Introduction

Campaign advertising framework

1.1 The December 2022 Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities⁴ (the Guidelines) establish the framework for Australian Government campaign advertising.

1.2 The Guidelines are administered by the Department of Finance (Finance) and apply to non-corporate Commonwealth entities (entities) designated under the Public Governance, Performance and Accountability Act 2013 (PGPA Act).⁵ These entities include Australian Government departments such as the Department of Defence (Defence).

1.3 The Guidelines state that they ‘operate on the underpinning premise that’:

1. members of the public have equal rights to access comprehensive information about government policies, programs and services which affect their entitlements, rights and obligations; and
2. governments may legitimately use public funds to explain government policies, programs or services, to inform members of the public of their obligations, rights and entitlements, to encourage informed consideration of issues or to change behaviour.⁶

1.4 The Guidelines apply to all information and advertising campaigns undertaken in Australia by entities⁷, including large-scale recruitment advertising for the Australian Defence Force (ADF). The Guidelines state that:

an advertising campaign involves paid media placement and is designed to inform, educate, motivate or change behaviour. Large-scale recruitment advertising not related to specific job vacancies and with a degree of creative content (e.g. Defence Force Recruiting) may be considered an advertising campaign. Entities are to seek advice from Finance if they are unsure whether an activity is an advertising campaign.⁸

1.5 The Guidelines are a government policy⁹ and entities subject to them must be able to demonstrate compliance with five overarching principles when planning, developing and implementing publicly-funded information and advertising campaigns. The principles require that campaigns are:

• relevant to government responsibilities;
• presented in an objective, fair and accessible manner;
• objective and not directed at promoting party political interests;
• justified and undertaken in an efficient, effective and relevant manner; and
• compliant with legal requirements and procurement policies and procedures.¹⁰

1.6 For advertising campaigns of $250,000 (GST exclusive) or more, the Guidelines include the following requirements relating to campaign review, certification and reporting.

• An Independent Communications Committee (ICC) will consider the proposed campaign and provide a report to the entity accountable authority¹¹ on compliance with Principles 1, 2, 3 and 4 of the Guidelines. Entities will be responsible for providing a report to their accountable authority on campaign compliance with Principle 5 of the Guidelines.
• Following consideration of the ICC and entity reports on campaign advertising compliance, the entity accountable authority will certify that the campaign complies with the Guidelines and relevant government policies.
• The entity accountable authority will provide the certification to the relevant minister who may launch the campaign or approve its launch.
• The entity accountable authority certification will be published on the relevant entity’s website when the campaign is launched.
• The compliance advice of the Independent Communications Committee will be published on Finance’s website after the campaign is launched.¹²

1.7 The Guidelines further provide that entity accountable authorities ‘will ensure that’:

• research reports for advertising campaigns with expenditure of $250,000 exclusive of GST or more are published on their entity website following the launch of a campaign where it is appropriate to do so; and
• details of advertising campaigns undertaken will be published in entity annual reports.¹³

1.8 In the Guidelines, the government has undertaken to provide reports to the Parliament that detail expenditure on all advertising campaigns with expenditure in excess of $250,000 (exclusive of GST) commissioned by PGPA Act entities.¹⁴ Finance prepares annual reports on campaign advertising as the administering entity for the Guidelines.¹⁵

1.9 Finance’s 2022–23 annual report on campaign advertising reported that the Government Communications Subcommittee of Cabinet (GCS) reviewed Australian Government advertising campaigns with budgets over $500,000 conducted by non-corporate Commonwealth entities prior to launch.¹⁶ The Department of the Prime Minister and Cabinet (PM&C) has issued a circular which sets out processes and requirements for entities engaging with the GCS and the predecessor Service Delivery and Coordination Committee of Cabinet (SDCC). The PM&C circular has been updated periodically, to reflect changing requirements.

1.10 The Guidelines provide (in paragraph 9) that the Minister for Finance can exempt a campaign from compliance with the Guidelines on the basis of a national emergency, extreme urgency or other compelling reason. Where an exemption is approved, the ICC must be informed of the exemption, and the decision formally recorded and reported to the Parliament as soon as practicable. Finance’s 2022–23 annual report on campaign advertising reported that no exemptions were sought or agreed during 2022–23.¹⁷

Guideline changes

1.11 The Guidelines have been revised periodically since their introduction in 2008. The only material change between the October 2020 and December 2022 Guidelines was that the December 2022 Guidelines clarified that all dollar figures are to be read as GST-exclusive.

1.12 Interim Guidelines were in effect between July and December 2022. They suspended the operation of the ICC¹⁸ and provided for the Minister for Finance (rather than a Cabinet sub-committee) to approve campaigns to proceed to market. This affected one of the Defence campaigns reviewed in this audit (see paragraph 2.22).

Australian Defence Force recruitment

Administrative arrangements

1.13 Prior to 1998, ADF recruiting was conducted separately by each military service for its own purposes. ¹⁹

1.14 In 2002, Defence Force Recruiting (DFR) was established as a branch of the People Capability Division (PCD) within Defence People Group (DPG). The Director-General of DFR (DGDFR) is currently an ADF officer (military one star).

1.15 DFR has responsibility within Defence for the management of campaign advertising for ADF recruitment.

Defence recruitment campaigns

1.16 In its annual report on Campaign Advertising by Australian Government Departments and Entities for 2022–23, Finance reported ‘Defence Force Recruiting’ expenditure of $60.2 million.²⁰ This figure included expenditure on all DFR advertising in 2022–23 and did not differentiate between individual campaigns (DFR’s advertising expenditure is discussed further from paragraph 2.93). The annual report also included the following objective for DFR’s consolidated campaign activities:

The campaign aimed to drive applications, build awareness and enhance propensity to consider a career in the Navy, Army or Air Force.

1.17 As shown in Figure 1.1, ADF recruitment advertising campaigns are typically the largest conducted by Australian Government entities each year. Annual reporting by Finance over time has indicated that Defence’s recruitment advertising expenditure has averaged 25 per cent of total Australian Government expenditure on campaigns over the last 10 years.

Figure 1.1: DFR advertising expenditure as a proportion of total Australian Government campaign expenditure, 2013–14 to 2022–23

Note a: Includes ‘consultants, services and other’ (advertising, market research, public relations and ‘other’) and media placement.

Note b: Consolidated campaign advertising expenditure (includes media and campaign development) by non-corporate Commonwealth entities.

Source: ANAO analysis of public reporting by the Department of Finance for the years indicated. The Campaign Advertising by Australian Government Departments and Entities report is issued annually and is available from https://www.finance.gov.au/publications/reports [accessed 4 January 2024].

