Speaking at the Westminster Health Forum seminar on alcohol and responsibility, Kate Blakeley said: "The current model of reliance on an entirely voluntary code is not necessarily working. The Portman Group code is for producers, and I think there is an opportunity to extend this further.
"We believe there is a case for the government and the industry to work together to identify appropriate standards for promotional activity in the on and off-trades."
Blakeley said the proposal would not mean more legislation, but could be put into practice in the form of licensing conditions on retailers.
"It would use the existing Licensing Act and make it a condition for licensees to meet certain standards for promotional activity - and there are penalties for those that don't meet those strict guidelines," she said, adding that the trade needs "some entity that has teeth to root out badly run promotions".