Brighton & Hove City Council

Advertising and Sponsorship Policy

1.    Objectives

Opportunities to advertise and/or partner with the Council as a sponsor are available to businesses and organisations to promote their brand, products and services. Brighton & Hove City Council aims to develop advertising and sponsorship opportunities on its assets for the purpose of generating income for the Council and directly enable a better Brighton and Hove for all. Opportunities should support, and not undermine, the Council’s priorities to create a city to be proud of, a fair and inclusive city, a healthy city that helps people to thrive, and a responsive and learning council with well-run services.

 

2.    Purpose of the policy

This policy sets out the terms under which Brighton & Hove City Council (“the Council”) may seek, accept, refuse, or withdraw advertising, sponsorship and brand activations.

The policy provides a clear, transparent framework to ensure that all advertising, sponsorship and brand activation arrangements:

·         Enable positive partnerships with responsible organisations that align and support the priorities of the Council and the commitment to ensure a better Brighton and Hove for all. This includes specifically promoting the city as vibrant, welcoming place to live, work and visit.

·         Generate sustainable revenue for reinvestment in council services.

·         Provide exceptional value for money, while giving due weight to environmental, social, and equality considerations.

·         Safeguard public health, the environment and the look and feel of the city.

·         Comply with relevant legislation and industry codes.

·         Uphold the Council’s reputation, values, and are developed in line with, and to support, the Council’s brand and marketing guidelines.

 

3.    Definitions

Advertising
Paid placement of content on council‑controlled assets (including but not limited to websites, social media, publications, buildings, vehicles, highways, seafront, hoardings and digital screens) by external organisations, whereby they gain publicity in the form of advertisement.

Sponsorship
A commercial or non‑commercial arrangement where an organisation or individual provides funding, resources, or benefits in kind in exchange for recognition or association with council assets, services, projects, programmes, or events, whereby they gain publicity or other benefits.

Brand Activation

A marketing activity or experience on a council-controlled asset that brings a brand to life by engaging people directly, creating memorable interactions that build awareness, loyalty and participation.

4.    Scope and application

This policy applies to:

·         All council‑owned and council‑managed advertising assets.

·         All sponsorship arrangements relating to council services, assets, and activities.

·         Commercial advertising and media partnerships across print, digital content, digital platforms, social media, audio, video, image and experiential assets.

·         Community, cultural, and partnership‑based sponsorships.

Exclusions:

·         Property fully leased to third parties (unless otherwise agreed on a case by case basis).

·         Advertising governed by separate, existing concession contracts (e.g. bus shelter advertising), until such contracts are renewed or varied.

5.    Guiding principles

The Council is actively pursuing advertising, sponsorship and brand activation opportunities that will support the delivery of Council Plan outcomes including:

·         Enhancing the city’s public realm, reputation, cultural life, visitor offer or local pride,

·         Promoting fairness, inclusion, accessibility and community benefit,

·         Protecting and improving public health, wellbeing and safety,

·         Supporting financial sustainability, good governance, service improvement.

The Council will use due diligence and proportionate controls to balance income generation with public health, equality, and reputational considerations.

 

All advertising, sponsorship and brand activation must:

·         Be legal, decent, honest, and truthful,

·         Be socially responsible,

·         Avoid harm to public health, safety, or wellbeing,

·         Protect children and vulnerable groups by preventing exposure to harmful, exploitative, inappropriate or misleading products, services or messages,

·         Be designed to have minimal climate impact and developed in line with the Council’s commitment to environmental sustainability and net zero ambitions,

·         Uphold equality, diversity, and inclusion and not discriminate on the grounds of age, race, colour, national origin, religion or belief, sexual orientation, gender or disability,

·         Avoid conflicts of interest or perceptions of undue influence by the Council,

·         Comply with the guidelines laid out by the Advertising Standards Agency (ASA)

·         Uphold the rules laid out in the UK Code of Non-broadcast Advertising, Sales, Promotion and Direct Marketing (CAP Code),

·         Take account of the Code of Practice on Local Authority Publicity.

 

The Council reserves the right to refuse, approve subject to conditions, suspend, or withdraw any advertising or sponsorship arrangement that does not comply with this policy.

