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Does Centre’s advisory give long rope to surrogate ads?

ASCI code defines the qualification criteria for brand extensions, which are permitted under the law, versus surrogate advertising that is prohibited under the law, ASCI CEO Manisha Kapoor told e4m

e4m by Kanchan Srivastava
Published: Sep 6, 2022 8:19 AM  | 6 min read
Surroagte ads

The Department of Consumer Affairs, Ministry of Consumer Affairs, Food & Public Distribution recently directed advertising bodies to ensure strict compliance of guidelines for prevention of “misleading advertisement” and “surrogate advertisements”.

The direction was given to Advertising Association of India, Indian Broadcasting Foundation, Broadcasting Content Complaints Council, News Broadcasters and Digital Association, Advertising Standards Council of India (ASCI), PHD Chamber of Commerce and Industry, Federation of Indian Chambers of Commerce and Industry, Confederation of Indian Industry, ASSOCHAM, International Spirits & Wines Association of India, and Indian Society of Advertisers.

Asked if the latest directions will bring a difference to the advertising universe, veteran adman and MD of Rediffusion Dr Sandeep Goyal said, “This is just blowing hot and cold. For the past 5 years, I waged a lonely battle against surrogate advertising against ASCI. I tagged every possible governmental authority - to no avail.”

“The government has become more active and vigilant in the past months. But till some brands, their owners, their ad agencies and their celebrity endorsers are taking visible action against, this malaise will continue,” Goyal added.

Manisha Kapoor, CEO & Secretary General, ASCI, cites ambiguity in the central law as the prime reason behind such violations.

“In the last 3 years, ASCI has processed 36 ads of liquor brand extensions, of which 31 ads were found to be violative, and the advertisers withdrew/ modified the ads. The ASCI code very clearly defines the qualification criteria for brand extensions which are permitted under the law, versus surrogate advertising which is prohibited under the law,” Kapoor told e4m.

She further explained, “The MIB advisory to Television networks on Surrogate advertising, dated 15 September, 2020 says-Rule 7(2)(vih)(A) of Advertising Code enshrined under Cable Television Networks (CTN) Rules, 1994 prohibits direct or indirect advertisements of cigarettes, tobacco products, wine, alcohol, liquor or other intoxicants. However, advertisements of genuine products sharing brand name or logo of such products are permissible subject to specified conditions prescribed therein. The rule thus aims at prohibiting surrogate advertisements while at the same time allowing advertisements of genuine brand extensions subject to specified conditions.”  

TV ads cleared by CBFC

The Advertising Code of the CTN rules requires advertising to comply with ASCI guidelines, Kapoor pointed out. All brand extension ads on TV channels are to be pre-cleared for telecast by CBFC, after confirming compliance with the guidelines, which were jointly developed by MIB, CBFC and ASCI, she further noted.

“In addition, noting direct advertising of alcohol brands on social media, ASCI also drew the attention of the Department of Consumer Affairs to this phenomenon for necessary action. ASCI’s guidelines and actions are therefore consistent with the provisions of the law, and we urge advertisers, media owners and creators to be mindful of these.”

She insists that clear criteria that qualify a genuine brand extension are also laid out in the ASCI code as below:

  1. Brand extension product or service should be registered with appropriate Government authority e.g., GST/FDA/FSSAI/TM etc.
  2. A) For a brand that is present in the market for >2 years, the following criteria would apply
  3. Sales turnover of the product or service should exceed Rs. 5 crore per annum nationally, or Rs 1 crore per annum per state, where distribution has been established.
  4. A valid certificate from an independent organisation such as NielsenIQ or category - specific industry association, or an independent and reputed CA firm would be required to prove the concerned criteria.
  5. B) Brand extensions which have been launched in the market, but have not yet completed two years must meet any one of the following criteria:
  6. Achieve a net sales turnover of Rs 20 lakh per month from launch. Such sales should not be to a subsidiary or sister concern.
  7. Demonstrate fixed asset investments which are exclusive to the advertised brand extension of not less than Rs 10 crore. Such assets could be land, machines, factories, software, etc., in case the product is being manufactured/ developed by the advertiser. No advertising related expense should be part of such investments.

