Submission from Television Limited to the Health Select Committee on The Public Health Bill

7 March 2008

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Introduction:

Television New Zealand Ltd is a Crown Owned Company established by the Television New Zealand Act (2003) with a remit that includes both maintaining commercial performance and giving effect to its public broadcasting Charter.

The TVNZ Charter is the declaration of principles underpinning TVNZ, which emphasises TVNZ's public broadcasting responsibilities and is particularly designed to foster a sense of national culture and identity. The Charter assigns to TVNZ a crucial role in developing and celebrating a shared sense of what it means to be a New Zealander.

As the country's nationally-owned public television broadcaster and largest New Zealand-owned media company, TVNZ has been given a mandate to feature New Zealanders and New Zealand events on free-to-air television, supporting locally-made programmes to an extent that is not possible in a purely commercial environment.

Although TVNZ is a Crown Owned Company operating under the Charter, it still screens advertisements. TVNZ needs a significant stream of commercial revenue to help fund increasing local content and to purchase the best programmes from around the world.

TVNZ earns more than 90% of its revenue from its commercial operations. The public funds it receives go directly into programmes and other specific initiatives such as the digital channels and maintaining transmission sites in remote parts of the country.

TVNZ reinvests more than $100 million a year of its commercially earned revenues back into local content (4832.7 hours in FY07). In FY07 18 of the top 20 programmes were on TVNZ channels.

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Executive Summary

1. TVNZ is passionate about the well-being of New Zealanders and, as such, is supportive of the purpose of the Public Health Bill to reduce the incidence of communicable and non-communicable diseases in New Zealand.

2. The problem of obesity in children in New Zealand, as in other similar countries, is complex and multi-factorial and requires a multi-faceted response. It is not appropriate for one industry or sector to bear the brunt of a multi-factorial ongoing social issue.

3. Less than one percent of all airtime on free to air television consists of advertising for inappropriate foods (those classified by the Ministry of Health as occasional or not at all foods appropriate for younger children). And the opportunity for children to be exposed to this advertising is very limited. On a daily basis in the 3:00pm to 8:30pm zone, all children in the 5-14 age group spend an average of 44 minutes viewing free to air television. That, in turn, means all children in the 5-14 age group are potentially exposed to 67 seconds of advertising for inappropriate foods. This equates to a potential exposure level of 2.2 30-second equivalent advertisements out of a total 946 advertisements that screen on free to air television during that zone in a day.

4. TVNZ is committed to the success of the joint industry self regulation framework agreed with Government to provide responsible programming and advertising.

5. TVNZ believes that the Public Health Bill, in its current form, imposes a needless additional layer of costs, controls and regulations that will result in significant harm to the company ($20 million per annum) and the free to air broadcasting industry without any tangible health benefits to the community.

6. TVNZ submits that clauses 81-88 and clauses 374 (r) and (x) of the Public Health Bill are unnecessary and should be deleted.

Background:

TVNZ is a supporter of the partnership approach outlined in the Health Select Committee Report on Obesity and Type 2 Diabetes.

It was in that spirit that TVNZ and the other free to air broadcasters demonstrated a commitment to making significant advancements in advertising, funding and programming to help fight obesity through the May 2007 voluntary agreement between the Government and the New Zealand Television Broadcasters’ Council.

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In that agreement, a five point plan to improve food advertising to children was set out. The five point plan is to:

1. Provide free commercial airtime to the Health Sponsorship Council social marketing campaign aimed at improving children’s healthy nutrition – to the value of $0.5 million per annum for the remaining two years of the programme;

2. Introduce a new 'Getting It Right' guide to children’s television advertising which includes a new Children’s Food (CF) rating. Only food products that receive this rating will be able to advertise in programmes directed at children;

3. Work closely with Sports and Recreation New Zealand (SPARC) in the production of television programming aimed at improving diet and exercise practice of children;

4. Provide training for advertisers and agencies in the new Getting It Right guide which is related to the Ministry of Health’s food classification system and the Codes for Food and Children approved by the Advertising Standards Authority (ASA); and

5. Participate in the Government consultative group on food advertising which will include monitoring of food promotion.

TVNZ supports the Ministry of Health’s introduction of a food classification system for use in schools which will provide guidelines on food and nutrition. The new edition of the ‘Getting It Right for Children’ Code for advertising to children on television introduces a special advertising classification – CF (Children’s Food).

Only food, drink, outlets and confectionary products that receive this rating will be able to be advertised in programmes directed at children aged 5-14. All other advertisements for these products will be rated as General Excluding Children (GXC), which means they cannot be played in the children’s programme zones and all commercials will still have to meet the relevant ASA Code of Advertising Practice.

Advertisements require a CF rating from the television industry’s pre-vetting agency, the Television Commercials Approvals Bureau (TVCAB) to resolve the eligibility of the advertisement for a CF classification, based on the Ministry of Health food classification system along with other information supplied by advertisers and agencies.

TVNZ recognises that ‘moderation’ programming makes a positive contribution to help fight obesity. The free to air broadcasters screened more than 120 hours of ‘moderation’ programming in the 2007 year, almost two thirds of which (79 hours in total) screened in the 3:00pm-8:30pm zone.

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According to AGB Nielsen Media Research moderation programming across free to air channels was seen by 91% of children aged 5-14 during 2007. Moderation programming that appeared in the key 3:00pm-8:30pm zone was seen by 87% of children aged 5-14. Below is a list of programmes which have screened on free to air television during the past year which act in a moderation capacity.