 

5. Assessment framework

In making its decisions, the Council will apply a proportionate approach, taking into account the:

·         anticipated benefits of the opportunity,

·         nature, severity and likelihood of any actual or potential risks,

·         adequacy and effectiveness of any proposed mitigation measures,

·         environmental and sustainability impacts of the activity, which may include:

Ø  greenhouse gas emissions and contribution to climate change;

Ø  energy efficiency and use of renewable energy;

Ø  resource consumption, waste generation and opportunities for reuse, recycling or circular economy approaches;

Ø  impacts on air quality, water quality, biodiversity and the natural environment;

Ø  environmental sustainability impacts of the product / service / brand being promoted which may include widely accepted evidence of particularly harmful environmental impacts;

Ø  the environmental practices, policies and commitments of the advertiser, sponsor or organisation concerned.

·         advertiser's, sponsor's or associated organisation's regulatory compliance history.

 

The weight given to these factors will be proportionate to the nature, scale and potential impact of the advertising, sponsorship or brand activation opportunity.

 

6. Developing and managing opportunities

To support sustainable income and responsible partnerships, the Council may actively develop advertising, sponsorship and brand activation opportunities, such as:

·         Publishing a clear offer (for example, asset inventory, media pack and/or rate card), subject to procurement and legal requirements,

·         Packaging opportunities to improve value and impact (for example, multi-site campaigns, event partnerships, and themed sponsorship),

·         Considering time-limited pilots where benefits are strong and risks can be monitored and managed,

·         Developing naming rights arrangements where these deliver significant public benefit and are consistent with this policy, subject to appropriate governance and approval,

·         Using standard terms and conditions, including placement rules, creative standards, and termination provisions,

·         Applying proportionate due diligence, including checks on legality, financial standing (where relevant), and alignment with council objectives.

 

7. Prohibited and restricted advertising, sponsorship and brand activation

7.1 General prohibitions

The Council will not accept advertising, sponsorship  or brand activation that, in its reasonable opinion, and after proportionate assessment:

·         Conflicts with council policies or statutory duties,

·         Damages or risks damaging the Council’s reputation,

·         Promotes illegal, violent, or socially harmful behaviour,

·         Is discriminatory or offensive,

·         Expresses political views or promotes political parties, pressure groups, or campaigns. This restriction does not apply to statutory public information, public health messaging, community awareness campaigns, charitable campaigns or equality-related communications that are consistent with the Council's duties and objectives,

·         Seeks to influence council decision‑making or procurement outcomes.

7.2 Specific prohibitions

The Council will not accept advertising or sponsorship relating to the following categories (absolute prohibitions):

·         Political organisations or lobbying groups,

·         Tobacco or related and emerging nicotine products (except where part of a national or local stop smoking campaign and central to quit support, featuring a product that is not owned or part-owned by the Tobacco Industry),

·         Addictive substances,

·         Weapons,

·         Payday loans or exploitative financial products, where the Council considers this inconsistent with its obligations to promote financial wellbeing and protect vulnerable residents,

·         Pornography or sexual services (except NHS‑endorsed sexual health content),

·         Gambling or gambling-related services, including games of chance,

·         Companies involved in fossil fuel production.

7.3 Restricted categories (case-by-case, with conditions)

The Council may consider the following categories on a case-by-case basis where legal and regulatory requirements are met and risks can be managed through conditions (for example, placement restrictions, age-gating, creative content controls, and clear non-endorsement messaging):

 

8. Council advertising

The Council may advertise its own services as appropriate using its own platforms. This may include adverts relating to traded services which generate an income.

 

9. Public Health and HFSS advertising controls

The Council will restrict advertising and sponsorship of High Fat, Sugar and Salt (HFSS) food and drink products on council‑owned and council‑managed advertising assets.

 The policy applies to:

·         Outdoor advertising (including bus shelters, hoardings, digital panels),

·         Advertising at council premises open to the public,

·         Advertising associated with council‑run or council‑supported events.

9a. HFSS assessment framework

The UK Nutrient Profiling Model (NPM) shall be used to determine whether a product is classified as HFSS.

The following rules apply:

Exceptions may be granted only in rare and clearly justified circumstances, where a product does not make a material contribution to poor health outcomes, and must be approved by the relevant senior officer.

Refer to Appendix 2 for detailed guidance on the control of HFSS advertising in the city.

10. Ethical safeguards

The Council will not enter into advertising, sponsorship or brand activation arrangements that:

 Arrangements must:

·         Deliver clear public benefit

·         Be proportionate and transparent

·         Protect the Council’s reputation and commitment to residents and communities.

