ASA Adjudication on Warner Bros. Entertainment UK Ltd

Ad

Two ads for the film RocknRolla. a. A poster featured the film's main characters; in the background one held a gun, which pointed into the foreground towards the left. Text stated "GUNS, GIRLS, GEEZERS … "; "YOU KNOW YOU WANT TO BE ONE ROCK N ROLLA ANOTHER PIECE OF THE ACTION FROM THE GUY WHO BROUGHT YOU SNATCH AND LOCK, STOCK AND TWO SMOKING BARRELS". b. An internet banner ad showed a character from the film with his arms spread wide and a gun in each hand, which pointed in either direction. Text stated: "ROCKNROLLA HIT ME".

Issue

1. One complainant objected that ad (a) condoned violence at a time of increasing public concern about gun crime;

2. another complainant objected that ad (b) glorified guns; and

3. the same complainant objected that ad (b) was inappropriate in a medium that was accessible to children.

CAP Code (Edition 11)

Response

Warner Bros. Entertainment UK Ltd (Warner Bros) said that they did not believe the ads condoned violence or glorified guns. They had demonstrated their sense of responsibility to consumers and society by taking steps to target those old enough to watch the film, which was part action, part gangster movie.  They said they felt the content of the ads provided just enough information about the type of film being advertised whilst being socially responsible compared with other recent poster campaigns for films of a similar genre.    

They said the campaign had ended and they had showed their willingness to co-operate by requesting that both ads were removed as soon as possible.       

1. Warner Bros said the poster used a collage of images of characters to create a general impression of the film without showing violent content.  They referred to the abstract image of a highly stylised character, who was clearly fictitious, holding a gun, which they ensured was not pointing at readers, or at any of the other characters, and was not a predominant element in the ad.  They said they had sought to ensure that the characters, rather than the gun, were predominant.  They also said the image was not threatening or glorified in a manner that would encourage imitation. The gun was not smoking as though it had recently been fired and no bullets or wounds featured in the ad. Along with the text in the poster it gave potential viewers an idea of what to expect from the film and allowed them to make an informed choice about its content.

Warner Bros said no local authorities or agencies that sold advertising space for the ads expressed concerns about the images. They said if they had, they would have made reasonable amendments to take those views into account.  They said they were aware that it was difficult to determine who would see outdoor advertising but in the case of their ads on buses, for example, they had amended the image so that the guns were almost completely out of view.  They said most of the film's marketing campaign was age-targeted online, as in the case of ad (b), or was displayed in licensed premises where children should not be expected to be granted entry.

Warner Bros said the text "YOU KNOW YOU WANT TO BE ONE" referred not to guns but to being a "RocknRolla", which was an overall style and image demonstrated by the various characters in the ad; the text "GUNS, GIRLS, GEEZERS ... ", which was a direct quotation from a magazine review, and therefore the reviewer's opinion, was used in the ad to describe the usual elements found in action and gangster films.  They said, as a whole, they believed the poster could not be seen to glamorise or provoke gun crime or to suggest the use of guns in real life was acceptable.  

2. Warner Bros said the internet banner ad was prepared with similar considerations to those given to the poster but was even more stylised: the character was animated in a surreal comic book form to separate the image from reality and to reflect the artistic nature of the campaign overall.  They said the image was artistically striking but was presented in a way that was not meant to be alluring, glamorous, aspirational or to encourage imitation.  They stated that the stance and dress of the character were not at all realistic and the guns were not pointed towards the reader and had not recently been fired.  

They said readers might reasonably interpret the image as a raw and gritty drawing that depicted a shocking situation and might therefore discourage them from entering a situation involving a gun.  Again, the image was chosen to give an impression of the content of the film without condoning real-life gun crime or suggesting it was glamorous.  The text "HIT ME" was intended to prompt readers to "hit" the banner as a 'click-through' to a website and did not glorify guns.  

3. Warner Bros said, in line with the classification of the film, they took steps to ensure ad (b) was targeted only at those aged 15 years and over; 97.29% of 90,189,000 online impressions were specifically targeted in that way.  They said their agency advised them that most of those impressions were restricted and were shown only to users of sites who had registered as being 15 years or over and were 'signed in'.  The remainder were on sites that targeted their content at those over 15 and that had audience measurement software tools which had shown the audiences to be aged 15 years and over.

Assessment

THIS ADJUDICATION REPLACES THAT PUBLISHED ON 17 DECEMBER 2008.  THE DECISION ON COMPLAINT 3 HAS BEEN REVERSED, MAKING THE COMPLAINT 'NOT UPHELD'.   

1. Not upheld

The ASA noted the images in the ad were stylised and reflected the film's storyline.  We acknowledged the text "YOU KNOW YOU WANT TO BE ONE" might be interpreted by some as aspirational but also noted the gun was not prominent and the characters did not display direct aggression.  We considered the overall impression of the ad was such that it would be understood as a reflection of the fictional content of an action gangster film and the presence of a gun in that context was unlikely to be interpreted as suggesting that the use of guns in real life was acceptable.  We concluded ad (a) was unlikely to be seen to glorify guns.

We investigated the ad under CAP Code clauses 2.2 (Responsible advertising) and 11.1 (Violence and anti-social behaviour) but did not find it in breach.

2. Upheld

We noted the text "HIT ME" was intended as an invitation to click on the ad.  We considered however that, in conjunction with the image of a character clearly pointing two guns, it could also be interpreted as a suggestion of aggression.  We acknowledged that the ad reflected the fictional content of an action film but considered that the stance of the character, in conjunction with the text, meant it was likely to be interpreted as glorifying guns.  Because it glorified guns, we concluded that ad (b) condoned violence and was irresponsible.   

On this point, the ad breached CAP Code clauses 2.2 (Responsible advertising) and 11.1 (Violence and anti-social behaviour).

3. Not upheld

We noted the Code stated that marketing communications addressed to or targeted at children should contain nothing that was likely to result in their physical, mental or moral harm.  We noted Warner Bros had taken steps to ensure that over 97% of online impressions were targeted at those aged 15 years or over.  We concluded that the ad had not been addressed to or targeted at children.

On this point, we investigated the ad under CAP Code clause 47.2 (Children) but did not find it in breach.

Action

Ad (a): no further action necessary.  

Ad (b) must not appear again in its current form.

Adjudication of the ASA Council (Non-broadcast)