1.18 As discussed in paragraph 1.4, the Guidelines apply to all information and advertising campaigns undertaken in Australia by entities, including ‘Large-scale recruitment advertising not related to specific job vacancies and with a degree of creative content (e.g. Defence Force Recruiting)’.

1.19 Defence uses ‘always-on’ marketing, which means that it generally has a presence somewhere in the market (such as social media, cinema, free-to-air TV, etc) and may run more than one campaign at a time. The term ‘campaign’ has also been used to refer to all advertising activity occurring at a point in time. For example, in March 2022, the Independent Communications Committee (discussed in paragraph 1.6) reviewed what it termed the ‘Defence Force Recruiting Campaign 2022–23’ for that year, when it reviewed aspects of all three campaigns listed in Table 1.2.

Campaigns selected for audit

1.20 In this audit, the ANAO has focused on Defence’s management of three ADF recruitment advertising campaigns launched in 2022–23. The campaigns are summarised in Table 1.2.

Table 1.2: Defence recruitment advertising campaigns launched in 2022–23, as certified by Defence’s accountable authority in March 2022

Note a: Campaign advertising is defined by Finance as ‘advertising produced and booked to appear through paid media placement as part of a planned series of communication activities that share common objectives, target the same audience and have specific timelines and a dedicated budget. Campaign advertising is designed to inform, educate, motivate or change behaviour.’

Note b: Complex Non-Campaign advertising is defined by Finance as ‘generally a block advertising program, similar to a recruitment drive, that encompasses many job vacancies or employment opportunities. As part of the recruitment process, this may require arranging of job/career fairs and information sessions (including web information sessions) to enhance media placement activity.’ See: Department of Finance, https://www.finance.gov.au/government/advertising/types-advertising [accessed 4 May 2024].

Source: ANAO representation of Defence information.

Recruitment context

1.21 Defence’s 2023–27 Corporate Plan states that the ‘Defence Strategic Review highlighted significant workforce challenges for Defence. In response, the Government has committed to grow and retain a highly skilled Defence workforce as a priority for immediate action’.²¹

1.22 Defence advised the ANAO in April 2024 that:

Employee desires for new ways of working (particularly as a result of COVID-19), a very tight job market, and 50-year-low rates of unemployment have all contributed to reduced applications to the ADF.

1.23 Responsible ministers stated in November 2022 that ‘right now we have a defence personnel crisis²²’ and in February 2024 that ‘We have a real challenge on our hands to recruit and grow the number of ADF personnel’.²³ On 25 May 2023, the Australian Government announced the appointment of the inaugural Chief of Personnel in the Australian Defence Force. This military three-star appointment commenced on 5 June 2023 and was made pursuant to recommendations in the 2023 Defence Strategic Review (DSR). The media release announcing the appointment stated that:

The DSR also recommended options be developed to change Defence’s recruitment framework.

This aims to improve the eligibility pool of potential applications and to align service recruitment requirements to military employment, especially in key technical and specialist trades.²⁴

1.24 Figure 1.2 shows that the gap between the ADF’s recruitment targets and the actual result achieved has increased over the last six years.

Figure 1.2: ADF recruitment targets compared with result achieved, 2016–17 to 2022–23

Source: ANAO analysis of Defence data.

1.25 The ADF is planned to grow from 60,831 in 2020–21 to 74,782 in 2042–43, an increase of 22.9 per cent.

Figure 1.3: ADF approved force allocation, 2020–21 to 2042–43

Source: ANAO analysis of Defence data.

Previous ANAO audits

1.26 The administration of Australian Government advertising has been examined in a series of ANAO performance audit reports, which also reviewed the development of the campaign advertising framework since its introduction in 2008.²⁵

1.27 The ANAO last examined Defence’s administration of recruitment advertising for the ADF between 2008 and 2010.²⁶

Rationale for undertaking the audit

1.28 Campaign advertising for ADF recruitment is an ongoing Defence activity and represents a material component of all Australian Government campaign advertising. In meeting its outcomes, Defence has identified ‘investing in the growth and retention of a highly skilled workforce to meet Australia’s defence and national security requirements’ as one of its seven key activities.²⁷ This audit provides independent assurance to the Parliament on Defence’s management of selected ADF recruitment campaigns.

Audit approach

Audit objective and criterion

1.29 The audit objective was to assess the effectiveness of Defence’s management of advertising campaigns for Australian Defence Force recruitment.

1.30 To form a conclusion against the audit objective, the ANAO adopted the following high-level criterion.

• Were the selected campaigns compliant with the Australian Government’s campaign advertising framework?

Audit scope

1.31 The audit focused on Defence’s compliance with the Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities issued by Finance, and the application of the associated circular issued by PM&C.

1.32 The audit did not examine Finance’s whole-of-government administration of the campaign advertising framework or other Defence recruitment initiatives.

Audit methodology

1.33 The audit involved:

• examining relevant records and documents; and
• meetings with relevant Defence personnel.

1.34 The audit was conducted in accordance with ANAO Auditing Standards at a cost to the ANAO of approximately $335,000.

1.35 The team members for this audit were Julian Mallett, Steven Meyer and Amy Willmott.

2.1 Entities undertaking campaign advertising are required to comply with the Australian Government’s campaign advertising framework (the framework). Framework requirements and processes are set out in the Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities issued by the Department of Finance (Finance), and an associated circular issued by the Department of the Prime Minister and Cabinet (PM&C).

2.2 The ANAO examined whether Defence complied with framework requirements for three selected campaigns by assessing Defence’s:

• processes for campaign review, certification and publication;
• compliance with the principles outlined in the Guidelines; and
• evaluation of campaign effectiveness.

2.3 The ANAO also examined the development of an annual media strategy by Defence.

2.4 The campaigns selected for review were:

• Take a Closer Look — launched in August 2022.
• Where It All Begins — launched in February 2023.
• Live a Story Worth Telling — launched in March 2023.

2.5 As noted at paragraph 1.11, the campaign advertising framework was introduced in 2008 and the Guidelines have been updated periodically.²⁸ The framework’s key processes and accountabilities, a number of which are specific to Defence, are summarised below.

Framework processes

2.6 The ANAO’s review was structured to reflect the processes illustrated in Figure 2.1. The steps shown in orange are those that are required by the Guidelines. The steps shown in blue have been added to provide context for the overall campaign process. Different requirements apply for individual campaigns and for the preparation of annual media strategies. There is also a two-pass government approval process for Defence campaigns, which is discussed in Box 1.