• The Biggest Loser • Turn Back Your Body Clock • Downsize Me • Downsize my Pet • Fighting Fat • Ian Wright’s Unfit Kids • Diet Doctors • X Weighted • Health Hazard • Is It Safe to Eat? • The Truth About Food

Children’s exposure to advertising

It is important to understand that the opportunity for children to be exposed to advertising for inappropriate foods is very limited. Free to air television specifically aimed at pre-school children does not carry any advertising content.

TVNZ submits that less than one percent of all airtime on free to air television consists of advertising for inappropriate foods (those classified by the Ministry of Health as occasional or not at all foods appropriate for younger children).

Using the Ministry of Health’s current definitions for classifying food, “Classifying foods and drinks in early childhood education services”, TVNZ has gathered data that looks at the level of children’s exposure to advertising for those foods and beverages classified as ‘Occasional’ or ‘Not At All’ (O/N foods).

Parameters used here are considered to be robust and are as listed below:

• Children are defined as 5-14 years of age1 • The period of consideration was calendar 2007 year • The time period under consideration is 3:00pm to 8:30pm • Using main free to air channels only (TV ONE, TV2, TV3, C4, Prime)2

1 AGB Nielsen Media Research is responsible for the measurement of television viewing in New Zealand and measures the viewing of people aged 5+. 2 While Sky Network Television Ltd accepts commercial advertising on 20 of its channels, advertising content is only monitored across five channels (Sport 1, Sport 2, Movies 1, Movies Great and Box). The commercial channels Cartoon Network and Nickelodeon, which are aimed specifically at children, are not currently included in the advertising monitoring. Consequently we are unable to include Sky Television in this analysis.

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On average, 20 percent of all airtime during a day on free to air channels is made up of advertising content. This equates to an average of 12 minutes an hour across a 24 hour schedule. In TVNZ’s case, the children’s programming slot (on TV2 this is 3:30pm-5:00pm Monday to Friday) has a 10 minute per hour limit. It is also important to note that on TV2 the 3:00pm-3:30pm period is advertising free, as is all Saturday and Sunday morning children’s programming.

Using the above parameters less than one percent of total airtime on average in a whole day is made up of advertising for O/N products. It is slightly higher in the 3:00pm-8:30pm zone but still only makes up less than two percent of the total airtime during that time zone.

In order to determine the exposure levels of children to these O/N advertisements, it is necessary to consider the quantity of viewing children do of free to air television. Obviously not all children aged 5-14 are viewing 100 percent of the time available in the 3:00pm to 8:30pm zone. Therefore, they could not possibly see all of those O/N advertisements.

On a daily basis in the 3:00pm to 8:30pm zone, all children in the 5-14 age group spend an average of 44 minutes viewing free to air television. That, in turn, means all children in the 5-14 age group are potentially exposed to 67 seconds of advertising for O/N products. This equates to a potential exposure level of 2.2 30- second equivalent advertisements out of a total 946 advertisements that screen on free to air television during that zone in a day. (See Appendix 1 for calculations of potential exposure and Appendix II for classifications of food advertisements.)

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Source: AGB Nielsen Media Research

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Obesity is multi-factorial

TVNZ submits that the research into any co-relation between advertising and obesity in children is far from conclusive and that obesity is a multi-factorial non- communicable disease. As has been widely recognised, factors include the following:

• Genetics and predisposition; • Psychosocial influences; • Behavioural factors and lack of exercise; • Socio-economic status; • Eating habits and family influences; and • Cultural preferences.

TVNZ recognises that incidence and prevalence of obesity and Type 2 Diabetes is an area of importance that requires addressing for the health of the nation. However, it is not appropriate for an industry or a sector to bear the brunt of a multi-factorial ongoing social issue.

The World Health Organisation’s (WHO) Global Strategy on Diet, Physical Activity and Health states:

The rising epidemic reflects the profound changes in society and in behavioural patterns of communities over recent decades. While genes are important in determining a person's susceptibility to weight gain, energy balance is determined by calorie intake and physical activity. Thus societal changes and worldwide nutrition transition are driving the obesity epidemic. Economic growth, modernisation, urbanisation and globalisation of food markets are just some of the forces thought to underlie the epidemic.

As incomes rise and populations become more urban, diets high in complex carbohydrates give way to more varied diets with a higher proportion of fats, saturated fats and sugars. At the same time, large shifts towards less physically demanding work have been observed worldwide. Moves towards less physical activity are also found in the increasing use of automated transport, technology in the home, and more passive leisure pursuits.

TVNZ believes that solutions to the problem of obesity need to be multi-faceted, recognising the true complexity of the issue, must address environmental as well as individual factors, and should be designed to bring about long-term, sustainable change. It is vital to ensure that the public are fully aware of the dangers of obesity and the importance of healthy eating and that they also have the practical skills and information they need to implement these messages in their daily lives.

TVNZ believes the use of advertising to promote balanced diets and healthy lifestyles, investing in public awareness, increased consumer information, and educational programmes for children in particular, to be the preferred approach.

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Self regulation is sufficient

Self regulation has played an important role in providing responsible programming and advertising to all New Zealanders and especially to children. The current framework around advertising is a joint industry commitment to making self regulation work.

Under an inclusive and socially responsible approach, the Advertising Standard Authority works with industry and public representatives to ensure that advertising content which is presented to children is socially responsible and adheres to the Advertising Codes of Practice. They specifically include a Code for Advertising to Children but there are a number of codes which offer additional protection to children. They include the Advertising Code of Ethics, Code for Advertising of Food and Code for People in Advertising.

