Written evidence submitted by ITV plc
IMPACT OF COVID-19 ON ORGANISATIONS UNDER THE DDCMS REMIT
- The last few months have clearly been extraordinary ones in the history of the UK and of the world. Many old certainties have been upended by the crisis and there has been a very rapid transformation of everyone’s lives.
- Clearly these changes have been hugely disruptive in almost every dimension: socially, culturally, economically, and practically. For most people the changes brought about have been deeply unsettling and, in many cases, personally traumatic.
- ITV has done its utmost, as a Public Service Broadcaster and critical public service under the government’s classification, to support and inform people through the crisis. We have provided accurate news at the same time as misinformation has flourished online. We have brought the country together at a time of acute isolation. We have told stories and encouraged national conversations of a truly UK nature.
- But, even as consumption of our free-to- air TV content has grown and as people have sought out information and comfort in the crisis, we have also seen our revenue move in an opposite direction as advertising spend has fallen and TV production across the world has been put on hold. The crisis has hastened trends we have long observed with the likes of Google, Facebook and Amazon further strengthening their competitive position in advertising and other markets versus national players (like the UK PSBs).
- We set out in this submission the role ITV has played in the crisis and the steps we have taken to mitigate the impact on our business, as well as a few areas where decisive action is now needed by policymakers and regulators to maximise the chances of the UK TV industry and the broader creative economy across the UK flourishing over the coming few years.
HELPING PEOPLE THROUGH THE COVID-19 CRISIS: ITV AS A PSB
- We have set out in a parallel submission to the Committee’s Inquiry into the future of PSB the role ITV plays, as a PSB, in the life of the UK. ITV has a unique ability to reach the public at scale, with an avowed social purpose, creating distinctively British shows that reflect and shape the world we live in. In summary, the PSBs deliver a number of key elements of particular importance in the current circumstances:
- A gold standard of trusted, accurate and impartial national and local journalism amidst the anarchy of fake news, offering plurality at every level to the BBC and reaching different audiences.
- The production of unifying national moments in good and bad times, and a mirror held up to our society helping us to better understand our country and our fellow citizens.
- A reliable and trusted broadcast platform to ensure effective communication to the public at times of crisis.
- Real, meaningful investment in talent and production across the whole country, a crucial underpinning of the creative industries, particularly in northern England, not just in London and the south-east.
- The recent experience of the Covid-19 crisis has been clarifying. It has been the Public Service Broadcasters who have been in the lead in informing, entertaining and supporting the UK public with programmes and information reflecting the specific UK experience of the crisis. Such services with a UK specific focus are important for us as a nation in normal times, but crucial in a crisis. We believe that the past few months have illustrated, better than any submission, the role of public service broadcasting in the 21st Century.
- The public appears to agree with this. In recent research by Freeview, almost 8 in 10 people (79%) felt that it was important for them to have easy access to content delivered by the PSBs at times of national crisis (three quarters of those aged 16-34 agreed with that too). 80% of people in the same survey agreed that the PSBs kept them informed about what was going on in the UK again with three quarters of 16-34 year-olds agreeing. Nearly three quarters of the survey claimed they mostly relied on PSBs to give them free and easy access to news and information. This at a time when, as a recent Press Gazette investigation found:
“YouTube is broadcasting Covid-19 conspiracy theory videos to millions of people, and in some cases running adverts alongside them”
- Free-to-access public service broadcast television is part of our social fabric. 99% of people in TV-owning households watched ITV in 2019. 18 million viewers watched our main channel each day – on average nearly 37 million per week.
- In normal times we broadcast live to the nation each weekday between 6am and 2pm. Even during the Covid-19 crisis we have stayed live to the nation each morning informing and entertaining our viewers with content about the impact on Covid-19 on our lives with everything from a platform for Dr Hilary to answer viewers medical questions to Martin Lewis offering financial advice. But more than this, we’ve offered daily tips, from dance-alongs to stay-at-home gardening, ways to keep in touch to coping with anxiety, sharing stories and helping people to talk to their children about Covid.
- We’ve also brought the nation together with high quality drama and entertainment with everything from an innovative and well received Virtual Grand National to keeping Ant and Dec’s Saturday Night Takeaway on air as long as we could, attracting nearly 10m viewers to shows. This led the Daily Telegraph’s review of their show in late March to comment that “Ant and Dec aren’t quite Covid-19’s version of the former Forces sweetheart [Dame Vera Lynn] but they come pretty close”.