Figure 2.1: Defence Force recruiting — campaign advertising processes

Note: Reference to the GCS (Government Communications Subcommittee) should be taken to include reference to the SDCC (Service Delivery and Coordination Committee). These committees are discussed in Box 1 below.

Source: ANAO analysis.

Accountabilities under the framework

2.7 Box 1 summarises the key accountabilities in the campaign advertising framework, including the roles of entities, individuals and committees.

Note a: For the selected campaigns the responsible minister was the Minister for Defence Personnel. In this report, references to ‘the minister’ are to the Minister for Defence Personnel unless otherwise specified.

Note b: The SDCC existed from May 2019 to May 2022. The GCS has existed since May 2022.

Note c: In 2016, Defence was granted a ‘concession’ which meant it was only required to take material to SDCC/GCS twice (unlike other entities which were required to do so three times).

Note d: Entities are required to use Hall & Partners for these services. Hall & Partners are paid by each entity using its services.

Note e: Entities are required to use Universal McCann. The Central Advertising System is the coordinated procurement arrangement that consolidates expenditure and buying power to secure optimal media rates for the placement of government advertising.

Note f: Entities are responsible for providing a report to their accountable authority on campaign compliance with Principle 5 of the Guidelines (see paragraph 1.6).

Source: ANAO analysis. Key elements of the framework are described in the December 2022 Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities and the Department of Finance’s Campaign Advertising by Australian Government Departments and Agencies Report 2022–23.

Were the required review, certification and publication requirements undertaken for the selected campaigns?

Where It All Begins (ADFA) campaign

2.8 In 2013, Defence launched a campaign called ‘Future Leaders’ which was aimed at attracting people in the target market (15–24 year olds) to consider a career in the ADF and enrol in the Australian Defence Force Academy (ADFA).²⁹ In 2019, research undertaken for Defence reported that ‘recognition of the ADFA campaign has dropped significantly among its youth target’.

2.9 DFR commissioned a creative agency (VMLY&R³⁰) to develop a campaign concept for a new campaign. Two concepts were developed and tested with focus groups. In April 2021, DFR presented a brief to the minister seeking approval for the preferred concept, Where It All begins, and obtained agreement to present the creative concept to the Service Delivery and Coordination Committee of Cabinet (SDCC) for first pass approval.

2.10 In May 2021, the government reviewed the evaluation and concept testing research and gave second pass approval that the Where It All Begins campaign could proceed to production. Filming was twice postponed due to the COVID-19 pandemic.

2.11 On 19 January 2023, the minister approved the advertising products that had been developed and agreed that the final materials be presented to the Government Communications Subcommittee of Cabinet (GCS) for approval. In January 2023, government reviewed the materials developed for the campaign and approved the campaign proceeding to placement in the media.

2.12 On 16 January 2023, DFR submitted a brief to the Secretary of Defence seeking agreement to the Accountable Authority Certification Statement required by the Guidelines. The briefing included a detailed supporting statement. The Secretary signed the Certification on 20 January 2023³¹ and it was published on Defence’s website as required by the Guidelines.

2.13 The Where It All Begins campaign ‘went live’ on 6 February 2023.

2.14 The Guidelines state that ‘Accountable Authorities will ensure that details of advertising campaigns undertaken will be published in entity annual reports’. Since May 2016, the Public Governance, Performance and Accountability Rule 2014 (PGPA Rule) has also required entities to include a statement in their annual reports naming the advertising campaigns conducted during the reporting period (financial year).³² Defence’s 2022–23 annual report included a section on advertising and market research, which related to its overall expenditure in this area. It did not list the individual campaigns.

2.17 The Guidelines also state that ‘Accountable Authorities will ensure that research reports for advertising campaigns with expenditure of $250,000 exclusive of GST or more are published on their entity web site following the launch of a campaign, where it is appropriate to do so’. There was no evidence that Defence considered whether publication of the research reports was appropriate and Defence did not include this information on its website. In April 2024, DFR advised the ANAO that ‘DFR was unaware of this requirement. DFR will comply with the requirement from this point forward’.

Take a Closer Look campaign

2.19 Market research of the 15–35 age group undertaken by external providers (Hall & Partners) in April to June 2021 suggested a ‘misalignment’ between job attributes valued by that group and those offered by the ADF. On 18 January 2022, DFR briefed the minister and advised that:

Research undertaken by Hall & Partners in June 2021, with DFR’s target audience indicates a perception misalignment between ideal job attributes and what the ADF delivers. Shifts in motivational drivers have also been observed amongst 15 to 35 year olds, with more importance placed on work-life balance, mental health, job security, family and good pay compared to traditional Defence attractors of travel and adventure …

To address this challenge, DFR is working with the media and creative agencies to adapt messaging and optimise communication channels to more effectively reach and engage with the target audience.

2.20 In the brief, DFR proposed to the minister an ‘explicit needs’ campaign (called Take a Closer Look) aimed at addressing three explicit needs of the target audience: work-life balance, good salary and job security. On 28 January 2022, the minister approved presentation of the concept to the SDCC.

2.21 In February 2022, the government reviewed the evaluation and concept testing research and provided first pass approval, agreeing that the Take a Closer Look campaign proceed to production.

2.22 In July 2022, Interim Guidelines were issued, which enabled the Minister for Finance to approve the launch of a campaign.³³ Under the Interim Guidelines, on 17 July 2022 DFR sought the minister’s agreement to launch the Take a Closer Look campaign. On 2 August 2022, the minister wrote to the Minister for Finance seeking approval for the campaign proceeding to placement in the media. The Minister for Finance provided approval on 10 August 2022.

2.23 On 27 July 2022, DFR submitted a brief to the Defence Secretary seeking agreement to the Certification Statement required under the Guidelines. The briefing included a detailed supporting statement.³⁴ The Secretary signed the Certification on 2 August 2022 and it was published on Defence’s website as required by the Guidelines.³⁵

2.24 The Take a Closer Look campaign was launched on 21 August 2022.

2.25 As discussed in paragraphs 2.14, 2.17 and 2.25, Defence did not meet the requirement to publish the name of the campaign in its annual report and did not publish research reports for the campaign on its website. Defence advised the ANAO in April 2024 that it had not published the research reports because it was not aware of the requirement to consider doing so.

Live a Story Worth Telling campaign

2.26 An advertising campaign for the Navy titled What Will You Bring? was launched in July 2016. A January 2022 brief to the minister advised that:

This campaign has been successful in driving propensity to join, however since 2019/20 there has been a steady decline in Navy applications. As at 10 January 2022, Navy applications are down 42 percent compared to the same period [a] year ago with a significant decline also seen across STEM roles.’

2.27 Market research conducted by external providers (Hall & Partners) in September 2021 also showed declines in Navy ‘brand recognition’ among the target demographic.