III.  In case the manufacturing/procurement of such brand extensions is being outsourced, then evidence may include board resolutions and purchase orders for long term (> 1 year) contracts with service providers/manufacturing entities, stating their capacities, and contracted volumes/Rupee value, which clearly demonstrate the possibility of achieving the turnover as laid out in criteria 2B (I).

  1. Give evidence of turnover greater than 10% of the turnover of the same brand in the restricted category (including sub brands in the restricted category).

*All the above evidence should be certified by a reputed and independent CA firm.

“Irrespective of the length of time the brand has been in the market, the date of launch would be considered as the date of the first invoice for sale for the said brand extension. If a brand extension cannot meet the qualification criteria, for the purpose of the ASCI code it would not be considered a genuine brand extension, but rather a surrogate created to advertise a restricted category,” Kapoor said.

Rules can be challenged

Surrogate advertising has always been seen as a hidden opportunity to get closer to the audience by owning an emotive zone that is unique to the brand voice and identity. It is celebrated in creative brainstorming rooms as ‘take that’ rather than an ‘oh no’, says Amrita Dey, Group Creative Director at 4AM Worldwide.

“There is a constant sparring between the ban lobby consisting of government, NGOs and various vocal individuals on one side, and the pro lobby consisting of free spirits (pun unintended) on the other side. Government slaps fines that are ignored, often because the rules are unclear and can be challenged. For example, it is still unclear if liquor companies can advertise drinking water and soda or not,” Dey contended.

“Ischemic heart diseases and stroke have been identified as the leading causes of death in lower middle-income countries. But we do not see governments banning use of foods and beverages that contain high salt, sugar and unhealthy fats. It is left to the consumer’s sensibilities to control and monitor their consumption. The ban against alcohol and tobacco advertising then appears to be more socio political/ cultural presented in the context of healthcare. The companies in that case have no option but to resort to surrogate ads. And the users have no choice but to hide and consume or rebel against this rhetoric,” she points out.

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Uber & Dentsu Creative India show the reality behind wedding reels

The campaign encourages soon-to-wed couples to take a Rental Health Day together

By exchange4media Staff | Dec 7, 2022 12:11 PM   |   2 min read

Uber Rentals

Uber Rentals in association with Dentsu Creative India has launched its latest campaign for the wedding season, shedding light on the days leading up to the big day. The brand introduced the world to #RentalHealthDay earlier this year with a mockumentary starring Anil Kapoor.

The brand has partnered with two couples whose wedding plans are always the talk of the town - Jasmin Bhasin & Aly Goni and Krishna Mukherjee & Chirag Batliwalla. Starring in their respective films, these reality-packed reels show the couples adding booking an Uber Rentals to their to-do list, so that “shaadi ke chakkar mein city ke jitney chakkar lagein” they don’t have to worry about driving or parking. It is pertinent to note here that both films have been received with a lot of delight and positivity from fans of the two couples, who love the real chemistry between the couples on reel.



wedding reelsTalking about the campaign, Ameya Velankar, Head of Marketing, Uber India and South Asia said, “In our quest to consistently reimagine the way the world moves, we turned our attention to the wedding season. With Uber Rentals as their partner, a bride & groom can avail absolute convenience and the peace of mind that they rightfully deserve. One car for up to 12 hours and the option to add multiple stops on the go - saving them the effort of finding parking spaces or multiple trips. Our films capture the heart-warming moments and fun that couples can unlock when they aren’t hassled by the perils of city driving.”

Ankit Mathur, Creative Director, Dentsu Creative India added, “Year after year, wedding-themed ads on TV and social media show couples looking like they’ve just returned from a vacation when in reality they are exhausted and perhaps even tired of each other! We looked at #RentalHealthDay being a solution for those who can take driving off their to-do list and an opportunity for couples to make the most of their free time - like pestering one another.”

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In 2023, we’ll see more advertisers recognise the value of OTT: Gavin Buxton, Magnite

The Managing Director-Asia of Magnite spoke to e4m about rising consumption of AVOD, the potential of connected TV and more

By Kanchan Srivastava | Dec 6, 2022 8:15 AM   |   7 min read

Buxton

Gavin Buxton, Managing Director, Asia, Magnite, was in India recently to launch a report by the company on OTT trends - ‘India Embraces The Streaming Era’. In a chat with e4m on the sidelines of the launch, Buxton shared his insights on the reasons behind the rising consumption of AVOD, the difference between India and other Asian markets, and the emerging OTT trends that could be the highlight of 2023.