- In the midst of the Covid crisis we relaunched our Britain Get Talking campaign (“Apart. But never alone”) on air and on social media with huge impact. We’ve been supporting key workers through Clap for Carers, pausing our broadcasts for two minutes on a Thursday evening as well as though the One Million Claps campaign and ITV’s NHS Day which has raised well over £1m for NHS Charities Together. In addition, we’ve worked with Public Health England to deliver public health messaging campaigns on air targeting hard to reach groups – for instance our Stay at Home Lads campaign on ITV2. We also launched our ITVKidsCreate initiative that gave children in lockdown the opportunity to create idents for ITV with over 6,000 entries. As an illustration of the level of trust in ITV we’ve even had thousands of calls to our viewer services number seeking advice on Covid, which we have referred to the government website.
- It is also to broadcast news that audiences have turned in the current Covid crisis. In the weeks since the lockdown ITV News has reached 22.8m viewers each week – 38% of the TV population of the UK a significant increase on the first 11 weeks of the year. This increase has come from across the population, in the weeks since the lockdown ITV News has reached 2.8m people aged 16-34 a week, a 20% increase on the first 11 weeks. Nations and regions news in particular has been of particular importance. The feedback we have had on those programmes has suggested that an understanding of what is happening close to home has been a particular public priority, given the clarity and regularity of daily government briefings about the national position which are generally well covered. It was an ITV regional news programme that first interviewed Captain Sir Tom Moore on TV.
- Even before the audience spike caused by the crisis, the number of people watching our regional news programme at 6pm had increased by nearly 10% since 2015 and the number watching our national news programme at 6.30pm had grown by nearly 5%. This is instructive in a world where the assumption is that only online viewing is increasing.
- Or consider the set piece statements by the Prime Minister during the Covid-19 crisis which directly reached a large proportion of the UK population in one go across the different audiences of the PSBs. The PSBs are the natural home for such moments in our national life being free, universally accessible, reliable and highly trusted. It is very hard to see a plausible online alternative to broadcasts on digital terrestrial TV from the PSBs at critical national moments such as these for a long time to come.
ITV’S BUSINESS RESPONSE TO COVID
- Like many other businesses, ITV has had to respond decisively to the COVID-19 crisis on a variety of fronts, the most significant of which we set out below.
Safeguarding and protecting employees
- Clearly our top priority has been to ensure the safety, health and well-being of our employees and those who work with us on a freelance basis. From mid-March the overwhelming majority of our employees began working at home and still are. We rapidly put in place plans to ensure that our news and morning magazine programmes could remain on air safely with appropriate COVID production protocols, and to reschedule and revise that programming we continue to make and to broadcast it safely.
- In this context we were helped by the sensible approach of the government to the definition of key workers which included journalists and broadcasters engaged in work for the public service broadcasters. This removed one possible area of uncertainty in the early weeks of the crisis and made it possible for us to carry on with core elements of our work to keep the channels on air.
- However, in truth, most TV production stopped fairly rapidly as it became increasingly difficult for productions to operate safely in lockdown with no pre-planning or preparation where physical proximity had never before been an issue. Added to this were the legitimate concerns of employees for their own welfare at a time of considerable uncertainty and unease. This end to TV production was global, affecting all of ITV’s production businesses across the world.
- We have worked hard with our union partners and others in the industry to ensure as far as we could that the government’s schemes for furloughing employees and the self-employed were accessible to those who work for ITV. We were particularly active in ensuring that freelancers who we engage on PAYE were covered under the terms of the government’s schemes when at one point it appeared that they could fall through the cracks of different schemes. The government deserves praise for the scope and ambition of its furlough scheme and the speed with which it was rolled out.
Measures to protect ITV’s investment in the creative industries
- ITV is a massive investor in the UK creative economy, investing in UK content at a scale unmatched by commercial multichannel television channels or the SVODs. Ofcom figures show ITV invested over £750m in first run UK originations for its main channel alone in 2018, compared to under £500m for the entire multichannel sector. PACT figures show SVODs invested £328m.