 The Council retains final approval over:

·         Use of its name, logo, and branding

·         All associated marketing and communications materials related to any advertising or sponsorship partnership. 

11. Governance, approval and accountability

All advertising, sponsorship and brand activation proposals must undergo proportionate checks, as appropriate to the scale and risk of the opportunity, which may include:

·         Financial appraisal

·         Legal review

·         Communications and reputational assessment

Approvals (tiered):

The Council may remove, suspend, or terminate advertising or sponsorship that later becomes unacceptable or non-compliant, including following complaints, regulatory action, or material changes in the partner’s activities. The Council will also use complaints and performance information to refine controls and improve decision-making over time.

The Head of Strategic Communications will act as policy lead to maintain oversight of advertising and sponsorship activity across the Council.

 

12. Implementation and review

Corporate coordination of advertising and sponsorship sits with the Council’s Marketing and Communications function.

Guidance, templates, and supporting documentation will be made available to officers and potential partners.

This policy will be reviewed annually, or sooner where legislative, public health, or strategic priorities change.

13. Disclaimer

Acceptance of advertising, sponsorship and brand activation does not constitute support or endorsement of products, services, an organisation or viewpoint, by Brighton & Hove City Council.

All relevant publications and media must carry the following disclaimer:

Whilst every effort has been made to ensure the accuracy of advertisements, Brighton & Hove City Council cannot accept liability for errors or omissions, nor for claims made by advertisers. Inclusion does not constitute endorsement.

14. Further information

For advice on advertising, sponsorship or brand activation, officers and external organisations should contact the Council’s Marketing & Communications Team or refer to published guidance in the first instance:

Email: news@brighton-hove.gov.uk 

Switchboard: 01273 29 00 00

 

Appendix 1: Advertising, Sponsorship and Brand Activation Quick Reference Guide

Step 1: Is it automatically prohibited?

If YES to any of the following, the proposal is likely to be rejected.

Not Allowed

Examples

Tobacco and smoking-related products

Cigarettes, vapes, heated tobacco products, nicotine pouches

Harmful addictive substances

Illegal drugs, psychoactive substances and other harmful substances that could create dependency or undermine public health 

Gambling advertising or sponsorship

Betting companies, casinos, online gambling

Weapons

Guns, knives, ammunition, weapon retailers

Payday loans or exploitative financial products

Rent-to-own finance, guarantor loans, logbook loans, unregulated consumer lending

Pornography or sexual services

Adult services, explicit content, except NHS-endorsed sexual health content

Illegal, offensive or discriminatory content

Hate speech, unlawful activity, content promoting violence, discrimination or social harm

Political campaigning

Political parties, election campaigns, lobbying groups

Attempts to influence Council decisions

Sponsorship or advertising linked to procurement, planning, licensing or other Council decision-making outcomes 

High Fat, Salt or Sugar product advertising

Products classified as HFSS under the UK Nutrient Profiling Model

Fossil fuel production

Exploration, extraction, production, refining, or promotion of fossil fuels, including coal, oil, gas, tar sands, and unconventional hydrocarbon extraction.

Step 2: Does it pass the basic tests?

All proposals must meet all of these requirements.

✓ Legal, honest and truthful

✓ Complies with ASA/CAP advertising standards

✓ Socially responsible

✓ Supports equality, diversity and inclusion

✓ Protects children and vulnerable people

✓ Does not create conflicts of interest

✓ Does not harm public health, safety or wellbeing

✓ Considers environmental sustainability and climate commitments

✓ Protects the city's appearance, public realm and reputation

✓ Aligns with Council values and priorities

Step 3: Ethical Checklist

A sponsorship proposal can proceed only if it:

Ø  Delivers a clear public benefit

Ø  Is transparent and proportionate

Ø  Protects the Council's reputation

Ø  Does not create a real or perceived conflict of interest

Ø  Does not compromise the Council's regulatory or statutory duties

Ø  Does not imply council endorsement

Quick Decision Matrix

Outcome

What it Means

🟢 APPROVE

Meets policy requirements and presents low risk

🟠 APPROVE WITH CONDITIONS

Risks can be managed through controls, restrictions or additional approvals

🔴 REJECT

Falls within prohibited categories or presents unacceptable risk

When in doubt...

Stop and seek further advice from Marketing & Communications before progressing any advertising or sponsorship proposal.

 

Appendix 2: Control of advertising High Fat Sugar and Salt (HFSS) products

(As approved by Strategy, Finance and City Regeneration Committee on 7th December 2023)

Why is the Council controlling HFSS advertising?