Excerpts:

Your report suggests that OTT audiences have embraced ad-supported content although most of them have shifted from TV to OTT primarily because the latter was ad-free. Is this due to concerns over economic conditions or a behavioural change? 

Audiences are gravitating toward OTT for many reasons, one among them being that consumers enjoy the flexibility and control that streaming provides. According to our report, 66% of consumers prefer to watch streaming over traditional TV, and 75% of streamers are streaming more now than a year ago, with key reasons being greater access to original programming, favourite shows, higher quality content as well as the choice to watch locally produced or international content.

According to our report, 80% prefer to watch ad-supported content rather than pay for an ad-free experience and 73% of streamers are happy to see ads in return for quality programming.

Among streamers in India, the disposition to ad-supported streaming is strong, with free or some ad-supported content preferred by 4 in 5 streamers rather than paying for an ad-free experience (1 in 5).

There is also a clear acceptance of ads by viewers in exchange for quality content, with streamers happy to view up to 8.3 minutes of advertising per hour on paid platforms and 10.7 minutes on free streaming platforms.

As we move towards a more evolved ecosystem, what trends are you expecting in the digital advertising space in 2023? 

OTT adoption has grown rapidly throughout India, with AVOD in particular now actively watched by linear TV and UGC audiences across all demographics. With viewers drawn to its convenience and variety of premium content, OTT promises to continue its upward growth trajectory. In the coming year, I believe we’ll see more advertisers recognizing the value of OTT, and including it in their TV-based media plans as they look to most effectively reach the right audiences and achieve key marketing objectives.

In addition, as we see major global players roll out advertising solutions and/or ad-supported tiers in the coming year, I believe the AVOD model is the way forward and will be increasingly embraced by more content owners.

This shift will bring an increased supply/inventory to the market. The increase in demand for streaming inventory will push more supply out of walled gardens and into the open programmatic ecosystem.

We also expect to see the continued scaling of viewers consuming CTV ‘big screen’ content as more people replace their TVs with smart TVs or through new set-top boxes.

Live streaming will continue to increase as the audience will prefer watching shows that matter to them, and broadcasters will start to activate digital replacement of ads, which will further scale streaming ad opportunities.

How different is the Indian digital advertising space compared to other Asian markets such as China? 

The Indian digital advertising market is one of the fastest growing in the world and the second largest in Asia, due in part to a large middle class that is growing exponentially every year. Ad tech is well positioned for continued rapid growth here, with Magna Global predicting the ad industry will grow 15% by year’s end. Greater accessibility to increasingly affordable streaming devices and cost-effective home broadband plans will only accelerate this growth going forward. As consumers spend more time on OTT devices, ad dollars will continue to follow, further propelling the industry forward.

India is similar to other Asia markets in having a high proportion of viewers watching on their mobile phones, with 88% using their mobile to stream based on our research. The number and variety of streaming platforms for viewers to choose from in India is more than in other Asia markets, which is generally due to the size of the market and the breadth of languages spoken. 

There has been a massive shift from linear TV towards CTV. What opportunities does this disruption offer to advertisers? 

CTV offers greater opportunities to reach audiences. Viewers on streaming platforms are more engaged and more receptive to advertising than those on traditional TV, as evidenced by our latest research study.

Audiences gravitate toward CTV because of the high-quality programming, the lighter ad load, and the prospect of discovering new, exclusive content. This high engagement with the content results in more attentive viewing to both the programming and the advertising.

The full-screen, non-skippable environment of streaming (across mobile and big screen) inherently results in high viewability and high completion rates. It also helps advertisers extend reach, especially among audiences who watch little traditional TV and are difficult to reach and this enables customised creative opportunities.

Which category of brands dominates the CTV space?

Brands across all industries can benefit from advertising on CTV. With CTV, brands are not only buying based on content—they’re buying based on addressable audiences.

Powered by programmatic technology, buyers can reach audiences with precision, and one-to-one targeting across demographics. CTV technology goes beyond linear TV’s index-powered buying, leveraging audience, geographic, contextual, and behavioural data to drive campaign performance.

As audiences flock to streamers, buyers should be adding and ramping up CTV within their media mix. With media companies and advertisers seeing the benefit on bottom lines, they’re seeing CTV for what it truly is: high-performance television with holding power.