Proposed amendments to the Public Health Bill:

Subpart 3 – Codes of Practice and Guidelines

This section empowers the Director-General of Health to “issue a code of practice or guidelines to a sector on a particular activity that the sector undertakes if the Director-General has reason to believe that the sector can reduce, or assist in reducing, a risk-factor associated with, or related to, the activity.”

TVNZ submits that clauses 81 to 88 be deleted from the Bill.

TVNZ does not, in principle, support the enactment of Subpart 3 of Part 3 – Codes of Practice and Guidelines – of the Public Health Bill, as this is a significant departure from, and undermines the agreed voluntary industry self- regulation framework.

TVNZ is concerned that under this provision the Director-General of Health is not formally required to substantiate, or provide evidence to substantiate, his or her “reason to believe” that the conditions exist to make it necessary to impose codes of practice or guidelines.

TVNZ supports the use of principles that should to be taken into account by the Director-General when performing functions such as issuing a code of practice or guidelines to a sector on a particular activity that the sector undertakes (as per clause 81).

Principles provide the overarching guide for authorities or a person holding a position of authority to exercise the authority in a balanced manner.

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TVNZ submits that the current principles under clause 80 be amended to require that the direct and indirect impacts on the industry of the imposition of a code of practice or guidelines are fully considered and taken into account, by including the following new paragraph (i):

Clause 80 Principles In performing his or her functions under this Part, the Director-General must take into account the importance of -

(i) any potential negative impact on any sector that would be either significant or disproportionate or both, when issuing a notice, code of practice, or guidelines

The addition of a principle of this nature will ensure that a balanced approach is exercised when the Director-General performs his or her functions under this part of the Act.

TVNZ submits that such a principle is required to be articulated explicitly to ensure that fair and reasonable intervention is maintained.

Part 3 – Clause 374 (r) and (x)

Clause 374 Regulations about public health generally The Governor-General may, by Order in Council, make regulations at any time for all or any of the following:

(r) the prohibition or regulation of the importation manufacture, packing, or sale of any thing likely to introduce or increase a risk to public health:

(x) reducing, or assisting in reducing, risk factors (within the meaning of section 79) associated with, or related to non-communicable diseases:

TVNZ submits that clause 374, paragraphs (r) and (x), be deleted from the Bill.

TVNZ submits that clause 374, at paragraphs (r) and (x), allow the Ministry of Health and the Minister of Health to have excessive powers to unilaterally impose regulation by Order in Council, which can potentially lead to an unreasonable imposition of a regulatory and compliance regime on business and will, in turn, limit or reduce economic transformation across New Zealand.

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TVNZ submits:

• That clause 374 establishes an ambiguity due to the broad and sweeping scope of paragraphs (r) and (x) that places regulations promulgated under these paragraphs, tangible or intangible, inherently open to legal challenge and judicial review; • That regulations promulgated under clause 374 (r) and (x) will impose undue and disproportionate compliance costs on business, which TVNZ estimates to be approximately $20 million in lost advertising revenue per annum3; • That clause 374 (r) and (x) establishes in the hands of the Minister of Health a new and hitherto not contemplated censorship regime, effectively creating a new role for the Minister of Health, acting on advice, as the “Advertising Tsar” in relation to children’s television; • That clause 374 (r) and (x) will require the establishment by the Director- General of Health of a costly formal process for the vetting and approval of television commercials, separate and distinct from the Advertising Standards Authority, to verify compliance with any regulations promulgated; • That clause 374 (r) is inconsistent with the TVNZ Charter because it extends to the Minister of Health the power to ban the importation of programming content that may be deemed to introduce or increase a risk to public health (while an extreme example if passed unchanged the Bill theoretically could mean programmes like “Coronation Street”, which often portrays characters making less than ideal health and lifestyle choices, could be banned); and • That clause 374 (r) holds the potential to create uncertainty and harm to New Zealand businesses and their employees involved in the importation, manufacture, packaging or sale of any thing deemed by the Minister of Health to be a risk to public health.

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3 This is based on an estimate of real revenue impact based on data extracted from Nielsen Media Research Advertising Information Service.

11 APPENDIX I Average Daily Data for 2007 Potential exposure of Occasional or Not at All Food Advertisements by 5-14 year olds Data is in seconds Total airtime available TV One TV2 3 Prime C4 FTA 30 mins = 1,800 1,800 1,800 1,800 1,800 9,000 5.5 hours = 19,800 19,800 19,800 19,800 19,800 99,000

Avg Time Spent Viewing by 5-14 year olds Time spent viewing as a % of total airtime by half hour TVOne TV2 TV3 PRIME C4 FTA TVOne TV2 TV3 PRIME C4 1500-1530 5 25 28 3 3 64 1500-1530 0.3% 1.4% 1.6% 0.2% 0.2% 1530-1600 7 55 45 4 4 115 1530-1600 0.4% 3.1% 2.5% 0.2% 0.2% 1600-1630 9 77 46 3 6 141 1600-1630 0.5% 4.3% 2.6% 0.2% 0.3% 1630-1700 9 66 52 5 9 141 1630-1700 0.5% 3.7% 2.9% 0.3% 0.5% 1700-1730 10 58 99 17 8 192 1700-1730 0.6% 3.2% 5.5% 0.9% 0.4% 1730-1800 20 67 142 10 8 247 1730-1800 1.1% 3.7% 7.9% 0.6% 0.4% 1800-1830 63 98 127 6 8 302 1800-1830 3.5% 5.4% 7.1% 0.3% 0.4% 1830-1900 80 142 105 8 7 342 1830-1900 4.4% 7.9% 5.8% 0.4% 0.4% 1900-1930 61 188 83 6 26 364 1900-1930 3.4% 10.4% 4.6% 0.3% 1.4% 1930-2000 64 166 112 14 18 374 1930-2000 3.6% 9.2% 6.2% 0.8% 1.0% 2000-2030 61 165 107 16 9 358 2000-2030 3.4% 9.2% 5.9% 0.9% 0.5% 2640