Childhood obesity and overweight levels in Brighton and Hove have risen over the last few years. One in three 11-year-olds leaves primary school already overweight or obese. In some schools in the city this rises to one in two.

Nationally two out of three adults are overweight or obese, this brings with it a risk of diabetes, many cancers, heart disease and other health problems affecting our residents. Those children and adults living in more disadvantaged parts of our city have a higher chance of not being a healthy weight and suffering from the health problems that brings.

Advertising of foods that are high in fat salt and sugar has been shown to significantly increase purchase and consumption of these items. National evidence shows the relationship between the advertisement of unhealthy foods and more deprived areas. Restricting advertisements for these foods has been recommended as one of a range of evidence-based measures to reduce consumption of high calorie and less healthy food options, reducing the risk of obesity amongst children and adults. 

There is currently a restriction on advertising fast food takeaways within 100 metres of any school or youth club, NHS building, or public sector building/premises/facility/park/leisure centre primarily used by those under the age of 18 (or their guardian or carers).

The main feature of the HFSS advertising policy is that it bans the direct or indirect promotion of HFSS food and drink as defined by the UK Nutrient Profiling Model (NPM), but would not ban directional adverts e.g., “McDonald restaurant 200m left” or an advert purely showing a “healthy” product.

Application of proposed policy

This policy applies to:

Private (non-council) advertising sites  

The policy will only apply to council owned advertising sites.  There are numerous advertising sites and displays both on and adjacent to the public highway.  For example, there are about 30 free standing digital adverting panels which are former BT phone boxes now managed by One Digital, some are within several metres of a bus shelter. These adverts cannot be controlled by the policy and so there could be a situation where a branded HFSS product was displayed within a few metres of similar branded non HFSS product blunting the impact of the policy on public health.  The same applies to advertisements in shops and other premises facing the highway.

This conflict is accepted until and unless there is comparable national legislation on the control of HFSS advertising in both the public and private realms.

Purpose of HFSS policy

The policy details guidance relating to restrictions of High Fat, Salt, or Sugar (HFSS) products and requirements for advertising or sponsorship approvals. 

General Principles: The Nutrient Profiling Model

The UK Nutrient Profiling Model (NPM) has been identified as the best way of identifying food that is high in fat, salt, or sugar. It has been subject to rigorous scientific scrutiny, extensive consultation, and review. It is supported by the independent Scientific Advisory Committee on Nutrition (SACN) and a wide range of nutrition experts. The scoring system it uses balances the contribution made by beneficial nutrients important in children’s diets with food components that children should eat less of.

Guidance on how to identify whether a product is considered HFSS under the NPM is available here.

Exceptions

In rare situations, an exception will allow a product not thought to make a substantial contribution to childhood obesity although deemed unsuitable by the NPM to be approved for advertising (for example Olive Oil).

Content featuring only non HFSS products

This is approved, unless existing restrictions on advertising apply, for example:

Current guidance

Advertisements for alcoholic drinks should not feature in promotions directed at people under 18. Advertising for alcoholic beverages should not be sited within 100 meters of any school.

Existing restrictions include adverts for fast food takeaways within 100 metres of a school.

Content featuring only HFSS products

Where a proposed advertisement features only food and/or non-alcoholic drink, which is rated HFSS, such advert would be rejected.

Content featuring a range of food and/or drink products, some of which is HFSS

The advertising or promotion of HFSS products is unacceptable under the policy, so a range or meal could not feature them (e.g., individual items could only be advertised if all individual products were non-HFSS). This would also apply to any meal or eating settings being shown, including those for restaurants, aggregator platforms and delivery services.

Content featuring no food or drink directly, but the advertisement is from (or features) a food/drink brand:

This includes:

·         Advertisements where the brand’s logo is included but no products, such as a brand values campaign (e.g., X brand which is well known for fast food, or a high energy drink has a prominent advertisement without showing any food or drink).

·         Directional signage to a store, app, or website

·         Promotional advertising which is price-led but features no products, e.g., “50% off everything”

·         Advertising about a business or its performance

·         Slides delivered by a sponsor at an event sponsored by a food or drink brand products) as the basis of the advert

Food and drink brands (including food and drink service companies or ordering services) will only be able to place such advertisements if it promotes healthier options (i.e., non-HFSS products) as the basis of the copy.