- ITV’s investment is crucial to the success of our brilliant independent production sector. As public service broadcasters, we are obliged to commission 25% of our programming from independent producers. Independent producers also benefit from regulated terms of trade that ensure they can develop businesses based on the intellectual property they create. Pact figures show that the PSBs spent around £1.3bn with indie producers in 2018 vs £321m by the multichannel sector. Competitors like Netflix or Comcast-Sky are not obliged to do this. The fact that we are is one of the reasons the UK broadcasting ecosystem is so dynamic.
- In addition, as we set out later in this submission, ITV’s investment has helped create a genuine creative industries hub across the north of England, with major, permanent investments both by ITV but also the BBC and Channel 4 as part of their public service remit sustaining viable, well-paid and stimulating career paths in the regions.
- However, like many businesses, ITV has had to act quickly and decisively to ensure that we can ride out the current crisis and hit our stride effectively as restrictions begin to lift. Although we have not issued forward guidance about our business, we gave a sense of the early impact of Covid-19 in our Q1 trading statement on 6 May. This confirmed that:
a. Since mid-March ITV Studios has had to pause the majority of its productions globally as a result of the restrictions on working practices
b. There has been a significant impact on the demand for advertising across most advertising categories, particularly from April which was down 42% -- the largest fall in a single month ever
- No company could absorb the scale of the impact of the current crisis on the TV sector without responding decisively. TV is a high fixed cost business, so sudden drops in revenue have a significant and immediate impact. Accordingly, in response to the rapid change in market conditions, and in anticipation of further revenue disruption, we had to rapidly put in place a decisive plan to ensure that we reduced costs and managed cash flow and liquidity, including:
a. Reducing overhead costs by £60m in 2020
b. Reducing capital expenditure by £30m
c. At least a £100m reduction in the programme budget
d. Furloughing around 800 ITV colleagues, broadly 17% of our UK workforce the majority of whom were in ITV Studios.
e. Introducing a recruitment and salary freeze, reducing the pay of the Management Board and ITV PLC board as well as scrapping bonuses in 2020 for all employees.
f. Withdrawing the proposal to pay a dividend to shareholders in relation to the 2019 results.
- In addition to this, we have been working closely with our clients – both advertisers and programme commissioners -- to find ways to either continue to work together or to suspend business until the earliest point that we can both begin to operate properly again. Clearly the broad economic situation of the UK and the world is now challenging and therefore we need to continue to keep a close eye on costs to ensure that ITV can rapidly wind up activity as the economy starts to recover and as there is a gradual return to normality.
- ITV’s spend on TV content in normal times creates a very significant multiplier effect through the UK’s creative economy, supporting a significant infrastructure of on- and off-screen talent – from actors, to lighting and sound engineers from prop companies to TV directors. Clearly the ripple effects of the crisis across those groups will have been considerable. However, ITV’s most significant priority, through use of furloughing and “pausing” rather than cancelling productions has been to retain the skilled capacity in the creative industries for as long as we can in what we hope will only be a temporary interruption.
- In this context, in the midst of the crisis we announced the creation of a £500,000 development fund for independent producers to accelerate the search for new ideas and content for ITV for the latter part of 2020 and into 2021. Our objective is to continue to help to fund the TV industry’s equivalent of R&D even in a crisis so that we can emerge as rapidly and confidently as possible.
ITV’s role in leading a return to TV production
- In recent weeks, ITV has led the work in the UK TV industry to begin TV production again as the lockdown is eased. In particular, last month in partnership with UK’s leading broadcasters and producers, we published TV industry guidance for the safe resumption of production following a process of consultation with other stakeholders including the HSE, the Unions and the nations governments. We were pleased that the UK government endorsed the guidelines which have already made a significant contribution to restoring some of the confidence in the market and amongst our employees and freelancers to begin producing TV again. In this context, it has been a significant step forward to begin filming of our two continuing dramas Emmerdale and Coronation Street in recent days.
NEXT STEPS FOR GOVERNMENT: GETTING THE CREATIVE INDUSTRIES ACROSS THE WHOLE OF THE UK BACK IN BUSINESS
- However, the initial TV production guidance is merely the beginning rather than the end of the process of getting the TV industry and the broader creative industries back on their feet again.
- Clearly the current crisis will have a very serious impact on the UK creative economy in the short term. The really key challenge for everyone lies in trying to prevent this short-term impact from having serious longer-term repercussions. We believe that there are two key dimensions to this – measures to restore TV and film production rapidly and at scale, and measures to stimulate the economy and restore consumer confidence.