2.28 A creative agency (VMLY&R) was engaged by Defence to develop a new concept, which was provided to DFR in September 2021. An external provider (WhereTo) was also engaged to undertake market testing of the concept in October and November 2021, and recommended that the Live a Story Worth Telling concept proceed. On 2 February 2022, the minister approved the concept and agreed that it be presented to the SDCC.

2.29 On 10 February 2022, the government reviewed the materials that had been developed for the campaign as part of the first pass approval process and agreed to the campaign proceeding to the next stage of development.

2.30 On 9 November 2022, the minister approved the final advertising materials that had been developed and agreed to their presentation to GCS. On 15 November 2022, the government gave second pass approval and agreed that the Live a Story Worth Telling campaign could proceed to placement in the media.

2.31 On 19 January 2023, DFR submitted a brief to the Acting Secretary of Defence seeking agreement to the Certification Statement required under the Guidelines. The briefing included a detailed supporting statement.³⁶ The Acting Secretary signed the Certification on 24 January 2023 and it was published on Defence’s website as required by the Guidelines.³⁷

2.32 The Live a Story Worth Telling campaign was launched on 19 March 2023.

2.33 As discussed in paragraphs 2.14 and 2.17, Defence did not meet the requirement to publish the name of the campaign in its annual report and did not publish research reports for the campaign on its website. Defence advised the ANAO in April 2024 that it had not published the research reports because it was not aware of the requirement to consider doing so.

Annual media strategy and Independent Communications Committee

2.34 As discussed in paragraph 1.9 and Box 1, the Department of the Prime Minister and Cabinet (PM&C) has issued guidance for entities which sets out requirements for preparing items for consideration by Cabinet committees with a role in approving government campaign advertising — the Service Delivery and Coordination Committee (SDCC) and later the Government Communications Subcommittee (GCS).

2.35 One of the requirements was for entities to present to government an annual Media Strategy. On 10 February 2022, DFR provided the minister with the draft media strategy for 2022– 23 for consideration, together with a draft submission for the SDCC. The draft media strategy included details of:

• research undertaken into the effectiveness of campaign activity in 2020–21 and the first two quarters of 2021–22;
• research into strategies to target particular audiences (Generation Z and 25–34 year olds);
• a media overview plan;
• a communications strategy;
• proposed campaign budget; and
• the aims, communication objectives and key messages for the Take a Closer Look, Where It All Begins and Live a Story Worth Telling campaigns.

2.36 The minister approved the annual Media Strategy on 17 February 2022 and it was considered and approved by the government on 16 March 2022.

2.37 Consistent with arrangements agreed by government in 2016³⁸, the strategy was then submitted to the Independent Communications Committee (ICC) for review. The ICC reviewed the strategy on 17 March 2022 and on 18 March 2022, the ICC wrote to the Secretary of Defence in the following terms³⁹:

On 17 March 2022, the Committee considered the Defence Force Recruiting campaign being developed by the Department of Defence. As part of its consideration of this campaign, the Committee met with your officers and reviewed the following supporting documentation:

1. communication strategy
2. campaign tracking research
3. draft media strategy and indicative media plan overview
4. a statement against Principles 1 to 4 of the Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities (Guidelines).

The Committee is satisfied that the campaign is relevant to government responsibilities (Principle 1), and that the campaign is being developed in line with Principles 2 to 4 of the Guidelines. The Committee’s view has been formed at the communication strategy stage, and it has not considered the advertising materials. For this reason, the Committee has concluded that the proposed Defence Force Recruiting campaign is capable of complying with Principles 1 to 4 of the Guidelines.

2.38 As noted by the ICC, it concluded that the proposed campaign was ‘capable’ of complying with Principles 1 to 4 of the Guidelines. The timing of the ICC’s review meant that at that stage, final advertising material had not yet been developed and could therefore not be considered by the ICC. The ANAO has previously observed that the ICC’s role does not involve the examination of actual final campaign material and recommended that the ICC’s terms of reference be amended to enable the ICC to review and advise on final advertising materials, including creative materials.⁴⁰ In September 2020, the government decided to not implement the ANAO recommendation.⁴¹

2.39 The report of the ICC is required to be published on the Department of Finance’s website. This occurred on 19 July 2022.⁴²

2.40 The Acting Secretary of Defence completed a Certification Statement for the 2022–23 media strategy, which was posted on Defence’s website.⁴³

Were the principles of the Australian Government’s campaign advertising framework adhered to for the selected campaigns?

2.41 As discussed in paragraph 1.5, the 2022 Guidelines state that:

Entities subject to the Guidelines must be able to demonstrate compliance with the five overarching principles when planning, developing and implementing publicly-funded information and advertising campaigns. The principles require that campaigns are:

• relevant to government responsibilities
• presented in an objective, fair and accessible manner
• objective and not directed at promoting party political interests
• justified and undertaken in an efficient, effective and relevant manner, and
• compliant with legal requirements and procurement policies and procedures.⁴⁴

2.42 The Guidelines provide information under each of the overarching principles to illustrate how entities can demonstrate compliance.⁴⁵ This information is framed as ‘considerations’ which could evidence compliance with the principle. The principles and ‘considerations’ are reproduced in Appendix 3.

2.43 The ANAO considered the three selected Defence campaigns against each principle. Not all ‘considerations’ are relevant to these campaigns.⁴⁶

Principle 1 — were the campaigns relevant to government responsibilities?

2.44 In the Statement against the Principles provided to the Defence Secretary for certification of the 2022–23 Media Strategy, DFR stated that:

Defence Force Recruiting (DFR) advertising is directly related to the Australian Government’s key priority to defend the nation and its interests. DFR is responsible for recruiting men and women for the Australian Navy, Army and Air Force, and uses its advertising as a proven means by which to attract them and maintain a constant flow of candidates into the recruiting pipeline.

All DFR advertising expenditure is funded from Defence’s annual appropriations for departmental outcomes under Outcome 1, Program 1.12: Defence People. DFR is responsible for delivering ab-initio people capability to meet future force requirements detailed in the Force Structure Plan 2020 and Defence White Paper 2016.

2.45 In the Guidelines, one of the ‘considerations’ for demonstrating compliance with Principle 1 is that: ‘The subject matter of the campaign directly relates to the Government’s responsibilities.’ Paragraph 51(vi) of the Australian Constitution provides that the legislative powers of the Australian Parliament include ‘the naval and military defence of the Commonwealth and of the several States’. On that basis, the three selected campaigns complied with Principle 1.

Principle 2 — were the campaigns presented in an objective, fair and accessible manner and designed to meet the objectives of the campaigns?