Where advertisers and/or sponsors or advertising space contract holders are uncertain about the classification of proposed copy under these guidelines, they should discuss this with the council through the council’s the communications team.

Advertisements or other content where food and drink are shown ‘incidentally’ i.e., it is not the subject of the advertisement but is included (or implied) by visual or copy

HFSS products should not be promoted by being featured in advertisements for other products. It is the responsibility of advertisers and/or sponsors and their agents to verify the HFSS status of featured products using the NPM

Advertisements or other content where food and drink are referenced in the text, or through graphical representations or other visual representation contains indirect promotion of HFSS food and/or drink

HFSS products should not be promoted through textual references, graphic images, or other visual representations. Where a food or drink item is featured in this way and does not relate to a specific identifiable product which can be assessed for its HFSS status, copy may be rejected by the council on the basis that it promotes the consumption of HFSS foods.

Indirect promotion of HFSS food and/or drink

Where a product is non-HFSS but falls within a category covered by the Office for Health Improvement and Disparities (OHID - formerly PHE (Public Health England)) recommendations for sugar and calorie reduction, the product should always carry a prominent product descriptor to help differentiate it from non-compliant products (e.g. an advertisement featuring a non-HFSS burger or ice cream should include prominent text that accompanies the image naming the specific product and retailer). It is the responsibility of the advertiser and/or sponsor to determine whether products fall into a category covered by the OHID recommendations for sugar and calorie reduction.

Children should not usually be shown in advertisements for products which are compliant in a category which is covered by OHID’s recommendations for sugar or calorie reduction.

Portion sizes: The NPM model is based on nutrients per 100g of a product, rather than recommended portion size. Advertisers should always ensure that they promote products in portion sizes which encourage healthy eating. For products that are non-HFSS but fall within a category covered by PHE’s recommendations for sugar or calorie reduction, the product should be displayed as a single portion.

If advertisers, sponsors, and/or agencies are unsure about how to interpret this, or any other aspect of these guidelines, they are encouraged to contact the council or its agents and work together on a solution to avoid submitted copy requiring changes or being rejected.

Example decision table:

Advertising Content

Examples

Outcome

Notes

Only non HFSS products advertised

Fruit and vegetables, low sugar- wholegrain cereal

🟢 APPROVE

Subject is compliant with HFSS policy

Only HFSS products

Deep fried chicken burger with mayonnaise, large fries, high-sugar drinks, and ice cream

🔴 REJECT

Subject is not compliant with HFSS policy – advertiser can promote healthier product such as grilled chicken wrap with fresh vegetables, water and fruit and include the name of the business.

A range of products some of which are HFSS

An advertisement that features a shopping basket with fruit, vegetables, ice cream and high sugar drinks

🔴 REJECT

All food and drink items must be HFSS compliant – Instead, the shopping basket could contain e.g., fresh fruit, vegetables, a loaf of bread, lentils, a yoghurt, and water and include the name of the retailer.

No food or drink directly displayed but the advertisement is from (or features) a food/drink brand

A fast-food business promoting non-HFSS products such as fruit, vegetables, water, low sugar drink etc. (APPROVED)

A fast-food business promoting a HFSS product such as high sugar ice cream and drink (REJECTED)

 

🟠 POSSIBLY APPROVE (Depends on product featured)

 

Food and/or drink is shown ‘incidentally’ as part of an advert

A financial services advertisement, featuring a beach with ice cream (REJECTED)

A financial services advertisement, featuring a beach with fruit (APPROVED)

🟠 POSSIBLY APPROVE (Depends on product featured)

 

Food and drink are referenced in the text, through graphical representations or other visual representation (not a real product being advertised)

A cartoon image of a banana (APPROVED)

 

A cartoon image of a milk chocolate bar (REJECTED)

🟠 POSSIBLY APPROVE (Depends on product featured)

If the advertisement can be reasonably considered to promote HFSS products it will be rejected regardless of whether the food is an actual product.

Indirect promotion of HFSS food and/or drink

A non-HFSS soft drink with a prominent text that accompanies the image naming the specific product/retailer. (APPROVED)

 A non-HFSS soft drink without a prominent text that accompanies the image naming the specific product/retailer. (REJECTED)

 

🟠 POSSIBLY APPROVE (Only if prominent text accompanies the image naming the product and retailer)

A prominent product descriptor helps to differentiate it from non-compliant products. This is necessary where the product falls into a category typically associated with HFSS products (such as soft drinks).