guidelines around truthfulness and accuracy in advertising copy, businesses can build trust among consumers while ensuring fair competition within a highly regulated industry.
Alcoholic Beverage Advertising
Alcoholic beverage advertising has always been a sensitive topic, with concerns about promoting alcohol to minors and encouraging irresponsible consumption. The ASA guidelines state that advertisements should not imply that drinking can improve social or sexual success, nor should it depict excessive drinking. Advertisements for alcoholic drinks must also include a responsible drinking message, such as "drink responsibly" or "enjoy in moderation."
In addition to these general rules, specific regulations apply to different types of drinks. For example, whiskey ads cannot suggest that the drink is capable of changing mood or behavior while beer ads can only show moderate levels of alcohol consumption.
The ASA is particularly strict when it comes to targeting children and young people. Advertisements for alcoholic beverages must not be placed where they are likely to be seen by those under 18 years old.
Advertisers need to balance their desire for creative promotion with the responsibility and care needed when advertising potentially dangerous substances like alcohol.
Environmental Claims Advertising
Environmental Claims Advertising is an important aspect of advertising that has been given great attention by the ASA. Any advertisement claiming environmental friendliness and sustainability must be supported with substantial evidence, failing which it may be considered misleading or deceptive.
Advertisers must ensure that their claims are not vague or overgeneralized. The claim should refer to a specific environmental benefit rather than being generic and ambiguous. Advertisers should also avoid using words like “green”, “eco-friendly” and other similar terms unless they can provide clear evidence supporting such claims.
The advertiser must substantiate their claim with adequate proof. This may include research data, industry certification or independent third-party verification of their product's eco-friendliness. If the claimed benefits cannot be fully substantiated, then advertisers will have to modify them accordingly.
The ASA has established strict guidelines for Environmental Claims Advertising in order to protect consumers from false claims about products' environmental impact. As companies continue to prioritize corporate social responsibility (CSR), it is essential for marketers and advertisers alike to adhere strictly to these guidelines when promoting environmentally friendly products.
To conclude, as more consumers become aware of the importance of protecting our environment through sustainable means, advertising agencies must remain mindful of the strict regulations surrounding Environmental Claims Advertising set out by the ASA while effectively communicating any genuine environmental benefits associated with their clients’ products/services in order not to mislead customers into making uninformed decisions based on unsupported marketing statements made by businesses trying only to maximize profits without regard for societal values beyond profit-making objectives alone.
Influencer marketing has become a popular advertising tactic for many brands in recent years. However, it is not exempt from the regulations of the Advertising Standards Authority (ASA) guidelines. Influencers must adhere to the same standards as traditional advertisers when it comes to disclosing sponsored content and avoiding misleading claims.
One important aspect of influencer marketing compliance is clearly indicating when posts are sponsored or paid promotions. This can be done through hashtags such as #ad or #sponsored, but simply thanking a brand may not suffice if there is an exchange of goods or payment involved.
It's also essential that influencers avoid making false or misleading claims about products they promote. They should ensure that their statements align with scientific evidence and that any endorsements made are truthful and genuine.
The ASA guidelines also require influencers to disclose any material connections they have with brands they're promoting beyond monetary compensation, such as free products or gifts. This ensures transparency for consumers who may be influenced by their recommendations.
Adherence to ASA guidelines in influencer marketing helps maintain trust between brands, influencers, and consumers while ensuring fairness in advertising practices.
Misleading Claims Advertising
Misleading claims in advertising can be a serious issue, as they have the potential to deceive consumers and lead them to make uninformed decisions. The ASA is committed to ensuring that all advertisements are truthful and accurate, and misleading claims are one of their major concerns.
In order for an advertisement to be considered misleading, it must contain a claim that is likely to mislead the average consumer. This could involve exaggerating the benefits of a product or service, making false comparisons with competitors' products, or omitting important information.
The consequences for breaching these guidelines can be severe - companies may face fines or legal action if they continue to make misleading claims. It's therefore essential that advertisers ensure their claims are backed up by solid evidence before making any statements in their ads.
If you're unsure whether your ad could be seen as misleading, it's always best to seek advice from the CAP Compliance team before going ahead with any campaigns. They can help you ensure that your messaging is both effective and compliant with ASA guidelines.
Avoiding misleading claims in advertising isn't just about staying on the right side of regulators - it's also about building trust with consumers. By being honest and transparent about what your product or service offers, you'll create lasting relationships with customers who appreciate authenticity and fairness in advertising.