Campaign content

2.46 In the Guidelines, the ‘considerations’ for demonstrating compliance with Principle 2 include the following.

• The recipients of the information can distinguish between facts, comment, opinions and analysis;
• Information presented as a fact, is accurate and verifiable;
• The basis of factual comparisons is clear and does not mislead the recipient about the situation;
• Pre-existing policies, products, services and activities are not presented as new; …

2.47 The ANAO reviewed all final campaign materials for the three campaigns as shown in Table 2.1.

Table 2.1: Final campaign materials reviewed by the ANAO, by document type

Note a: The ANAO asked DFR to provide copies of all final campaign materials. The ANAO reviewed a selection of images for the Where it All Begins campaign, as Defence could not confirm how many of the 564 images provided had proceeded to media placement.

Source: ANAO analysis of Defence documentation.

2.48 The final campaign materials reviewed by the ANAO were compliant with the objectivity requirements of Principle 2.

Accessibility of campaign materials

2.49 In the Guidelines, the ‘considerations’ for demonstrating compliance with Principle 2 also include the following:

• Special attention is paid to communicating with disadvantaged individuals or groups identified within the target audience. Particular attention is paid to meeting the information needs of Aboriginal and Torres Strait Islander Australians, the rural community, people with disability and those for whom English is not a convenient language in which to receive information;
• Imagery used in campaigns appropriately reflects the diverse range of Australians. Where it is consistent with the campaign objectives, this includes the realistic portrayal of the full participation of women, Aboriginal and Torres Strait Islander Australians, culturally and linguistically diverse communities and people with disability; and
• Campaigns are tested with target audiences to indicate they are engaging and perform well against their objectives.

2.50 The ANAO’s review of final campaign materials indicates the following:

• Take a Closer Look contained images of military hardware, not people. The campaign materials with voiceovers had both male and female voiceovers.
• For Where it All Begins and Live a Story Worth Telling, both campaign images and videos included a diverse range of Australians, in terms of gender and ethnicity.
• Print, audio and video materials for the selected campaigns were produced in the English language only.⁴⁷

2.51 Figure 2.2 to Figure 2.4 show some examples of images from the selected campaigns.

Figure 2.2: Example of advertisements used in the Take a Closer Look campaign

Source: Department of Defence.

Figure 2.3: Examples of advertisements used in the Where It All Begins campaign

Source: Department of Defence.

Figure 2.4: Examples of advertisements used in the Live a Story Worth Telling campaign

Source: Department of Defence.

Campaign testing

2.52 As discussed in paragraph 2.49, the Guidelines state that one of the ‘considerations’ for demonstrating compliance with Principle 2 is that: ‘Campaigns are tested with target audiences to indicate they are engaging and perform well against their objectives’.

2.53 The selected campaigns underwent concept testing to determine the effectiveness and engagement of campaign materials prior to release. DFR conducted testing at two stages for each campaign: at the concept stage and at the final stage of development.⁴⁸ Testing involved multiple qualitative focus group discussions with people of different ages, genders and locations from within the target audience. Some focus groups had sub-groups of the target audience, such as STEM-aligned individuals, indigenous people, teachers or parents. Focus groups were conducted online.

Take a Closer Look campaign

2.54 The concept testing report (November 2021)⁴⁹ recommended proceeding with one of the two ‘explicit needs’ campaigns developed by the creative agency (VMLY&R). The report said that both options tested strongly with audiences.

2.55 The final testing report for Take a Closer Look (May 2022) recommended proceeding with the campaign as it would fill ‘critical gaps’ in knowledge and had ‘no major weaknesses or significant issues.’ The report noted that the campaign would increase target audience awareness of good work-life balance, opportunity for personal growth, and opportunities and benefits not available with other employers, including financial benefits.

2.56 The creative agency (VMLY&R) updated some campaign materials based on DFR feedback.

Where It All Begins campaign

2.57 The concept testing report⁵⁰ was provided to Defence in September 2020. The report recommended proceeding with the Where it All Begins campaign. The report recommended that new communications be established within the campaign to clearly communicate information ‘such as ‘ADFA is a world-class university at which you get a degree.’

2.58 The final creative testing report (October 2022) found that overall, the campaign materials ‘successfully communicated the message that ADFA offers a “world-class university education,” which was new news to many’.’ The campaign was also considered to communicate core benefits, including getting a fully funded degree, a salary whilst studying and a guaranteed career upon completion. ⁵¹

2.59 The report recommended simplifying the campaign ‘headlines’ and communicating that ADFA is a university. The report provided three alternative headlines.⁵² The previous headlines were subsequently replaced with ‘This is no ordinary university education’ in all images.

Live a Story Worth Telling campaign

2.60 The concept testing report (November 2021)⁵³ recommended that Defence proceed with development of the Live a Story Worth Telling campaign, on the following grounds:

Live a Story Worth Telling offers the greatest opportunity to evolve the positioning of the Navy and tell the audience something new about what’s on offer, and what they could expect from a Navy career. The gravitas and sense of worthiness appeals to a different side and a wider range of people, and it helps to broaden audience understandings of Navy careers.

2.61 The report also noted that the campaign concept may not provide enough action for ‘adventure and excitement seekers’ and suggested that Defence look at other ways of appealing to this group.

2.62 The final concept testing report (September 2022) concluded that:

Across two round[s] of creative testing, we have shown that DFR have created a strong, well-balanced suite of brand advertising, able to add to people’s understating [sic] of Navy roles, and able to inspire and motivate new interest in Navy careers. We are confident that the final suite has at least two effective creative executions across every channel and offers Navy strong potential as a recruitment campaign.

2.63 The ANAO’s review of materials for the three selected campaigns found that they complied with the requirements of Principle 2.

Principle 3 — were the campaigns objective and not directed at promoting party political interests?

2.64 In the Guidelines, the ‘considerations’ for demonstrating compliance with Principle 3 include the following:

• Language used in the campaign is objective language and is free of political argument; and
• Campaigns must not try to foster a positive impression of a particular political party or promote party political interests.

2.65 The Guidelines also provide that:

Campaigns must not:

1. mention the party in Government by name;
2. directly attack or scorn the views, policies or actions of others such as the policies and opinions of opposition parties or groups;
3. include party political slogans or images;
4. be designed to influence public support for a political party, a candidate for election, a Minister or a Member of Parliament; or
5. refer or link to the web sites of politicians or political parties.

2.66 For the three selected campaigns, DFR advised the Defence Secretary, in the Statement Against the Principles, that:

DFR advertising is by its nature free of political interests, with no party-political themes, messages, or content. The website referenced in DFR advertising is www.defencejobs.gov.au which houses content on ADF jobs, pay and conditions, training, fitness standards and the recruiting process.