Further measures to help restore TV production at scale and pace
- ITV has production operations across Europe and is seeing different approaches to opening up production from which the UK can learn valuable lessons as we come out of lockdown. Perhaps the two most acute problems faced by TV (and most likely by many of the performing arts too) are:
- the necessarily close proximity of cast and crew but above all of on-screen talent to each other which is challenging in a world where social distancing is the norm.
- The risk to the future of a production if someone in either the cast or crew develops Covid-19 symptoms.
- One lesson we are starting to learn from other countries is that systematic testing of crew and on-screen talent may be a key part of the way in which both of these problems might be mitigated, albeit in the context of a wide range of other health and safety precautions on productions.
- However, the UK needs to move very quickly in this and the other areas set out below to ensure that our international rivals for production activity who are well advanced in their planning for a post Covid world in film and TV do not establish themselves as more attractive locations for filming than the UK. The government has brought the industry together in a working group chaired by the minister for media and data to work through the issues raised by restoring production which is very welcome but there is no time to lose.
- It has been very striking observing the Italian approach to the TV and film sector as lockdown has been lifted. In particular, our understanding is that regional governments have facilitated hospital and clinic-based access to testing for TV and films as part of broader engagement with the sector around the appropriate measures to ensure the restart of TV production. This has meant that everyone is tested (both swab test and blood test) before a production gets going (with results in 6 hours and 20 minutes respectively) with the on-screen cast tested each week. In the event of anyone exhibiting Covid-19 symptoms the facility exists for rapid testing across the entire on- and off-screen talent to screen out those who may be infected. As part of a broader set of measures, this proactive approach means that, if necessary, production can be interrupted relatively briefly rather than having to shut down for 14 days which would be very challenging economically and would offer relatively little difference in terms of risk. It has also meant in Italy (as part of broader precautions) that there is more scope, where strictly necessary, for closer interaction between cast members on set.
- It may be that such a hospital based solution is more challenging in the UK and we are conscious of the key priority of ensuring that those with clinical need have priority access to testing. However, as the lockdown gradually unwinds and we look to restore more economic activity at pace, we are very keen that the UK should try to maximise the potential which could be offered by reliable private sector testing alternatives. Such a set up, at scale, could give very rapid and reliable testing results to businesses such as TV and film producers with results back in a matter of hours. With such an approach in place, we would hope that effective testing could be used to isolate particular individuals rather than having to shut down whole productions or business units in the event of a further suspected outbreak that might not have spread beyond a single individual.
- There are three key things government could help with in this area:
- A rapid and systematic approach to endorsing or accrediting private sector providers for professionalism and reliability to maximise confidence in the system overall.
- A partnership between government and business to agree on what is reasonably practicable in terms of testing as we try to determine what degree of assurance particular levels of regular testing give us as part of broader precautionary measures. So, for instance, it would make sense that a rigorous testing regime could enable the isolation of those who have symptoms and have tested positive rather than shutting down whole productions comprising people who have tested negative.
- Clarity that particular approaches to risk management – for instance weekly testing as part of a broader risk management regime -- would be sufficient to give reassurance that proximity closer than 2 metres in a small and defined cohort (principally on screen talent) for short periods would be acceptable
- In this context, we are also concerned that in the absence of coherent guidance around testing regimes and relative risk that some players might be tempted to make their own rules up and it will be the responsible players who will pay the price in increased cost.
2 metre social distancing rule
- The requirement for people to remain 2 metres apart as a general rule is very challenging in the context of filming drama and for many performance activities in the arts more generally. There are possible work arounds including employing existing partners or cohabitees as lead actors but clearly these are very limiting and not a viable medium- or even short-term solution at scale. There remains considerable concern about what it is possible and safe to do on screen and on stage.
- In Italy, the comprehensive approach to testing (particularly for on-screen talent), in combination with other protective measures, has enabled the Italian authorities (and talent unions) to be comfortable with the idea that certain types of filming will require proximity closer than 2 metres and that this can be done safely. Clearly such proximity is being kept to a minimum and only where it is essential to the action but, as a general approach, it is both very clear but also a significant step forward from where the UK is today.