Occasional & Not at All Food Ads O/N Food Ads as a % of total airtime TV One TV2 3 Prime TV C4 FTA TVOne TV2 TV3 PRIME C4 1500-1530 14 17 31 7 6 75 1500-1530 0.8% 0.9% 1.7% 0.4% 0.3% 1530-1600 14 47 38 9 5 111 1530-1600 0.8% 2.6% 2.1% 0.5% 0.3% 1600-1630 17 46 37 11 6 118 1600-1630 1.0% 2.6% 2.1% 0.6% 0.4% 1630-1700 8 49 42 9 4 112 1630-1700 0.5% 2.7% 2.3% 0.5% 0.2% 1700-1730 8 64 58 15 2 148 1700-1730 0.4% 3.6% 3.2% 0.8% 0.1% 1730-1800 8 54 53 8 7 129 1730-1800 0.4% 3.0% 2.9% 0.4% 0.4% 1800-1830 12 81 32 13 9 147 1800-1830 0.6% 4.5% 1.8% 0.7% 0.5% 1830-1900 9 83 31 14 12 150 1830-1900 0.5% 4.6% 1.7% 0.8% 0.7% 1900-1930 10 70 45 17 62 204 1900-1930 0.6% 3.9% 2.5% 0.9% 3.4% 1930-2000 11 60 46 16 49 183 1930-2000 0.6% 3.4% 2.6% 0.9% 2.7% 2000-2030 10 71 48 18 35 182 2000-2030 0.6% 3.9% 2.7% 1.0% 1.9% 1560

Potential secs for 5-14 year olds to view O/N ads TV One TV2 3 Prime TV C4 FTA 1500-1530 0.04 0.24 0.48 0.01 0.01 0.8 Potential to view ads is number of seconds of O/N foods ads multiplied by the time spent view 1530-1600 0.05 1.43 0.94 0.02 0.01 2.5 1600-1630 0.09 1.97 0.95 0.02 0.02 3.0 1630-1700 0.04 1.78 1.22 0.02 0.02 3.1 1700-1730 0.04 2.07 3.20 0.14 0.01 5.5 1730-1800 0.08 2.02 4.15 0.04 0.03 6.3 1800-1830 0.41 4.41 2.29 0.04 0.04 7.2 1830-1900 0.41 6.51 1.83 0.06 0.05 8.9 1900-1930 0.34 7.33 2.09 0.06 0.90 10.7 1930-2000 0.40 5.58 2.89 0.13 0.49 9.5 2000-2030 0.35 6.47 2.88 0.16 0.18 10.0 67

No. of 30-second ads 67 seconds would equate to 2.2

12 APPENDIX II

2007 Food & Beverages excluding Alcohol & Petfood N = Not at all O = Occasional E = Everyday S = Sometimes

Product Advertiser Classification Bell's Fruit & Veges Aparima Holdings E Blueberries New Zealand Blueberries New Zealand E Eating Well Promotion BrandWorld Ltd E Bush Road Vegetables & Salads Bush Road Ltd E Campbells Real Stock Campbell's Foods NZ Ltd E Pump Water Coca-Cola Amatil NZ E Daawat Basamati Rice D N Govan Ltd E Dole Superfoods Dole Asia E Dole Tropical Gold Pineapple Dole Asia E Easi-Yo Yoghurt Easiyo Products Ltd E Eggs Incorporated Eggs Incorporated E Anchor Mega Milk Fonterra Brands E Anchor Milk Fonterra Brands E Anchor Xtra Milk Fonterra Brands E Anlene Milk & Yoghurt Fonterra Brands E Fresh n Fruity Lite Yoghurt Fonterra Brands E Fresh n Fruity Splatz Fonterra Brands E Mainland Special Reserve Range Fonterra Brands E Fresh In The Kitchen Fresh Communications E NZ Natural Min.Water Prog.Prom Frucor Beverages E NZ Natural Mineral Water Frucor Beverages E Quality Bakers Molenberg Goodman Fielder NZ Ltd E Vogel's Bread Goodman Fielder NZ Ltd E Harraways Rolled Oats Harraway & Sons Ltd E Heinz Nurture Gold Toddler Heinz Wattie's NZ Limited E Tegel Chicken Heinz Wattie's NZ Limited E Watties Food in a Minute Heinz Wattie's NZ Limited E Watties Steam Fresh Meals Heinz Wattie's NZ Limited E Watties Steam Fresh Veges Heinz Wattie's NZ Limited E Ingham Chicken Breast Tenders Ingham Enterprises E Ingham Chicken Products Ingham Enterprises E Ingham Lite Chicken Breast Ingham Enterprises E Yoplait Elivae International Fine Foods E Jina's World of Fresh Produce Jinas World Of Fruit E Kelloggs All-Bran Kellogg (Aust) Pty Ltd E Kelloggs Just Right Kellogg (Aust) Pty Ltd E Kelloggs Just Right Tropical Kellogg (Aust) Pty Ltd E Northwest Cherries Kerrigan & Co E Dolmio Chunky MasterFoods ANZ E Dolmio Stir-In Sauces MasterFoods ANZ E McCain Healthy Choice Dinners McCain Foods (Aust) Pty Ltd E McCain Healthy Choice Twin Pk McCain Foods (Aust) Pty Ltd E Mccain Steamtime McCain Foods (Aust) Pty Ltd E Meat Cuisine Online Butcher Meat Cuisine E Uncle Tobys Oat Products Nestle NZ Ltd E Nutricia Karicare Toddler Gold Nutricia Ltd E NZ Beef and Lamb Promotion NZ Beef & Lamb Marketing Burea E New Zealand Food Safety Auth NZ Food Safety Authority E Regal Marlborough Salmon NZ King Salmon Company Ltd E