Ad waste and fraud are quite common in CTV due to multiple layers of streaming. What should an advertiser do? And what are you as a platform doing to bring measurement protocol? 

Because standards and thresholds vary for measurement vendors, our approach is to work with individual buyers to demonstrate how our inventory can meet their specific needs. This includes the creation of curated private marketplaces.

We enforce baseline content standards across all our publishers, ingesting and honouring the site blocklists advertisers pass to us through their buying platforms, and providing complete transparency on where their campaigns run. In this way, ultimate control rests in the advertiser’s hands.

With our long history and team committed to marketplace quality and brand safety, our exchange gives buyers the ability to transact confidently on high-quality, high-reach inventory.

What ad tech tools are currently being utilized by publishers to target the audience?

Streaming combines the best of linear and digital, offering marketers a high-quality, long-form television environment, plus the precision of digital media. Streaming marketers can reach curated audiences en masse by leveraging first and third-party data. Video streaming captures the holy grail of marketing: timely, personalized messaging to coveted consumers without compromising scale.

As the third-party cookie will soon be deprecated, audience creation is moving from the buy-side to the sell-side, which directly owns the relationship with consumers. Though this shift is new for many publishers, seller first-party data has long been key to addressability in CTV/OTT. While Magnite will continue to support industry IDs such as UID 2.0, a range of identity signals must be used to make as much inventory addressable as possible.

This year, we acquired Carbon, a company with unique tools and expertise to help publishers drive revenue with their first-party audience data, and Nth Party, a start-up developing cryptographic software for secure audience data sharing and analysis. This will help grow Magnite’s audience and identity capabilities and accelerate their integration across our omnichannel offerings. These acquisitions will accelerate our ability to bring audience creation tools and our audience marketplace to the world’s largest publishers and advertisers.

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India's ad revenue to grow 16.8 per cent in 2023: GroupM report

According to the This Year Next Year 2022 Global End of Year Forecast, the ad revenue growth in 2022 will be 15.8 per cent

By exchange4media Staff | Dec 5, 2022 5:39 PM   |   2 min read

GroupM report

GroupM has released its This Year Next Year 2022 Global End of Year Forecast. According to the report, India’s advertising revenue growth forecast for 2022 is 15.8%, with that figure further accelerating to 16.8% in 2023.

“This growth is led by pure-play digital advertising, which accounts for the largest share (48.8%) in 2022 and is expected to continue rising above pre-pandemic levels. Retail media in India is forecast at $551 million in 2022 and is expected to nearly double by 2027,” states the report.

“TV advertising, representing 36% of advertising market share, is expected to grow 10.8% this year and continue growing double digits, driven by strong growth in both traditional and connected TV,” it adds.

On the global numbers, the report states, “we now expect global advertising to grow 5.9% in 2023, behind the IMF’s expectation for global inflation of 6.5% and a downgrade from our 6.4% June estimate. Retail media, one of the fastest growing segments of the advertising industry, is now estimated to reach $110.7 billion dollars in 2022, an upgrade from our September forecast of $101 billion.”

“Television continues its recovery to pre-pandemic levels, albeit more slowly in 2022, with an expected global growth rate of 1.7% (excluding U.S. political advertising). Growth in global OOH this year will amount to 2.2% globally (excluding U.S. political spending), or 18.1% on an excluding-China basis. Audio is projected to grow 3.8% globally in 2022 (excluding U.S. political advertising) and decelerate to 1.3% growth in 2023,” it states further.

“After a brief respite in 2021, traditional print continues its decline of 7.4% in 2022. Print-based media will decline by 3.7% when including digital extensions, which are forecast to make up nearly half of total revenue this year and more than three-quarters of revenue by 2026,” mentioned the report.

 

 

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Tata Soulfull promises a “BetterForYou” Breakfast with its new ad

The multi-media digital campaign has been created and executed by Wondrlab

By exchange4media Staff | Dec 5, 2022 3:54 PM   |   2 min read

Tata Soulfull

Tata Soulfull has launched its first ever digital campaign for the product line, Tata Soulfull Millet Muesli with a new tagline, ‘Better Crunch, Wholesome Munch’.

