Independence & Conflict Policy

I hold two regulatory advisory appointments: Chair of Ofcom's Advisory Committee for Scotland, and member of the ASA's Advertising Advisory Committee. I take the independence these roles require seriously, and I am open about how I manage it.

1. Independent Capacity All consulting work, articles and opinions are provided solely in my capacity as an independent consultant. They do not represent the views, policy or advice of Ofcom, the Advertising Standards Authority, or any other body with which I hold an appointment.

2. No Lobbying In line with the Codes of Conduct for my public appointments, I do not undertake lobbying, and I do not represent clients in their dealings with Ofcom or the ASA.

3. Conflict checks. Each engagement is checked at the outset against the Codes of Conduct for my appointments. I do not take on engagements that would create a conflict with either role, and some engagements are declined for this reason.

4. Ongoing advisory engagements. Ongoing retainer engagements are undertaken only with organisations that are not directly regulated by Ofcom under the Online Safety Act or by the ASA under the CAP and BCAP Codes.

5. No regulatory endorsement. My observations and advice are made in my private capacity as an independent expert. They do not constitute regulatory endorsement, comment, approval or pre-clearance by Ofcom or the ASA.

6. No Legal Advice My work is for strategic and assurance purposes and does not constitute legal advice. Organisations should seek their own legal advice on statutory compliance.

7. Jurisdiction Jess Digital is a trading name of Jess Ltd. These terms and any dispute or claim arising out of or in connection with them shall be governed by and construed in accordance with the law of Scotland. The courts of Scotland shall have exclusive jurisdiction to settle any dispute or claim.