Report March 2025

Submitted

Ebiquity, listed on the London Stock Exchange (AIM:EBQ), is the world leader in media investment analysis. We harness the power of data to provide independent, fact-based advice, enabling brand owners to perfect media investment decisions and improve business outcomes. We are a data-driven solutions company helping brand owners drive efficiency and effectiveness from their media spend, eliminating wastage and creating value. We do not plan, buy, or sell media, but we enable our advertiser clients fact-based recommendations on how to make their media investments work better for them. Ebiquity is therefore able to provide independent, unbiased advice and solutions to brands because we have no commercial interest in any part of the media supply chain. With more than 600 media specialists, we have the largest pool of dedicated media professionals outside of the agency groups. We are physically present in 24 markets globally, representing ~80% of the world's media investments. This means that we are best placed to advise multinational brand owners, and our media analyses and reporting can cover more than 100 national markets. We provide media audit and evaluation services for 75 of the top 100 advertisers, with 500+ advertiser clients globally. Although headquartered in the UK Ebiquity has a local EU market office presence in Denmark, France, Germany, Italy, Portugal, Spain and Sweden, but provides services to clients across all EU markets. A number of our service offerings relevant to the digital media ecosystem are consistent and aligned with the objectives of the EU Code of Practice on Disinformation, and our support to advertiser clients in creating the effective and actionable monitoring, evaluation and reporting of media investments to those websites or media properties that are disseminating harmful content and disinformation is a natural extension of our capabilities. Our standard media governance digital audit applies a set of rules-based principles that structurally identify and quantify the opportunity for value improvement across five pillars of analysis; Supply chain inefficiencies, Transparency, Activation, Ad Quality, and Ad engagement. These evaluation criteria assess ad placements across programmatic, display, video, social and search media buys. Extending the rules-based principles to encompass those media properties involved in the propagation of disinformation would guard against advertiser funding of such sites.

Advertising

Commitment 1

Relevant signatories participating in ad placements commit to defund the dissemination of disinformation, and improve the policies and systems which determine the eligibility of content to be monetised, the controls for monetisation and ad placement, and the data to report on the accuracy and effectiveness of controls and services around ad placements.

We signed up to the following measures of this commitment

Measure 1.4

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 1.4

Relevant Signatories responsible for the buying of advertising, inclusive of advertisers, and agencies, will place advertising through ad sellers that have taken effective, and transparent steps to avoid the placement of advertising next to Disinformation content or in places that repeatedly publish Disinformation.

QRE 1.4.1

Relevant Signatories that are responsible for the buying of advertising will describe their processes and procedures to ensure they place advertising through ad sellers that take the steps described in Measure 1.4.

Although not directly involved in the planning, execution or placement of media, Ebiquity plays a key support role to advertisers in the audit, evaluation and recommendations for improvement in these transactions. The Responsible Media Investment evaluation puts in place a key governance procedure to filter all media buys by an advertiser for adherence to pre-determined principles of responsible investment (including disinformation) and identifies where non-compliance may be occurring and requiring remedial action.

Ebiquity is moving away from the Responsible Media Investment evaluation, and instead will include analysis of spend on Disinformation sites as an integral part of the Digital Media Governance solution, which is our core digital solution, servicing over 50 clients. This change will mean that all clients will be able to monitor and reduce their spending on Disinformation sites, without having to sign up to an additional service.

Commitment 3

Relevant Signatories involved in buying, selling and placing digital advertising commit to exchange best practices and strengthen cooperation with relevant players, expanding to organisations active in the online monetisation value chain, such as online e-payment services, e-commerce platforms and relevant crowd-funding/donation systems, with the aim to increase the effectiveness of scrutiny of ad placements on their own services.

We signed up to the following measures of this commitment

Measure 3.1 Measure 3.2 Measure 3.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 3.1

Relevant Signatories will cooperate with platforms, advertising supply chain players, source-rating services, services that provide indicators of trustworthiness, fact-checking organisations, advertisers and any other actors active in the online monetisation value chain, to facilitate the integration and flow of information, in particular information relevant for tackling purveyors of harmful Disinformation, in full respect of all relevant data protection rules and confidentiality agreements.

QRE 3.1.1

Signatories will outline how they work with others across industry and civil society to facilitate the flow of information that may be relevant for tackling purveyors of harmful Disinformation.

Ebiquity is in a unique position in the media ecosystem, as an independent and objective media specialist that advertisers trust to offer an impartial evaluation of their advertising investment. Since we do not plan, buy or sell media, nor have any controlling investment in our business by agencies, media owners or tech specialists, we can be affirmative as to facts and truth regarding media investments, without fear or favour.

Measure 3.2

Relevant Signatories will exchange among themselves information on Disinformation trends and TTPs (Tactics, Techniques, and Procedures), via the Code Task-force, GARM, IAB Europe, or other relevant fora. This will include sharing insights on new techniques or threats observed by Relevant Signatories, discussing case studies, and other means of improving capabilities and steps to help remove Disinformation across the advertising supply chain - potentially including real-time technical capabilities.

QRE 3.2.1

Signatories will report on their discussions within fora mentioned in Measure 3.2, being mindful of not disclosing information that is confidential and/or that may be used by malicious actors to circumvent the defences set by Signatories and others across the advertising supply chain. This could include, for instance, information about the fora Signatories engaged in; about the kinds of information they shared; and about the learnings they derived from these exchanges.

Ebiquity is dedicated to helping brands understand exactly where their digital ads are running, and thereby giving them the opportunity to eliminate waste and fund quality sites on the open internet. We have used results from our pioneering brands that have bought into our early Responsible Media solution to educate our other clients to the perils of Disinformation sites, and due to the demand that this has created, we are transitioning our Disinformation tracking into our core Digital Media Governance solution.

Measure 3.3

Relevant Signatories will integrate the work of or collaborate with relevant third-party organisations, such as independent source-rating services, services that provide indicators of trustworthiness, fact-checkers, researchers, or open-source investigators, in order to reduce monetisation of Disinformation and avoid the dissemination of advertising containing Disinformation.

QRE 3.3.1

Signatories will report on the collaborations and integrations relevant to their work with organisations mentioned.

Ebiquity works with the Global Disinformation Index and iffy.news to create a list of Disinformation sites to track our clients’ spend against. This list is kept up to date with regular refreshes and allows Ebiquity to inform brands of how much of their budgets is appearing on Disinformation sites and giving them the opportunity to reduce monetisiation of those sites.