The 30-second film has a lively, banter style of dialogue. It shows a young health-conscious couple having a playful conversation about their breakfast choice. The advertisement transforms the functional representation of muesli into a quirkier and more interesting rendition that the audience can resonate with. It adopts a completely fresh strategy for millet marketing while concentrating on its target consumers who are seeking better choices in line with their aspirations.

The launch of the campaign also aligns with the UN’s International Year of Millets 2023 which places an emphasis on healthy food choices and snacking. The company is making consistent efforts to make millets part of everyone's diet by constantly innovating and offering consumers a variety of tasty, nutritious, convenient, and modern formats of millet-based products.

Speaking on the launch of the campaign, Prashant Parameswaran, MD & CEO, Tata Soulfull, shared, "Product innovation with health benefits at the core is the driving force of all our Tata Soulfull’s offerings. With the increased millet quotient in the Fruit & Nut variant of Millet Muesli, our mission is to focus on delivering high-quality, wholesome millet-based products in tasty formats to our consumers. People love our millet muesli for its taste and crunchiness and 25% millets-version is a source of protein and is a high fibre breakfast option. Tata Soulfull is at the forefront of reviving the consumption of Indian millets through more distinctive and accessible formats, making them a crunchier go-to option for consumers seeking delicious taste in nutritious products they seek for their healthy lifestyle.”

“We have a strong millet-based product pipeline, which we will continue to build in line with the United Nations' announcement of the International Year of Millets 2023.”, he further added.

The multi-media digital campaign has been created and executed by Wondrlab. Amit Akali, CCO and Co-founder, Wondrlab, added, “Muesli is the default breakfast of choice for younger, affluent lifestyles. So, we set the film amongst one such couple and integrated the product into their relationship and everyday life. The other task we put on ourselves was to do justice to an amazing product.  The difference between Tata Soulful Millet Muesli and ordinary Muesli is actually visible, be it the wholegrains or fruits. Therefore, we focused on visually bringing this difference alive, through beautiful product shots.”

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Apple's new ad is a powerful tribute to users with disabilities

The spot highlights Apple's accessibility features, which can help people with disabilities navigate the world with ease

By exchange4media Staff | Dec 2, 2022 7:27 PM   |   2 min read

apple ad

The term "empowering" has been so often these days that the word has lost its sheen. Yet, no other adjective is half as befitting when it comes to describing the new Apple accessibility ad. Ahead of International Day of Disabled Persons 2022, the tech giant has launched its latest ad titled "The Greatest."

It's a powerful tribute to people who navigate through everyday life in a world designed for their able-bodied counterparts. They do so fearlessly with a little help from Apple's accessibility features on products like iPhone, Apple Watch and Mac.

According to Neilsen's research on 4,50,000 primetime ads, there is no representation of disability unless the product is meant for the disabled. A dismal 1% of ads have adequate representation of disability-related themes.

Media can play a large role in promoting inclusivity by normalising disabilities and changing the narratives around them. Big companies like Apple can drive this change by depicting people with disabilities in an empowering way and not in a sympathetic light.


The ad film hinges on the idea that accessibility is for everyone and shouldn't be limited at any cost. The tech company has released to commemorate the 30th year of International Day of Persons with Disabilities, which falls on December 3.

"At Apple, we believe accessibility is a human right. Innovative features like Door Detection, Sound Recognition, Voice Control and more are designed to let you use your devices in ways that work best for you," says the video description.

The 2:21 minute video showcases everyday instances of people with disabilities of visual, physical, hearing and cognitive nature empowered by Apple accessibility features.

The video is filled with inspiring moments: a woman with no arms wakes up in the morning with instructions for Siri, who helps her open the blinds; A wheelchair-bound man uses voice instructions to click his pictures; A deaf mother knows her child is crying with the help of the Apple watch that alerts her; Another woman uses her legs to operate her phone and to browse the web; A blind man locates his red jacket by moving his iPhone camera around the room. 

The spot steers clear of any mawkish tropes to inspire pity for its subjects. Instead, it shows the many ways in which people with disability lead fulfilling lives, doing things that excite them.

Apple's in-house team has crafted the ad. The video is set to a foot-tapping number by Spinifex Gum titled "I am the greatest." It has vocals by Marliya Choir.

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For those who take their sleep seriously, says campaign for Duroflex Wave Plus

The campaign comprises three digital films

By exchange4media Staff | Dec 3, 2022 8:44 AM   |   2 min read

duroflex

Duroflex has launched Duroflex Wave Plus, an adjustable bed.