- As we emphasise above in the context of testing, there is a real need for the industry to work with government around testing and other mitigations to enable us to solve this problem of physical proximity if we are to resume drama production at scale for the long term.
- Under the current government guidance people are permitted to stay overnight at places other than where they live if it is reasonably necessary for work purposes. However, at the same time in the same regulation it is clear that the providers of any overnight accommodation – hotels etc – are not permitted to offer accommodation other than in very limited circumstances, primarily where someone works in one of the critical sectors. Whilst this means that people could stay overnight when working on programmes for ITV (as a PSB) they could not if working on a programme for Sky or Netflix. This will clearly be an impediment to production beginning across the whole market.
- It is a challenge for many producers to take the risk to return to TV production, particularly to high budget content such as drama, given the ever-present on-going risk of temporary shutdown for 14 days (or considerably longer in the event of a second societal shutdown because of a second wave of infection).
- The risk of further Covid (or even pandemic) business interruption is not something that producers can now insure against – there is a clear market failure. For this reason, a number of governments are, sensibly, looking at the possibility of establishing state backed insurance products (akin to PoolRe for terrorism insurance of FloodRe for flood protection) in relation to future pandemic insurance. We understand that discussions between the insurance industry and the government on this issue are underway which we are very supportive of.
- However, establishing any new insurance structure across the economy will take time and we are very concerned in the meantime that the scale and likelihood of risk in the short to medium term will make it very hard to restart substantial amounts of TV production, most particularly drama. Accordingly, we are very supportive of industry efforts to persuade government to guarantee TV production company losses in the short to medium term from further Covid related interruptions. In this context, we note that the government has recently underwritten trade credit insurance in order to help get money flowing around the economy again in circumstances where that insurance market had effectively failed too for understandable reasons.
- In this context, we would note that the Italian government has already put in place interim arrangements to help TV and film producers in this area. In particular, it has raised the production tax credit in Italy from 30-40% to help to compensate for the additional costs of ensuring safe working in TV production and to help to mitigate the cost of interruptions in filming. In addition, we understand that the Italian government has also guaranteed an 80% tax credit in circumstances where a production simply cannot continue as a result of a COVID-19 related interruption, enabling a TV producer to offset most of the abandoned costs to tax.
- Combined with the initiatives of the Italian government around testing, and in anticipation of other countries following suit, there may be an increasing risk that the UK is left behind as a venue for filming in the short to medium term unless we are able to develop our own initiatives to make filming here as straightforward as possible.
Stimulating the economy and restoring consumer confidence
- There is clearly a lot of thought going on across government into how to restore consumer confidence and to minimise the harm caused by Covid-19 to the economy. Put simply, given that consumer spending is around 70% of the economy, consumer confidence is a crucial element giving advertisers the confidence to spend, thus enabling broadcasters to have the confidence to increase investment in programming to reverse the current vicious circle.
- Clearly there is a separate submission that could be written about the policy levers that government could pull in these circumstances. However, we thought it might be most useful to put to the committee some thoughts about the types of fiscal incentives that we believe could have a positive economic effect for TV and the creative sectors that feed into TV but also more broadly for the wider economy.
Advertising tax credit
- There is a case for a short-term and targeted tax credit for advertising across media from August through the autumn and winter. The very simple idea would be to try to encourage advertisers to begin to advertise again (and for others to advertise more) and for consumers to then begin to perceive a return to greater normality, encouraging them to begin to spend money and grow in confidence.
- We are particularly concerned that many companies (like consumers) are likely to be very cautious indeed in the early days coming out of lockdown, seeking to conserve cash against future risks to their businesses. Such an (understandable) approach across the board will significantly depress demand across the economy. We know that advertising helps to underwrite competition in the economy and competition in turn drives innovation and productivity gain so there are powerful general arguments in favour of a rapid kick start of the advertising market. Quite apart from this, marketing and advertising is a significant sector in the economy and has a very significant direct multiplier effect as it feeds through media and numerous other marketing channels.
- We believe that such a targeted tax credit, as part of the broader opening up of the economy, could help to unlock more economic activity across the economy very broadly, paying for itself in increased tax receipts and helping to support media such as TV, newspapers, radio and magazines which have experienced very sharp revenue declines in the current crisis.