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NZ Pork Industry Board NZ Pork Industry Board E 5+ A Day Prog Promo NZ Vege & Potato Growers E Alfa One Rice Bran Oil Old Fashioned Foods Ltd E King Soup Mix Old Fashioned Foods Ltd E Old Fashioned Foods Old Fashioned Foods Ltd E Only Organic Baby Food Only Organic Baby Food E Dole Pineapple Pave Consumer Brands Co Ltd E Raeward Fresh Raeward Fresh Fruit & Veg E Fish Market Sanford Limited E Sanitarium Light & Tasty Sanitarium Health Food Co E Sanitarium Single Serv Sanitarium Health Food Co E Sanitarium Nutrition Educ.Serv Sanitarium Health Food Co E Sanitarium So Good Sanitarium Health Food Co E Sanitarium So Good Active Sanitarium Health Food Co E Sanitarium Weet-Bix Sanitarium Health Food Co E Sanitarium Weetbix Tryathlon Sanitarium Health Food Co E Sanitarium Whole Grain Story Sanitarium Health Food Co E The Aussie Butcher The Aussie Butcher E Bonita Bananas Prog Promo Turners & Growers Ltd E Bertolli Pasta Sauces Australasia E Flora Pro-Activ Unilever Australasia E Waiwera Infinity Water Waiwera Infinity Water E Yakult Yoghurt Yakult Australia Pty Ltd E Ploughmans Bread Allied Foods Co Ltd E/S Tip Top Bread Allied Foods Co Ltd E/S Tip Top Bread Prog Promo Allied Foods Co Ltd E/S Bega So-Light Cheese Bega Co-op Society E/S Discover Great Food Ideas BrandWorld Ltd E/S Campbells Chunky Soups Campbell's Foods NZ Ltd E/S Campbells Sensations Soups Campbell's Foods NZ Ltd E/S Easi-Yo range Easiyo Products Ltd E/S Export Meat Warehouse Export Meat Warehouse E/S Anchor Calci-Yum Squeezables Fonterra Brands E/S Mainland Cheese Fonterra Brands E/S Mainland Munchables Fonterra Brands E/S Mainland Stirling Colby Cheese Fonterra Brands E/S Mainland Vintage Cheddar Fonterra Brands E/S Meadow Fresh Brand Goodman Fielder NZ Ltd E/S Watties Big and Hearty Soup Heinz Wattie's NZ Limited E/S Ingham Everyday Roast Chicken Ingham Enterprises E/S Vegemite Kraft Foods NZ Ltd E/S The Mad Butcher Mad Butcher Ltd E/S Dolmio Sauces MasterFoods ANZ E/S McCain Mini Roasts McCain Foods (Aust) Pty Ltd E/S Nestle Carnation Light&Creamy Nestle NZ Ltd E/S Subway International E/S Wholegrain Pas/Sau Unilever Australasia E/S Bundaberg Apple Ale Bundaberg Brewed Drinks N Bundaberg Ginger Beer Bundaberg Brewed Drinks N Bundaberg Lemon Ale Bundaberg Brewed Drinks N Bundaberg Lemon Lime & Bitters Bundaberg Brewed Drinks N Bundaberg Peachee Bundaberg Brewed Drinks N Charlie's Natural Fruit Soda Charlie's Trading Co. N Ch'i Mineral Water Ch'I International N Lemon & Paeroa Coca-Cola Amatil NZ N Coca-Cola Coca-Cola Oceania N Coca-Cola Prog.Promos Coca-Cola Oceania N