2.67 The ANAO’s review of final campaign materials for the three selected campaigns found that they were compliant with the requirements of Principle 3.

Principle 4 — were the campaigns justified and undertaken in an efficient, effective and relevant manner?

2.68 In the Guidelines, the ‘considerations’ for demonstrating compliance with Principle 4 include the following.

• Campaigns are only instigated where a need is demonstrated, target recipients are clearly identified and the campaign is informed by appropriate research or evidence;
• Campaign information clearly and directly affect [sic] the interests of recipients;
• The medium and volume of the advertising activities is cost effective and justifiable within the budget allocated to the campaign; and
• Campaigns are evaluated to determine effectiveness.

2.69 As discussed earlier in this chapter, for the three selected campaigns there was evidence of:

• a documented justification (see paragraphs 2.9, 2.20 and 2.26);
• consideration of target groups (see paragraphs 2.9, 2.21 and 2.28);
• research activity, such as market research, concept testing and creative testing (see paragraphs 2.8, 2.10, 2.19, 2.21, 2.27 and 2.28); and
• campaign information (campaign materials) directed to the interests of the identified recipients (see paragraphs 2.49 to 2.51).

2.70 There was evidence that Defence’s media buy for each of the selected campaigns was based on advice from the mandated master media agency.

2.71 Defence’s expenditure (to date) for each of the selected campaigns is discussed from paragraph 2.93 and campaign evaluation activity is discussed from paragraph 2.102.

Principle 5 — were the campaigns compliant with legal requirements and procurement policies and procedures?

Legal requirements

2.72 Principle 5 of the Guidelines states that:

29. The manner of presentation and the delivery of campaigns must comply with all relevant laws including:

1. laws with respect to broadcasting and media;
2. privacy laws;
3. intellectual property laws;
4. electoral laws;
5. trade practices and consumer protection laws; and
6. workplace relations laws.

2.73 For each campaign, DFR provided Defence Legal with a selection of campaign materials for legal review and clearance. Defence Legal conveyed its advice by email that relevant materials had been reviewed and that there were no legal concerns with the content. The emails did not explicitly refer to the items included in Principle 5.⁵⁴

2.74 In April 2024, Defence advised the ANAO that:

Special Counsel (Defence People Group) confirmed in reviewing the content, Defence Legal are conscious of Principle 5 of the Guidelines on Information and Advertising Campaigns (being broadcasting and media laws; privacy; IP; electoral; trade practices and consumer protection laws; and workplace relations laws).

Upon viewing the content, where Defence Legal identify an issue, they will notify DFR via email of the issue.⁵⁵

2.75 As discussed in paragraphs 2.12, 2.23 and 2.31, supporting statements were provided to the Defence Secretary (signed by the Head, People Capability) to provide assurance that the Principles have been complied with. The supporting statements contained the assurance that: ‘Defence Legal have been consulted and confirm that the key campaign messages are factual and supported by extant Defence policies’. As noted at paragraph 1.6, the Secretary’s certification is required to be published on Defence’s website.

Procurement policies and procedures

2.77 The Guidelines state that: ‘Procurement policies and procedures for the tendering and commissioning of services and the employment of suppliers are to be followed, and there must be a clear audit trail regarding decision making.’

2.78 During the development and implementation of the three selected campaigns, DFR used the service providers shown in Table 2.2.

Table 2.2: Service providers used by Defence Force Recruiting for the selected campaigns

Source: ANAO analysis of Defence information.

Mandated service providers

2.79 Two service providers (Hall & Partners and Universal McCann) were engaged by the Department of Finance⁵⁶ and their use was mandated.

• Hall & Partners provides whole-of-government campaign evaluation and market research services for advertising campaigns conducted by non-corporate Commonwealth entities with expenditure above $500,000 per financial year.
• Universal McCann provides Master Media Agency services for the Australian government, including campaign and non-campaign advertising planning and placement services.

2.80 Table 2.3 shows the value of work undertaken for Defence by Hall & Partners and Universal McCann in 2022–23.

Table 2.3: 2022–23 Defence expenditure: mandated service providers

Source: AusTender data.

Panel providers

2.81 Two of the Defence service providers (ChatHouse and WhereTo) are members of a Market Research Services panel that Defence first established in May 2007 and retendered in 2010,2016 and 2021. Both companies have been members of the panel since 2016.⁵⁷

2.82 In April 2020, DFR issued a Tasking Statement (request for quotation) to the four panel members for concept and creative testing for a possible ADFA (Where It All Begins) advertising campaign. Three responses were received. These were evaluated by a Defence evaluation team⁵⁸ which recommended that ChatHouse be awarded the ‘ADFA concept and creative testing activity’. The delegate approved the evaluation team’s recommendation and a contract with ChatHouse to November 2020 was entered into.⁵⁹ Due to ‘circumstances outside the control of Chathouse’ and ‘additional unforeseen circumstances (COVID)’, the project was delayed and the contract with ChatHouse expired before it could undertake the testing of final creative materials. DFR sought and obtained delegate approval to issue a fresh contract to ChatHouse without inviting tenders from other members of the Market Research Services panel. An email from a contract officer in DFR’s Directorate of Business and Contract Management noted that the ‘continuation is for the remainder of the works’ and that ‘the only changes were the final dates to account for delays that have occurred’.⁶⁰

2.83 As noted in paragraph 2.19, market research by Hall & Partners had suggested a ‘misalignment’ between ‘ideal’ job attributes and those that the ADF can deliver. The government approved the development of a campaign (Take a Closer Look) in March 2022. In October 2021, DFR invited WhereTo Research (WhereTo) to provide a quote for the provision of ‘Concept and Final Creative Testing’ for what was then termed a ‘Reversing ADF Application Decline Campaign’. WhereTo was on the Market Research Services Panel discussed in paragraph 2.81. The subsequent evaluation report assessed that it offered value for money on the basis that WhereTo ‘provides very good efficiency for the project as they already possess an in-depth understanding of the application decline situation/market factors and are familiar with the Tri Service Reversing the Application Decline initiatives.’ The delegate approved the engagement of WhereTo on 22 October 2021 and a contract was entered into on 23 October 2021.

Limited tender — Creative Advertising and Digital Services

2.84 In 2018, a contract with Defence for Creative Advertising and Digital Services was held by Havas Worldwide Australia trading as Host/Havas. The contract was due to expire on 31 March 2019.

