John Ayling & Associates Brand Safety Policy

Introduction

The modern digital marketplace offers amazing opportunities for advertisers; yet the speed of evolution within the sector has resulted in an ongoing challenge to meet the ever emerging risks posed to advertisers and agencies alike. Whilst it is impossible to guarantee absolute protection within the digital ecosystem, John Ayling and Associates (JAA) are fully committed to the continual development of our approach and tools to ensure that all reasonable endeavours are employed to provide our clients with a safe and transparent environment in which to run their digital advertising.
Our Brand Safety policy will therefore evolve over time to remain effective.
This document details the measures employed by JAA to take all reasonable endeavours to minimise the risk of clients advertisements being placed next to content that is not deemed “brand safe” and protect wherever possible against fraudulent behaviours across digital display, video and mobile media channels.
__________________________

For clarity we will use the following definitions:

Brand Safety: We define brand safe environments, as those avoiding two types of content:
1. Illicit and unlawful content
a. Content that contravenes UK law: Sexual assault, child abuse, graphic violence/death, promotion of drugs or other illegal acts including computer based crime (Phishing, Malware infection, viruses etc.) and intellectual property infringement
b. Content that is accepted to be inappropriate for any client’s brand to appear in proximity to: nudity, pornography, explicit sexual conduct, racist content, suffering, neglect or violence, political or religious extremism, hate speech

2. Content inappropriate to a specific brand. For example, environments suitable to a charity brand will be different to those of a gambling brand.

Click Fraud: The generation of invalid clicks from a user, program or automated system (e.g. bot or spider) that accesses an URL for the purpose of falsifying and/or manipulating click measurement.
Bot: Automated software that operates without human intervention
Blacklist: A schedule of inappropriate domains which are permanently excluded
Whitelist: A schedule of appropriate domains
Insertion Order: Contract on standard terms provided by the media vendor traditionally used when buying media, and which is signed and exchanged by email
Agency SLA (Service Level Agreement): An agreement between Agency and Vendor or service provider which defines the parameters and responsibilities expected from vendor/service provider in executing a media campaign

Content Verification (CV) Technology: Any system used to identify inappropriate content on a web page, before or after an ad appears or which detects invalid traffic (IVT) or Non-Human Traffic (NHT). CV Technology allows the blocking of ads from serving, and therefore appearing, pre or post bid, where content is deemed inappropriate; and/or allows the serving of ads on domains that are deemed appropriate.
______________________________

JAA buying teams will manage each client’s specific digital requirements utilising the following measures as a matter of course to ensure ad misplacement is minimised:

1. Deployment of an independently verified CV partner (Brand Safety & Anti-Fraud)
2. Industry accreditation – working with industry bodies to maintain best practice methodology e.g. JICWEBS DTSG
3. Excluded inventory sources (e.g. Agency Blacklist)
4. Contractual protection: agreement with the JAA SLA trading terms
5. Domain transparency

Content Verification Partner – Double Verify (DV)
JAA use DoubleVerify’s tagging across display & social campaigns; as industry leaders in brand safety, viewability and anti-fraud tracking & prevention they are independently audited and are a certified CV supplier to JICWEBS standards.
Their technologies, in addition to human auditing as detailed below, minimise the risk of clients advertising appearing alongside content in real time and which does not comply with the highest Brand Safety standards.
Brand Safety

• Client specific Brand Safety Profiles: Working with each client, JAA buying teams will create a tailored brand safety profile, utilising 75 different content classifications to clearly define what is and is not appropriate content. Through DV technology this is applied at a site and web-page level.

