Behind the Scenes with PromoVeritas: Q&A with Jeremy Stern

What do PromoVeritas do?

PromoVeritas literally means “truth in promotions.” We ensure everything is safe, legally compliant, and fair. We act on behalf of the brands to protect their reputation (so they don’t end up in the Daily Mail!) and also for the public so that you can trust the process. We run over 2,000 projects a year across 80 countries. A typical prize draw receives between 20,000 and 40,000 entries but it really depends on the communication, the ease of entry, and whether it’s advertised on TV.

How difficult is it to run competitions across different countries – are the laws very different?

Incredibly different! In the UK we are lucky; we have some of the easiest promotional laws in Europe and no tax on prizes for winners. In Italy, you have to go to the government weeks in advance for approval, a public official conducts the draw, unclaimed prizes must go to charity, and winners pay tax. In Greece, if we give away a €10,000 prize, we actually take the tax out first and pay the winner €9,000.

What kind of sales increase does a brand hope to see from an on-pack promotion?

I used to be the Promotions Director for Coca-Cola North West Europe. If we achieved a 0.5% to 1% increase in sales, we were applauded! For a billion-pound brand, that 1% increase could be £10 million. However, most brands don’t actually run promotions just to get your data or directly increase sales. They do it to buy favours with supermarket buyers. Running a massive competition gets them the “gondola ends” (prime promotional spaces at the end of aisles), and simply being in that space is what increases their sales.

Why are there strict entry limits on so many on-pack promotions? 

Entry limits are tied to health regulations. Brands are terrified of being accused of promoting unhealthy eating habits or childhood obesity by encouraging people to bulk-buy chocolate or crisps just to get a football or win a holiday! Also, with the new “less healthy food and drink” laws, chocolate and crisps can’t be placed within four metres of a shop entrance or till. To get around this, brands like Cadbury and Mars are now paying for their own massive branded display fixtures in the middle of the aisles, where they feature their prize promotions. 

Do brands only run promotions to collect email addresses?

Actually, having 100,000 pieces of your data is very annoying for a brand! If they start to do anything with it such as emailing, it costs them money, and most don’t have the budget for direct marketing. Our default is “less is more.” We don’t even ask for your gender or title on our forms. And legally, if you do get sent an email, there must be a working unsubscribe button.

Is there a secret “blacklist” of compers who break the rules?

Let me be clear: there is absolutely no ongoing “blacklist” of naughty people used across different promotions. We can’t act as judge and jury – you might have broken a rule on one promotion, but be totally genuine on the next. We judge every entry on its own merits.

How do you spot third party and fake entries?

We make a clear distinction between “compers” (who follow rules but enter in volume) and “scampers” (who use fake IDs, aliases, or enter for every member of their family). We use IP checkers, but we know they aren’t perfect because a whole office of 50 people could share one IP address. Instead, we treat it like a house alarm. If just one trigger goes off (like a shared IP), we don’t disqualify. But if two triggers go off – for example, we once had 373 entries coming from one tiny council estate in Hounslow! – that flags as suspicious. This is also why we use one-time text codes; to stop people using ten different phones to game the system.

What is the most ridiculous story of someone getting caught out?

We ran a Bacardi competition to win a trip to Cuba. We drew the winner, rang the number, asked to speak to Mary, and they put a three-year-old child on the phone! Mary’s grandmother had put down every member of the family to get extra entries, so we had to disqualify them. We also had a 16-year-old win a bicycle on an 18+ promo; we contacted his mother to make sure it was okay for him to receive it, but we were absolutely within our rights to disqualify him. Breaking T&Cs is technically obtaining goods by deception, which is fraud.

Why don’t promoters ask us to upload our receipts at the point of entry rather than asking for them after winning?

It’s down to budget again, as it can cost about 10p to process each receipt. When we do check receipts, we use OCR (Optical Character Recognition) technology. It scans the receipt for unique data points and assigns it a numerical score. If a receipt comes up with the exact same score later, it gets flagged as a duplicate for a human to check.

How do “Winning Moments” actually work? Are they completely random?

Unless the terms say otherwise, we generate the winning moments randomly across the entire promotional period. There might be no winners on Tuesday, and ten winners on Wednesday – but that’s randomness for you! But sometimes the terms will specify that there is one WM a day, in which it could be anywhere within the stated hours, usually 24 hours but sometimes 8am to 8pm or similar. We also use an “on or first after” mechanic. If no one enters at the exact winning moment, the prize remains available for the very first person who enters after that moment. We do not like schemes where the prize is only awarded if someone enters exactly on the WM – highly unlikely and mildly deceptive.

What happens to unclaimed prizes? 

If a prize goes unclaimed in the UK, it typically goes to a reserve winner. However, international laws are wild – for a Polaroid promo in Italy, we had to donate 1,000 phone cases to a local cat charity because of the law!

Why are there so many merchandise and ‘tat’ prizes – surely these don’t meet a brand’s sustainability targets?

Sometimes brands simply have stock in their warehouse they need to clear! At PromoVeritas we like to add a hand-signed letter from the brand when we send  the physical prizes, so even if you only won a t-shirt, you feel like a brand ambassador.

When you need to ‘seed’ a winning product for a ‘Golden Ticket’ style promotion, how do you decide where they go?

We look at the brand’s sales data. If Scotland buys 25% of all Cadbury Creme Eggs, then we will hide 25% of the winning eggs in Scotland. If Tesco sells 10% of the volume, they get 10% of the winners. For high-volume, low-value prizes (like dropping £5 notes into biscuit packs), we do it at the factory. But for high-value prizes, our team travels the country secretly placing them on shelves! My favourite was taking a cruise up the coast of Norway on the Hurtigruten ferry, hopping off at every port to secretly place winning chocolate bars in local shops.