To promote the new offering, the company has rolled out three digital films in which they have chosen the true connoisseurs of sleep – the pets.

“Both dogs and cats love to sleep and are often called masters of sleep. The key digital film humorously captures the cat, Fluffy, trying to find the perfect space to sleep around the house while the dog, narrates the entire experience of the cat’s quest. From the laptop, to the carpet, to the top of the washing machine, Fluffy is unsatisfied till the dog takes Fluffy to Duroflex Wave. Here Fluffy’s search for the perfect sleeping space come to an end. The film aptly ends with the line that communicate how Duroflex Wave Plus is the answer to all those who value sleep, ‘Designed for those who take their sleep seriously.’

In the second digital film, the duo are shown being impressed by the Zero Gravity feature of the smart bed where their master is sleeping peacefully after adjusting the bed as per his comfort level. The third film highlights the Anti-Snore mode feature of Duroflex Wave Plus.

Commenting on the new launch, Mohanraj J, Chief Executive Officer, Duroflex said, “We are happy to introduce Duroflex Wave Plus, a product which offers a truly enriching sleep experience. As a brand, we are continually pursuing sleep technologies that will help India sleep better. After introducing research-backed mattresses, we decided it was time to introduce products that will further upgrade the sleep and comfort experience of the people. Our latest offering, Duroflex Wave Plus – adjustable smart bed will help consumers recline into different positions and angles to suit their needs, providing them ultimate comfort and support in whichever position they choose to lie on the bed for - sleeping, sitting or just relax and unwind.”

Talking about the campaign, Paul Dueman, Chief Business Officer, Vector Brand Solutions, said, “The Duroflex Wave sleep system heralds the future of sleep solutions.  The team approached this campaign with the clear understanding that the Wave sleep solution, is the first of its kind and therefore the campaign needed to be delivered in a manner that was also a first of its kind narrative for the category. I am very happy with the output and confident the campaign will deliver on both brand and business objectives.”

 

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Find the job that is perfect for you, says Monster as it rebrands as FoundIt

The campaign is designed by Wunderman Thompson Bangalore

By exchange4media Staff | Dec 3, 2022 2:00 PM   |   3 min read

monster

Monster India, in collaboration with Wunderman Thompson Bangalore, has launched a rebranding exercise and its new campaign. The campaign tells the story from the perspective of a new generation of job seekers. A generation that knows exactly what they are seeking and do not shy away from demanding what they want.

 

“In their earlier avatar, Monster has been connecting people with the right job opportunities for over two decades. Equipped with invaluable experience that provided rare insight into what people sought and what made them quit, Monster changed to FoundIt. As the new name suggests, FoundIt brings an optimistic energy to the entire job search process that is otherwise a stressful experience for both job seekers and recruiters,” the company said.

 

The campaign was strategically kickstarted on LinkedIn with a huge number of senior Monster India employees shaking things up by posting intriguing resignation posts on their profiles with #changeisgood. As this built buzz on the platform, three teaser films were shared on social media showing different professionals quitting their job in an unusual and fun style. The films ended with a common message thread, “Find the job that’s perfect for you” and gave a hint of the new branding towards the end of the films.

 

This was shortly followed up by the launch and reveal of the brand name. It was done again through multiple platforms, LinkedIn, SM handles as well as their website. The senior management broke the news of rebranding through their LinkedIn handles while the launch film showed a movement like scenario, with a culmination of many empowered professionals walking out of their jobs to find something better - FoundIt.

 

Talking about the campaign, Senior National Creative Director, Wunderman Thompson, Priya Shivakumar, commented, “We've all been hearing of layoffs across many organisations and it has been making news across media, social conversations and forums. What better time then, to balance things a bit and launch Monster's new identity with an audacious campaign that creates intrigue around people quitting. What starts off as a surprise spree of resignations by the Senior Management, is amplified through PR and communication as they sign off from Monster to finally reveal the name of the new entity. "FoundIt" as the portal is called, starts the way it means to go on, as a platform that will empower the employee and employer both, by bridging the gap between skills and requirements. The job scenario needed a new way of doing things and FoundIt is not only the new name but a new approach to recruiting.”

 

The new branding retains, the brand colours while bringing a contemporary and vibrant twist to it.

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