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Coca-Cola Zero Coca-Cola Oceania N Coca-Cola Zero Prog Promo Coca-Cola Oceania N Diet Coke Coca-Cola Oceania N Lift Plus Coca-Cola Oceania N Lift Plus Prog Promo Coca-Cola Oceania N Powerade Isotonic Coca-Cola Oceania N Sprite Lemonade Coca-Cola Oceania N TAB Energy Drink Coca-Cola Oceania N Buderim Ginger Confectionery House N Frucor Frank Frucor Beverages N Frucor Mizone Active Frucor Beverages N Frucor Mizone Rapid Frucor Beverages N Frucor V Frucor Beverages N Frucor V Prog Promo Frucor Beverages N Just Juice Bubbles Frucor Beverages N Just Juice Fruit Juice Frucor Beverages N Splenda Sweetener Johnson & Johnson NZ Ltd N Shot & Go National Beverages N Mountain Dew Pepsi-Cola Bottlers NZ Ltd N Mountain Dew Competition Pepsi-Cola Bottlers NZ Ltd N Pepsi Max Pepsi-Cola Bottlers NZ Ltd N Pepsi Max Prog Promo Pepsi-Cola Bottlers NZ Ltd N Phoenix Organic Drink Phoenix Organic Ltd N Red Bull Red Bull NZ Ltd N Red Bull Prog.Promo Red Bull NZ Ltd N Soda Stream Soft Drink Soda Stream NZ N Jarrah Coffee & Chocolate Rnge AB Foods (Novartis Nutrition) O Vertigo Acorn Group Ltd O Arnotts Crazy Faces Arnotts Biscuits NZ Ltd O Arnotts Farmbake Cookies Arnotts Biscuits NZ Ltd O Arnotts Jatz Original Arnotts Biscuits NZ Ltd O Arnotts Shapes Arnotts Biscuits NZ Ltd O Arnotts Shapes Crispy Puff Arnotts Biscuits NZ Ltd O Arnotts Tim Tam Love Potions Arnotts Biscuits NZ Ltd O Arnotts Tim Tam Prog.Promo Arnotts Biscuits NZ Ltd O Arnotts Tim Tams Arnotts Biscuits NZ Ltd O Ovaltine Max Milk Associated British Foods O Bluebird Delisio Bluebird Foods Ltd O Bluebird Grain Waves Bluebird Foods Ltd O Bluebird Health Plus Crisp Bluebird Foods Ltd O Bluebird HealthPlus Prog Promo Bluebird Foods Ltd O Bluebird Le Snak Bluebird Foods Ltd O Bluebird Potato Chips Bluebird Foods Ltd O Bluebird Snacks(All) Bluebird Foods Ltd O Chupa Chups Brandlines Ltd O Chupa Chups Cremosa Brandlines Ltd O Chupa Chups Melody Pops Brandlines Ltd O Lindt Chocolate Bunny Brandlines Ltd O Lindt Chocolates Brandlines Ltd O Mentos Brandlines Ltd O Mentos Blast Brandlines Ltd O Mentos Ice Chewing Gum Brandlines Ltd O Smint Brandlines Ltd O Werther's Original Brandlines Ltd O Zombie Chews Brandlines Ltd O What's New Promotions BrandWorld Ltd O Burger Fuel Burger Fuel Ltd O

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Burger Fuel Share Offer Burger Fuel Ltd O Cadbury Bars Promotion Cadbury Confectionery Ltd O Cadbury Brunch Bar Cadbury Confectionery Ltd O Cadbury Caramello Cadbury Confectionery Ltd O Cadbury Continental Chocolates Cadbury Confectionery Ltd O Cadbury Creme Eggs Cadbury Confectionery Ltd O Cadbury Crunchie Bar Cadbury Confectionery Ltd O Cadbury Dairy Milk Chocolate Cadbury Confectionery Ltd O Cadbury Dairy Milk Desserts Cadbury Confectionery Ltd O Cadbury Dairy Milk Duo Cadbury Confectionery Ltd O Cadbury Dairy Milk Prog.Prom Cadbury Confectionery Ltd O Cadbury Eden Chocolate Cadbury Confectionery Ltd O Cadbury Favourites Cadbury Confectionery Ltd O Cadbury Favourites Prog.Promo Cadbury Confectionery Ltd O Cadbury Flake Cadbury Confectionery Ltd O Cadbury Magical Elves Cadbury Confectionery Ltd O Cadbury Moro Gold Cadbury Confectionery Ltd O Cadbury Old Gold Choc Prog Pro Cadbury Confectionery Ltd O Cadbury Old Gold Chocolate Cadbury Confectionery Ltd O Cadbury Picnic Cadbury Confectionery Ltd O Cadbury Pinky Prog Promo Cadbury Confectionery Ltd O Cadbury Roses Chocolates Cadbury Confectionery Ltd O Natural Confectionery Co. Cadbury Confectionery Ltd O Pascall Fruit Bursts Cadbury Confectionery Ltd O Pascall Marshmallows Cadbury Confectionery Ltd O Pascall Pineapple Lumps Cadbury Confectionery Ltd O Candyland Candyland Coporation O Domino's Pizza Domino's Pizza O Domino's Pizza Prog Promo Domino's Pizza O NZ Natural Ice Cream Emerald Foods Ltd O Ferrero Nutella Ferrero Australia O Ferrero Rocher Chocolates Ferrero Australia O Ferrero Tic Tac Ferrero Australia O Kinder Bueno Ferrero Australia O Kinder Surprise Ferrero Australia O Hell Pizza Flame Ltd O Tip Top Brand Fonterra-Tip Top O Tip Top Ice Cream Fonterra-Tip Top O Tip Top Memphis Melt Down Fonterra-Tip Top O Tip Top Fonterra-Tip Top O Tip Top Popsicle Creamy Fonterra-Tip Top O Tip Top Trumpet Fonterra-Tip Top O Eta UpperCut Chips Griffins Foods Ltd O ETA Uppercut Corn Crisps Griffins Foods Ltd O Au'some Sour Flic'n'lic Innovex Group O Whittaker's Caramel Chocolate J H Whittaker & Sons Ltd O Whittaker's Chocolate J H Whittaker & Sons Ltd O Whittaker's Dark Chocolate J H Whittaker & Sons Ltd O Kelloggs Coco Pops Kellogg (Aust) Pty Ltd O Kelloggs Crunchy Nut Nutty Bar Kellogg (Aust) Pty Ltd O Kelloggs LCMs Shakes Bars Kellogg (Aust) Pty Ltd O Kraft Cheesy Pops Kraft Foods NZ Ltd O Kraft Easy Mac Kraft Foods NZ Ltd O Kraft Oreo Wafer Sticks Kraft Foods NZ Ltd O Philadelphia Caramelised Onion Kraft Foods NZ Ltd O Philadelphia Light Spreadable Kraft Foods NZ Ltd O Philadelphia Mango Chilli Phil Kraft Foods NZ Ltd O