Online Advertising has become one of the most popular and influential forms of advertising in recent years. With billions of people surfing the internet every day, it is not surprising that businesses have turned to this form of advertising to reach their target audience.
However, online advertising also falls under the jurisdiction of ASA guidelines which means advertisers must be careful about what they post on websites and social media platforms. Misleading claims or exaggeration can lead to complaints from consumers and ultimately result in sanctions from ASA.
One particular area where online advertisers need to be cautious is influencer marketing. Influencers who fail to disclose sponsored content or mislead their followers may face repercussions from both ASA and their own fan base.
Additionally, online advertisements targeting children are subject to even stricter regulations as they are vulnerable audiences. Advertisers should always ensure adverts aimed at children do not contain harmful or inappropriate material.
While online advertising presents a wealth of opportunities for businesses looking to connect with customers, it is important that they remain mindful of the ASA guidelines when creating ads for digital platforms.
Gender Stereotyping Advertising
In today's world, gender stereotyping in advertising is a hot topic. It refers to the portrayal of individuals as conforming to traditional gender roles and expectations. These stereotypes can be harmful and contribute to gender inequality by reinforcing outdated ideas about how men and women should behave.
The ASA's guidelines state that ads must not include "gender stereotypes that are likely to cause harm, or serious or widespread offence." This means that advertisers need to be mindful of the language they use, the images they portray, and the messages they convey.
For example, an ad that shows a man doing all the DIY work while his wife looks on passively would likely be seen as perpetuating negative stereotypes about women being passive bystanders in home improvement projects. Similarly, an ad featuring young girls playing with dolls while boys play with cars could reinforce the idea that girls should only engage in nurturing activities.
It is important for advertisers to take these issues seriously and ensure their advertising does not contribute to harmful gender-based attitudes or behaviors. By promoting diversity and inclusivity in their messaging, companies can help break down harmful stereotypes and promote equality for all genders.
Health and Beauty Advertising
Health and beauty advertising is a popular type of advertising across all media channels. Advertisers in this industry must be careful to avoid making misleading or unsubstantiated claims about their products, as well as avoiding promoting unrealistic expectations.
The ASA has previously investigated ads for weight loss supplements that made exaggerated claims about their effectiveness and relied on before-and-after photos that were not representative of typical results. Similarly, advertisers can face consequences for using photoshop to enhance the appearance of models in advertisements for skincare or makeup products.
In addition to concerns about false or misleading claims, health and beauty advertising can also raise issues related to body image and self-esteem. The ASA has taken steps to address these concerns by prohibiting ads that promote harmful gender stereotypes or present an unrealistic portrayal of what bodies should look like.
It is important for advertisers in the health and beauty industry to prioritize honesty, accuracy, and sensitivity when developing ad campaigns. By doing so, they can build trust with consumers while staying compliant with ASA guidelines.
Television and Print Media Advertising
Television and print media advertising are two of the most common forms of advertising, but they also come with their own distinct set of guidelines. The Advertising Standards Authority (ASA) has strict rules when it comes to what can and cannot be advertised in these mediums.
For television advertisements, the ASA ensures that all ads are truthful, accurate, and not misleading. They also prohibit any content that may cause harm or offense to viewers. Additionally, there are specific rules around the use of children in TV commercials.
When it comes to print media advertising such as newspapers and magazines, the ASA is similarly concerned about accuracy and truthfulness in messaging. However, they also have additional guidelines around things like body image and gender stereotyping.
Both television and print media must adhere to specific time limits for ads during programming or publication. Any claims made within an advertisement must be able to be substantiated with evidence.
Both television and print media advertisers must exercise caution when creating campaigns as failing to comply with ASA regulations can lead to complaints being filed against them which could negatively affect their brand reputation.
Conclusion and Future Implications
Compliance with the Advertising Standards Authority guidelines is essential for any business that wants to operate ethically and legally in the UK. The ASA plays a crucial role in regulating advertising across all media platforms and ensures that adverts are truthful, honest, and not harmful to consumers.
By following these guidelines, businesses can protect their brand reputation while also avoiding heavy fines or legal action. It's important for companies to stay informed of changes made by regulatory bodies such as the ASA so they can adapt their marketing strategies accordingly.
As technology continues to advance rapidly, it's likely that new challenges will arise within the advertising industry. The ASA must continue to update its guidelines accordingly and ensure transparency in advertising standards. Businesses should always strive towards ethical practices when marketing their products or services.
Companies must recognize the importance of complying with the Advertising Standards Authority guidelines if they wish to succeed in today's market while maintaining ethical values at all times.