2.85 In March 2018, SDCC agreed that eight suppliers from the Department of Finance’s Campaign Advertising Supplier Register (CASR), including Host/Havas, be invited to participate in a limited tender process, with Defence to return to SDCC with recommended shortlisted suppliers.

2.86 In September 2018, DFR provided the Minister for Defence Personnel with the procurement evaluation results for the limited tender process, which identified two tenderers as ‘shortlisted tenderers’ (including VMLY&R).⁶¹ Consistent with the evaluation results, in November 2018 the minister recommended to SDCC the appointment of ‘a tenderer’ for the delivery of DFR’s Creative Advertising and Digital Services.

2.87 SDCC agreed to the appointment of a tenderer, as proposed. The available records do not indicate which of the two shortlisted tenderers was selected or whether one was endorsed over the other by the SDCC. Further, Defence records do not indicate whether the decision to negotiate with VMLY&R between 12 and 21 December 2018 (and not the other shortlisted tenderer) was made by officials. In April 2024, DFR advised the ANAO that:

DFR is unclear why Ministerial Brief [MS18-002800] did not suggest to the Minister that he recommend a single preferred tenderer out of the two shortlisted tenders. DFR cannot explain why the brief does not recommend a tenderer.

2.88 In June 2024, Defence advised the ANAO that it had undertaken additional searches of its records and provided the ANAO with the following documents for both shortlisted tenderers:

• ‘detailed financial assessments’⁶²;
• negotiation registers listing issues with the tendered proposal that would need to be resolved; and
• contract negotiation directives.⁶³

2.89 Defence also advised the ANAO in June 2024 that the detailed financial viability assessments conducted in September 2018 indicated that the other shortlisted tenderer ‘represented a relatively high financial risk.’ Defence further advised that ‘Defence records do not show whether it undertook a negotiation with [the other shortlisted tenderer], or whether no negotiation was entered into given those risks’.

2.90 Defence advised the ANAO that the 7 January 2019 section 23 approval demonstrated that the Director General of DFR was the decision-maker ‘for the selection of VMLY&R as Defence’s contractor for creative advertising’.⁶⁴ In accordance with the Defence Procurement Manual, the section 23 approval was provided seven days before Defence’s contract with VMLY&R was executed on 14 January 2019. The identity and approval of the decision-maker for the decision to negotiate with VMLY&R in December 2018 (and not the other shortlisted tenderer) was not documented as required.

2.91 A contract notice for VMLY&R was published on AusTender on 8 February 2019 with a stated value of $55.7 million.⁶⁵ The contract was later extended, and the contract value increased to $112.8 million.

2.92 As noted in paragraph 2.82, when seeking to engage the services of a member of the Market Research Services panel, DFR issued Tasking Statements (requests for quotation). There were no similar documents for the commissioning of Creative Advertising and Digital Services work from VMLY&R. In April 2024, Defence advised the ANAO that: ‘There are no tasking statements for campaign production(s)’.

Campaign costs

2.93 As discussed at paragraph 2.37, government committees refer to and consider DFR’s advertising activities as one campaign with the exception of approval for the development and implementation of new campaign advertising assets. Defence advised the ANAO in April 2024 that its campaign budgets are endorsed once by government and the ICC for the creative and production costs for new materials and annually for media placement costs.

Market research and creative and production costs

2.94 In terms of expenditure, market research and creative and production costs are incurred by Defence prior to receiving SDCC approval for the final campaign materials to proceed to placement in the market. The ANAO sought Defence’s advice on these costs.

2.95 Defence advised the ANAO in April 2024 that all market research and creative and production costs for each campaign were incurred prior to 30 June 2023 as follows:

• Take a Closer Look: planned expenditure was $921,921 and actual was $859,106;
• Where It All Begins: planned expenditure was $1,737,842 and actual was $1,989,863; and
• Live a Story Worth Telling: planned expenditure was $4,213,344 and actual was $4,960,727.

Media placement costs

2.96 All three campaigns were still ‘in the market’ at the time of this audit and costs for media placement will be ongoing for some time.⁶⁶ In April 2024, Defence advised the ANAO that it could only provide actual media placement costs to 30 June 2023 as more recent figures ‘cannot be provided until reconciled by the MMA [Master Media Agency (Universal McCann)] at the end of the financial year’.

2.97 On 7 June 2024, after seeking more recent information from Universal McCann, Defence provided the following figures which it advised are the planned and actual expenditure costs for media placement for each campaign from commencement to February 2024:

• Take a Closer Look: planned expenditure was $9,618,928 and actual was $9,330,518;
• Where It All Begins: planned expenditure was $1,398,375 and actual was $1,384,852; and
• Live a Story Worth Telling: planned expenditure was $5,660,968 and actual was $5,410,873.

2.98 Defence could not provide the ANAO with supporting evidence to verify the accuracy of the expenditure information it provided. In the absence of this information, no assurance can be provided on the accuracy or completeness of the campaign advertising expenditure as advised by Defence.

Public reporting on campaign costs

2.99 As discussed in paragraph 1.16, in its annual report on Campaign Advertising by Australian Government Departments and Entities for 2022–23, Finance reported ‘Defence Force Recruiting’ expenditure of $60.2 million.⁶⁷ This figure included expenditure on all DFR advertising in 2022–23 and did not differentiate between individual Defence campaigns. In contrast, for other entities, the report does include expenditure on individually named campaigns. Further, as discussed in paragraph 2.14, information on individual Defence campaigns has not been reported by Defence in its annual report. Consequently, there is no public reporting on the cost of individual Defence recruiting campaigns, which reduces transparency to the Parliament and community.

Were the selected campaigns evaluated to determine effectiveness?

2.102 DFR uses Hall & Partners to monitor the performance of campaigns which are in the market through quarterly Communications Tracking reports. These reports measure the ‘reach, response and impact’ of the campaigns based on focus groups held with members of the target groups (such as 15 – 35 year olds).⁶⁸ The tracking reports are used by DFR to assess whether campaign messages are reaching the intended audience.⁶⁹ They are also used as part of the ‘first pass’ submission to SDCC.

2.103 Separately, the Guidelines and associated circular issued by the Department of the Prime Minister and Cabinet (PM&C) (see paragraph 2.1) require that campaigns be evaluated ‘to determine effectiveness’. The circular requires the evaluation to be completed ‘as soon as practicable after the conclusion of media activity, typically within three months.’ These evaluations form part of the whole-of-government contract between the Department of Finance and Hall & Partners.⁷⁰ The statement of requirements which form an annex to the whole-of-government contract state that:

Once the campaign is in market, tracking is conducted (continuous or burst depending on the campaign characteristics), following which final reporting is undertaken, delivering a detailed full evaluation report, one page summary of the campaign results and a presentation.