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Philadelphia T.Chutney Philli Kraft Foods NZ Ltd O M & M's Competition MasterFoods ANZ O M & M's Milk Chocolates MasterFoods ANZ O Maltesers MasterFoods ANZ O Masterfoods Bars Promotion MasterFoods ANZ O Pods MasterFoods ANZ O Snickers Bar MasterFoods ANZ O Snickers Maximus Bar MasterFoods ANZ O Twix Bar Prog Promotion MasterFoods ANZ O Masterpet Jer High Jerky Masterpet Corp Ltd O McCain Beer Batter Steakfries McCain Foods (Aust) Pty Ltd O Mcdonald's Happy Meals Prog Pr McDonald's System Of NZ Ltd O McDonalds Prog.Promos McDonald's System Of NZ Ltd O McDonalds McDonald's System Of NZ Ltd O Allen's Confectionery (All) Nestle NZ Ltd O Allen's Naturals Nestle NZ Ltd O Flemings Chewy Nestle NZ Ltd O Nescafe Noir Nestle NZ Ltd O Nestle Aero Nestle NZ Ltd O Nestle Cheerios Nestle NZ Ltd O Nestle Chocolate Bar Range Nestle NZ Ltd O Nestle Chocolate Competition Nestle NZ Ltd O Nestle Coconut Milk Nestle NZ Ltd O Nestle Heaven Nestle NZ Ltd O Nestle Heaven Prog.Promo. Nestle NZ Ltd O Nestle Red.Cream & Maggi Soup Nestle NZ Ltd O Nice & Natural Fruit Strings Nice & Natural Ltd O Aunt Betty's Range Old Fashioned Foods Ltd O Aunt Betty's Sensational Puddi Old Fashioned Foods Ltd O Aunt Betty's Yorkshire Pudding Old Fashioned Foods Ltd O Hansells Jungle Juice Old Fashioned Foods Ltd O Pizza Hut Pizza Restaurants (NZ) Ltd O KFC Brands NZ Ltd O KFC Meals(H) Restaurant Brands NZ Ltd O KFC Snacks(L) Restaurant Brands NZ Ltd O Pizza Hut Prog Promo Restaurant Brands NZ Ltd O Sanitarium Gizmos & Gadgets Sanitarium Health Food Co O www.freshcakes.co.nz Shebran Ltd O Birds Eye Golden Crunch Fries Simplot NZ Ltd O Double D Snow's Confectionery O Frooze Pop Stuart Alexander & Co NZ Ltd O Fruit Blasts Stuart Alexander & Co NZ Ltd O WOM Thumb Dippers Stuart Alexander & Co NZ Ltd O Restaurants Tasman Pacific Foods O Dairy Whip Prog Promo Tatua Co-Op Dairy Co Ltd O Tatua Dairy Whip Tatua Co-Op Dairy Co Ltd O The Cheesecake Shop The Cheesecake Shop O Continental Cup-A-Soup Unilever Australasia O Continental Cup-A-Soup Asian Unilever Australasia O Cornetto Unilever Australasia O Streets Unilever Australasia O Streets Unilever Australasia O Streets Paddle Pop ProgPromo Unilever Australasia O Carbury Moro,Garnier,VodafoneP Vodafone New Zealand O Wendy's Prog.Promo Wendco NZ Ltd O Wendys Restaurants Wendco NZ Ltd O Wendys Supa Sundaes Wendy's Supa Sundaes O

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Guylian Chocolates Wilson Consumer Products O Guylian Seashell Chocolates Wilson Consumer Products O Wrigley's Eclipse Chewing Gum Wrigley Co NZ Ltd O Wrigley's Extra 14 Piece Pack Wrigley Co NZ Ltd O Wrigley's Extra Chewing Gum Wrigley Co NZ Ltd O Wrigley's Extra White Wrigley Co NZ Ltd O Wrigley's Solano Wrigley Co NZ Ltd O Sunsweet Ones Americana Ltd S Sunsweet Pitted Prunes Americana Ltd S Arnotts Vita-Weat Crackers Arnotts Biscuits NZ Ltd S Bell Pure Ceylon Tea Bell Tea Co Ltd S Bell Tea & Teabags Bell Tea Co Ltd S Bell Tea Programme Promotion Bell Tea Co Ltd S Twinings Earl Grey Tea Bell Tea Co Ltd S Twinings English Breakfast Tea Bell Tea Co Ltd S Wild Bean Cafe BP NZ Ltd S Asian Home Gourmet Brandlines Ltd S Sakata Rice Crackers Brandlines Ltd S Breakers Cafe and Bar Breakers Bar & Cafe S Brumby's Hot Bread Shops Brumby's Hot Bread Shops S Greggs Cafe Gold Cerebos Gregg's Ltd S Greggs Cafe Gold Classic Cerebos Gregg's Ltd S Greggs Coffee Range Cerebos Gregg's Ltd S Greggs Rich Roast Cerebos Gregg's Ltd S Robert Harris Freeze Dried Cof Cerebos Gregg's Ltd S Robert Harris Sponsorship Cerebos Gregg's Ltd S Chai Tea Range Chai Tea S Cobb & Co Restaurants Cobb & Co S Cranberry Promotion Cranberry Promotion S Denny's Family Restaurant Denny's Family Restaurant S Dilmah Green Teas Dilmah NZ Ltd S Dilmah Tea Dilmah NZ Ltd S Primo Drink Fonterra Brands S Primo Prog Promo Fonterra Brands S Tip Top Fru Ju Fonterra-Tip Top S 4 Square Foodstuffs NZ Ltd S New World Prog.Promo Foodstuffs NZ Ltd S New World Sponsorship Foodstuffs NZ Ltd S New World Supermarkets Foodstuffs NZ Ltd S Pak N Save Foodstuffs NZ Ltd S Pam's Brand Foodstuffs Own Brands S Pam's Products Foodstuffs Own Brands S Pam's Prog Promo Foodstuffs Own Brands S Fresh Edge Fruitees Fresh Edge Ltd S Frozen Direct Frozen Direct S Fresh-Up Fruit Juices Frucor Beverages S Fresh-Up Sponsorship Frucor Beverages S Just Juice Plus Frucor Beverages S Just Juice Splash Frucor Beverages S Just Juice Splash Prog.Promo. Frucor Beverages S McCoy Fruit Smoothie Frucor Beverages S Old El Paso HardnSoft Taco Kit General Mills S Old El Paso Soft Taco Crispy C General Mills S Old El Paso Stand'n Stuff General Mills S Patak's Original Simmer Sauces General Mills S Happy Days Restaurant Happy Days Ltd S Havana Coffee Works Havana Coffee Works S

