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Seven Suckers

oil on canvas
22 x 20 in

Penny Machines
oil on canvas
23¾ x 29¾ in

Stack of Books
oil on canvas
30 x 24 in

Seven Suckers
oil on canvas
19 x 23 in

Twin Jackpots
oil on canvas
30 x 46 in

oil on canvas
20 x 26 in

Cake Slices
oil on canvas
20 x 16 in

Marketing ethics

As a minimum our companies are expected to comply with all laws, regulations and codes of marketing practice. All advertising produced by WPP companies should present products fairly and accurately, comply with the relevant law and marketing codes, and reflect changing public attitudes to questions of taste and decency or marketing of sensitive products.

Our Code of Business Conduct and CR Policy set out our approach and provide guidance to our companies and our people on the standards we expect. We benchmarked our Code of Business Conduct during 2009 and strengthened clauses on CR. Key excerpts include:

“We will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability.

We will not undertake work which is intended or designed to mislead, including in relation to social, environmental and human rights issues.

We will consider the potential for clients or work to damage the Group’s reputation prior to taking them on. This includes reputational damage due to participating in business activities that abuse human rights. WPP companies will not undertake work designed to mislead in any respect, including social, environmental and human rights issues.

WPP companies will comply with applicable regulations and self-regulatory codes of practice in the countries in which they operate.”

Ethical issues in client work

Where we operate, who we work for and the type of work we undertake can give rise to ethical issues. Examples include: work undertaken for government clients; operating in countries with a poor human rights record; and marketing for sensitive or controversial products.

In cases where work may be a potential risk to WPP’s reputation, employees are required to elevate the decision to the most senior person in the relevant office and then to the most senior executive of the operating company in the country concerned, who will decide if further referral to a WPP director is required.

Strengthening our decision-making process

We have strengthened our internal processes for assessing risks associated with client work and prepared a training module on this subject. Broad cross-company training on the revised Code of Business Conduct will be rolled out during 2010.

When required we hold review meetings for senior managers at Group level to discuss cases of concern and identify new risk areas. The internal audit program of work now incorporates a review of the considerations given by management to possible impacts on the Group’s reputation prior to accepting new clients.

Involvement in industry groups

Many professionals from within WPP companies play an important part in developing and revising industry codes in sensitive areas such as advertising to children and the marketing of food and pharmaceutical products.


Few campaigns that we produce for clients provoke complaint, but occasionally complaints do occur relating to matters of taste or fact. In most countries these are arbitrated by government or industry organisations. More information is available in our Corporate Responsibility Report.


Privacy and data protection are priority issues for all our companies and we aim to meet best practice standards. Our research and digital companies contribute to the debate on privacy and aim to increase transparency for consumers on how their data is obtained and used.

Our approach

We are assisting our companies in developing a set of principles on privacy to guide their approach and provide a consistent definition of ‘personal information’. Many companies have additional privacy policies and procedures, and some have developed their own technology and tools to improve transparency. Some of our companies collect and use consumer data to study attitudes and purchasing habits and to create targeted digital and direct marketing campaigns. We endeavour to comply with data protection laws and marketing codes of practice as applicable.

Our internal audit function is including privacy in its reviews of group companies. These assessments cover data security, privacy policies, procedures and compliance with regulations and best practice standards. Our key digital marketing and research agencies have nominated senior executives to provide leadership on privacy and to work with other agencies in the group.

We communicate regularly with clients on privacy issues to explain our approach and help them to keep abreast of current thinking and best practice. We also collaborate with others in our industry to improve privacy standards and ensure that information is accessible to consumers. We are members of the online Behavioural Advertising Self Regulation Coalition (BASRC) and many of our people are active participants in organizations such as the Interactive Advertising Bureau (IAB), Network Advertising Initiative (NAI) and Association of National Advertisers (ANA). In 2009 we collaborated with the Future Privacy Forum and others to enhance consumer information on privacy.

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