2.104 At the time of this audit, the three campaigns examined were still ‘in the market’ and had therefore not been formally evaluated. In November 2023, DFR advised the ANAO that it does not commission post-campaign evaluations from Hall & Partners because ‘the quarterly [tracking reports] provide this coverage’. As a result, there were no approved evaluation plans for these advertising campaigns.

2.105 The requirement in the PM&C circular to evaluate campaigns to determine their effectiveness is consistent with the Commonwealth Evaluation Policy which states that:

Commonwealth entities and companies are expected to deliver support and services for Australians by setting clear objectives for major policies, projects and programs, and consistently measuring progress towards achieving these objectives.⁷¹

2.106 While objectives had been developed for each of the three campaigns, there were different variations of those objectives appearing across Defence’s campaign documentation. In some instances, various objectives were identified for a campaign within the same document. For example, for Where It All Begins, the first pass submission to the SDCC described objectives as ‘to drive the number of applications to meet recruiting targets and build propensity to apply for ADFA’ and ‘to inspire, inform and persuade the target audience’.

2.107 The Commonwealth Evaluation Policy defines effectiveness ‘as the extent to which a program’s outcomes achieve its stated objectives’. To support effective evaluation and improve clarity in its reporting, there would be merit in Defence ensuring that its advertising campaign objectives are conveyed consistently across its documentation and are clearly established at the outset in an evaluation plan.

Appendix 1 Entity response

Appendix 2 Improvements observed by the ANAO

1. The existence of independent external audit, and the accompanying potential for scrutiny improves performance. Improvements in administrative and management practices usually occur: in anticipation of ANAO audit activity; during an audit engagement; as interim findings are made; and/or after the audit has been completed and formal findings are communicated.

2. The Joint Committee of Public Accounts and Audit (JCPAA) has encouraged the ANAO to consider ways in which the ANAO could capture and describe some of these impacts. The ANAO’s Corporate Plan states that the ANAO’ s annual performance statements will provide a narrative that will consider, amongst other matters, analysis of key improvements made by entities during a performance audit process based on information included in tabled performance audit reports.

3. Performance audits involve close engagement between the ANAO and the audited entity as well as other stakeholders involved in the program or activity being audited. Throughout the audit engagement, the ANAO outlines to the entity the preliminary audit findings, conclusions and potential audit recommendations. This ensures that final recommendations are appropriately targeted and encourages entities to take early remedial action on any identified matters during the course of an audit. Remedial actions entities may take during the audit include:

• strengthening governance arrangements;
• introducing or revising policies, strategies, guidelines or administrative processes; and
• initiating reviews or investigations.

4. During the course of the audit, the ANAO did not observe changes in Defence’s approach to its management of recruitment advertising campaigns.

Appendix 3 Campaign principles

1. The December 2022 Australian Government Guidelines on Information and Advertising Campaigns set out the five overarching campaign principles. Paragraph 11 of the Guidelines provides that:

These Guidelines are a government policy. Entities subject to the Guidelines must be able to demonstrate compliance with the five overarching principles when planning, developing and implementing publicly-funded information and advertising campaigns. The principles require that campaigns are:

• relevant to government responsibilities
• presented in an objective, fair and accessible manner
• objective and not directed at promoting party political interests
• justified and undertaken in an efficient, effective and relevant manner, and
• compliant with legal requirements and procurement policies and procedures.

2. The Principles are:

Principle 1: Relevant to government responsibilities

23. In demonstrating compliance with this principle considerations include:

• The subject matter of the campaign directly relates to the Government’s responsibilities
• The policy or program is underpinned by:
  • legislative authority; or
  • appropriation of the Parliament; or
  • a Cabinet Decision which is intended to be implemented during the current Parliament

24. Examples of suitable uses for government campaigns include to:

• inform the public of new, existing or proposed government policies, or policy revisions;
• provide information on government programs or services or revisions to programs or services to which the public are entitled;
• inform consideration of issues;
• disseminate scientific, medical or health and safety information; or
• provide information on the performance of government to facilitate accountability to the public.

Principle 2: Presented in an objective, fair and accessible manner

25. In demonstrating compliance with this Principle considerations include:

• The recipients of the information can distinguish between facts, comment, opinion and analysis;
• Information presented as a fact, is accurate and verifiable;
• The basis of factual comparisons is clear and does not mislead the recipient about the situation;
• Pre-existing policies, products, services and activities are not presented as new;
• Special attention is paid to communicating with disadvantaged individuals or groups identified within the target audience. Particular attention is paid to meeting the information needs of Aboriginal and Torres Strait Islander Australians, the rural community, people with disability and those for whom English is not a convenient language in which to receive information;
• Imagery used in campaigns appropriately reflects the diverse range of Australians. Where it is consistent with the campaign objectives, this includes the realistic portrayal of the full participation of women, Aboriginal and Torres Strait Islander Australians, culturally and linguistically diverse communities and people with disability; and
• Campaigns are tested with target audiences to indicate they are engaging and perform well against their objectives.

Principle 3: Objective and not directed at promoting party political interests

26. In demonstrating compliance with this Principle considerations include:

• Language used in the campaign is objective language and is free of political argument; and
• Campaigns must not try to foster a positive impression of a particular political party or promote party political interests.

27. Campaigns must not:

1. mention the party in Government by name;
2. directly attack or scorn the views, policies or actions of others such as the policies and opinions of opposition parties or groups;
3. include party political slogans or images;
4. be designed to influence public support for a political party, a candidate for election, a Minister or a Member of Parliament; or
5. refer or link to the web sites of politicians or political parties.

Principle 4: Justified and undertaken in an efficient, effective and relevant manner

28. In demonstrating compliance with this Principle considerations include:

• Campaigns are only instigated where a need is demonstrated, target recipients are clearly identified and the campaign is informed by appropriate research or evidence;
• Campaign information clearly and directly affect the interests of recipients;
• The medium and volume of the advertising activities is cost effective and justifiable within the budget allocated to the campaign;
• Distribution of unsolicited material should be carefully controlled; and
• Campaigns are evaluated to determine effectiveness.

Principle 5: Compliant with legal requirements and procurement policies and procedures

29. The manner of presentation and the delivery of campaigns must comply with all relevant laws including:

1. laws with respect to broadcasting and media;
2. privacy laws;
3. intellectual property laws;
4. electoral laws;
5. trade practices and consumer protection laws; and
6. workplace relations laws.

30. Procurement policies and procedures for the tendering and commissioning of services and the employment of suppliers are to be followed, and there must be a clear audit trail regarding decision making.