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Tegel Takeouts Range Heinz Wattie's NZ Limited S Watties Big Eats Heinz Wattie's NZ Limited S Wattie's Brand Heinz Wattie's NZ Limited S Watties Foil Sealed Meals Heinz Wattie's NZ Limited S Hellers Smallgoods Heller Tasty Ltd S Purplo's Honey Coctail Sausage Heller Tasty Ltd S Ingham Chicken Cordon Bleu Ingham Enterprises S Ingham Chicken Nuggets Ingham Enterprises S Ocean Spray Cranberry Products James Crisp Ltd S Ocean Spray Products James Crisp Ltd S Kaweka Long-Life Meals Kaweka Food Company S Kelloggs Coco Pops Coco Rocks Kellogg (Aust) Pty Ltd S Kelloggs Crunchy Nut Clusters Kellogg (Aust) Pty Ltd S Kelloggs Crunchy Nut Cornflake Kellogg (Aust) Pty Ltd S Kelloggs LCM Bars Kellogg (Aust) Pty Ltd S Kelloggs Nutri-Grain Kellogg (Aust) Pty Ltd S Kelloggs Spec.K Bars ProgPromo Kellogg (Aust) Pty Ltd S Kelloggs Special K Kellogg (Aust) Pty Ltd S Kelloggs Special K Prog Prom Kellogg (Aust) Pty Ltd S Kelloggs Sultana Bran Kellogg (Aust) Pty Ltd S Kelloggs Sultana Bran Crunch Kellogg (Aust) Pty Ltd S Kelloggs Sustain Kellogg (Aust) Pty Ltd S Little India Bistro & Tandoor Little India Restaurants S Lone Star Cafe Lone Star Cafe S Hogs Breath Cafe Mana Taverns S Dolmio Pasta Bake MasterFoods ANZ S Uncle Ben's Express Fried Rice MasterFoods ANZ S Mccain Pizza Subs McCain Foods (Aust) Pty Ltd S McCain Super Crunchy Fries McCain Foods (Aust) Pty Ltd S McDonalds Recruitment Mcdonalds Recruitment S McDonalds Junior Soccer Legend McDonald's System Of NZ Ltd S McDonalds McCafe McDonald's System Of NZ Ltd S McDonalds Sponsorship McDonald's System Of NZ Ltd S Mcdonalds,V,Rip Prog Promo Mcdonalds V & RIP S Mokena Restaurant Mokena Restaurant S Fleming's Nuts & More Nestle NZ Ltd S Maggi Cook In The Pot Nestle NZ Ltd S Maggi Programme Promotions Nestle NZ Ltd S Maggi Soup Sticks Nestle NZ Ltd S Maggi Tasty Cheese Sauce Nestle NZ Ltd S Maggi World Flavours Nestle NZ Ltd S Nescafe Classic Prog Promo Nestle NZ Ltd S Nestle Milo Nestle NZ Ltd S Nestle Milo Energy Cereal Nestle NZ Ltd S Nestle Nesquik Cereal Nestle NZ Ltd S Nestle Nesquik Cereal Prog Pro Nestle NZ Ltd S Nestle Nesquik Prog Promo Nestle NZ Ltd S Zinc Cafe Platters Inc S Countdown Supermarkets Progressive Enterprises Ltd S Foodtown Progressive Enterprises Ltd S Foodtown & Woolworths Progressive Enterprises Ltd S Foodtown & Woolworths Online Progressive Enterprises Ltd S Foodtown Woolworths& Countdown Progressive Enterprises Ltd S Fresh Choice Supermarket Progressive Enterprises Ltd S Woolworths & Countdown Progressive Enterprises Ltd S Woolworths Supermarket Progressive Enterprises Ltd S Alison's Pantry Prolife Foods Ltd S

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Red Seal Herbal Tea Red Seal Natural Health Ltd S Sakata Minis Snack Packs Sakata Australia S Honey Puffs Mad Movie Challeng Sanitarium Health Food Co S Sanitarium Ricies Sanitarium Health Food Co S Sanitarium Skippy Corn Flakes Sanitarium Health Food Co S Sanitarium Up & Go Sanitarium Health Food Co S Sanitarium Up & Go Energize Sanitarium Health Food Co S Sanitarium Up&GoEnergizeProgPr Sanitarium Health Food Co S Moccona Coffee Sara Lee Household & Bodycare S Sealord Products Sealord Products Ltd S Birds Eye Oven Bake Fish Prods Simplot NZ Ltd S Tasti Nut Bar Tasti Products Ltd S The Londoner The Londoner S Continental Recipe Bases Unilever Australasia S Weis Icecream Weis S

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