• In addition we deploy, where appropriate, negative keyword lists to ensure further protection against inappropriate content and/or respond to inappropriate topical content

• A client’s Brand Safety Profile can be employed in two ways:
o Brand safety monitoring: Allows the measurement of impressions served in violation of blacklists and/or the brand safety profile, on sites deemed to have high severity content

o Brand safety blocking: Blocks the ad serving of creative on sites which do not meet the pre-agreed brand safe environment profile

When blocking tags are in place, the Brand Safety incident rate is <0.5% [SOURCE: DoubleVerify March 2017] Fraud Prevention & Viewability • Independently certified fraud prevention technology is employed across all display campaigns where available, and as detailed in our Terms of Business and Agency SLA. Ensuring wherever possible: o Fraud and SIVT (Sophisticated Invalid Traffic) detection / NHT (Non-Human Traffic) identification o Geo Compliance o Blacklist implementation o Viewability metrics across all platforms, devices and formats (where available) in accordance with IAB Viewability Guidelines and/or custom viewability metrics We recommend all campaigns as a matter of course, wherever technology permits, only utilise media vendors which are able to carry, and implement, DV blocking tags. Where it is not possible to carry DV tagging in full, or in part, client teams will be notified in writing prior to campaign approval. DV technology can be deployed in part or in full, across a broad range of trading models that JAA employ including direct programmatic buys, networks, private market places, or any direct buys with publishers or third party managed services. We will support the implementation of alternative verification technology if requested by the client and which is available in the UK. Industry Accreditation & Operational Procedures JAA is committed to following the Digital Trading Standard’s (DTSG) Good Practice Principles as laid out by the UK Joint Industry Committee for Web Standards (JICWEBS). JAA also requires that publishers equally comply with the latest version of the DTSG Good Practise Principles. As of August 2018 JAA are a JICWEBS signatory. JAA also works with the City of London Police, to blacklist sites (as detailed below) which are listed on The Police Intellectual Property Crime Unit’s (PIPCU) Infringement Website List (IWL). Additional Procedures employed: Trading – Multiple Trading Models Dependent on client requirements we will utilise multiple buying models; JAA do not operate agency deals which restricts client access to one particular trading model or a particular set of media vendors. This ensures activity is tailored directly to client needs, more readily respond to non-compliant publishers/vendors and ultimately better mitigate against misplaced ads – e.g. where possible buying media directly from trusted publishers. Excluded Inventory We operate a manually curated Agency Blacklist which is employed on all client activity. This is in addition to bespoke, client specific Blacklists where relevant to the buying model. The Agency Blacklist is a list of domains that are deemed inappropriate for all our clients either as a result of illicit or illegal content or fraudulent behaviours as stated above. The JAA Agency Blacklist is continually updated on a regular basis and is available on request. Agency Blacklist is located here. In addition to domain blacklists each client, where appropriate to trading model and platform selection, will operate with a manually curated negative keyword lists to further ensure the incident of misplaced adverts is minimised. Where appropriate, and agreed with the client, whitelists will be applied on digital media bought programmatically; including direct programmatic buys, networks, private market places, or any direct buys with publishers or third party managed services. Takedown Policy If for any reason a client finds their advertisement in locations deemed inappropriate and which are outside of the existing blacklist or Brand Safety Profile, JAA operate a takedown policy to ensure these URLS are removed from the campaign within a 1hr target window (during working hours – 9am – 5.30pm) or by 10am the following working day. Our domain takedown policy operates in two ways: 1. Agency Blacklist: We will immediately upon notification update the appropriate client Blacklist. Once an infringing domain is added it is activated instantaneously. This ensures that all steps are taken to prevent any further infringements. 2. Vendor Notification: We will always notify the inventory supplier(s) immediately upon notification of an infringement, requesting that inappropriate domains are immediately added to publisher blacklists. Contractual protection To minimise the risk of advertisements being placed in contextual environments that don’t align with brand values, JAA specifies that vendors, publishers and their associated partners adhere to the JAA SLA. The Agency SLA ensures that all suppliers are aligned with the definitions, responsibilities and expectations as detailed in the JAA Brand Safety Policy; included within the SLA, but not limited to: • Definition of inappropriate, illicit and unlawful content • An expectation of Brand Safety ‘by design’ • Adherence to DTSG standards • Facilitation for the implementation of CV tagging • Takedown policy requirements Domain transparency We operate with 100% transparency on URL’s/Domains/Subdomains post-delivery. End. Updated: 25th September 2018