Regional production tax credit
- The UK has been very successful in attracting inward investment into our screen sector, reflecting the deep pool of talent, attractive tax incentives and full access to the EU market amongst other things. Netflix themselves have acknowledged that the depth and quality of the on- and off-screen skills base nurtured and maintained by the PSBs was one of the key factors in their decisions to invest at scale in the UK. We welcome this inward investment and we have been successful in making programmes for the new entrants.
- But look closely and you see that investment is concentrated overwhelmingly in London and the south east of England – the area with the biggest and deepest pool of skilled on and off screen labour and the greatest travel connectivity. Netflix has recently made a major commitment to Shepperton, Comcast-Sky to production at Elstree and major new film and TV studios have been announced in Ashford, Kent with interest from both Netflix and Amazon. All are in the Home Counties. This is good for the UK economy, but these investments help to solidify the existing bias in the UK creative industries to London and the south east. By contrast, the studio operator Pinewood withdrew from its Pinewood Studio Wales in March after 5 years despite the nearly £10m that had been spent by the Welsh government on buying and fitting out the studio building they were operating in.
- The public service broadcasters, by contrast, have acted differently. In ITV’s case 35% of our spend on programmes and of our broadcast hours must be made up of programmes made outside the M25. As a result, ITV is a major investor in regional creative economies. Nearly half of our UK employees are based outside London, with an extensive network of offices across the UK. We spend £300 million each year on programme making outside London – the same as the entire multichannel sector and PSB portfolio channels put together). That sustains big operations in Cardiff, Leeds and MediaCityUK in Salford and Trafford – enriching the economic lifeblood of those cities.
- However, there are real costs in seeking to buck the powerful market dynamic towards the South East of England in this way and capacity constraints which reflect the limited demand compared to the South East of England. More fundamentally, in an economic environment in which revenue in the PSB system may be reduced in the coming years there is an increasing need to look at market wide tax incentives to encourage TV production to locate permanently outside of London.
- The introduction of fiscal incentives to produce TV outside of London and the South East should include but also extend well beyond the PSBs, though initially at least it would help the PSBs to sustain (and even increase) their regional investment in what will be very challenging years to come. Such a market wide approach to incentivising production to move could ultimately become self sustaining if it enabled the development of sufficiently deep skills bases outside of the South East. The ready made Ofcom guidance on “out of London production” could be used to define which productions would quality for tax relief.
Moving rapidly to safeguard the future of the UK PSB system
- Public Service Broadcasting has proved itself to be a cornerstone of a national broadcasting system and creative industries across the UK. But for future generations of viewers to go on enjoying the benefits offered by the PSBs, we need big changes in how the British broadcasting sector is regulated.
- There is now a serious risk that the rapid globalisation of TV production and distribution leaves us, potentially quite rapidly, with mainly global TV services and platforms in the UK, marginalising and undermining national content and services, embodied in the UK in the PSB system. We need both the national and the global to flourish in the UK but that is not the likely market outcome absent intervention.
- It is within the power of the UK government and parliament to safeguard a balance between national PSB and global TV offers in this new world. But as the UK begins discussions around a trade deal with the US, we need to make sure that, as a country, we safeguard our ability to continue to exercise that discretion in different ways as the world changes in the years to come.
- To put it starkly, absent significant reform to the PSB regime, we will gradually see failures in a range of PSB outcomes – diminishing investment in original UK focussed content available universally for free, less focus on sustaining free, mass reach accurate news, stagnating long term investment in the UK’s regional creative economies and decreasing support for independent producers. Furthermore, we will continue to see value flow out of the UK economy into the hands of US technology and platform companies. By contrast, although we have substantial operations outside the UK too, ITV is a UK company, based in the UK, listed on the Stock Exchange here and paying substantial tax in the UK.
- We will explore these two key themes – that public service broadcasting in the UK has a key role and an exciting future; and that we must act now to guarantee that bright future - in more depth in our submission to the Committee’s PSB Inquiry. However, the COVID-19 crisis has increased the urgency for action through its impact on the economics of the commercial PSBs and by accelerating the pace of change in the market and the growth of global TV platforms and streaming services.
- We would urge government and Ofcom to be bold but to work at pace to help to safeguard the benefits that the PSB system creates for all citizens and consumers in the UK wherever they live.
 https://www.smallscreenbigdebate.co.uk/what-is-ssbd/ssbd-five-year-review (mulitchannel figure excludes spend on sport)