ASA Adjudication on British Sky Broadcasting Ltd

Ad

A TV ad and two national press ads for Sky included the claim "CarbonNeutral".

a. The first national press ad, for Sky digital packages featured small text at the top of the page that stated "Sky is a CarbonNeutral®company".

b. The second national press ad stated "BELIEVE IN BETTER Because the world's a great place, we're trying to keep it that way. CarbonNeutral®since 2006." Text at the foot of the page stated "sky.com/environment".

c. The TV ad featured a cartoon of a tiger walking through a town and fields to an upbeat soundtrack. In one scene, a car drove past the tiger with smoke emanating from its engine. The tiger grabbed the car and 'hugged' it; the scene changed to show the car and tiger in a field, surrounded by flowers. The voice-over stated "Because the world's a great place, we'll carry on doing our bit to keep it that way. Sky. Believe in better". On-screen text included the Sky logo, the text "CarbonNeutral®since 2006" and "sky.com/environment".

Issue

The ASA received four complaints: one about press ad (a), one about press ad (b) and two about the TV ad.  All four complainants challenged whether Sky could substantiate that they were carbon neutral.  One complainant believed, because the installation of satellite dishes was carried out by engineers travelling in vans that emitted carbon, the company could not possibly be carbon neutral.  The other complainants understood that Sky had not included the emissions produced by their set-top boxes in the calculation of their carbon emissions and therefore believed the claim was based on inaccurate figures.

CAP Code (Edition 11)

BCAP TV Code

Response

Sky explained that the claim related to their status as a company which had achieved carbon neutrality working with The CarbonNeutral Company (TCNC), a company specialised in carbon consulting and business carbon offsetting.  They said being "CarbonNeutral" meant that they had measured their carbon footprint, taken operational steps to reduce it and purchased offsets to counteract the remaining carbon emissions.

Sky said TCNC helped them to calculate their carbon emissions in accordance with the CarbonNeutral Protocol, which in turn accorded with the agreed international standards for assessing emissions set out in a framework published by the World Resource Institute and World Business Council for Sustainable Development (WRI/WBCSD), the Greenhouse Gas Protocol Initiative (the GHG Protocol).  Scope 1 concerned direct emissions from sources a company owned or controlled; Scope 2 concerned emissions from the generation of purchased electricity that a company consumed in its equipment or operations it ran or controlled; Scope 3 concerned emissions that were relevant to the company but not within its direct control.  Sky told the ASA that, under the GHG Protocol, companies had to account for all scope 1 and 2 emissions. Accounting for Scope 3 emissions was optional because they were often outside a company's control. Sky nevertheless opted to include emissions from employee business travel, a Scope 3 emission, within their carbon emissions calculation.  With regard to the concerns raised by the complainants, Sky explained that carbon emissions generated from company-owned vehicles were included in the calculation of their carbon footprint as Scope 1 emissions, but the emissions from set-top boxes were not included because they were not within Sky's direct control.  Sky nevertheless pointed out that they had produced an auto-standby set-top box which automatically switched to standby at certain times.

Sky said the measure of their carbon footprint was verified by two independent third parties, the Edinburgh Centre of Carbon Management (ECCM) and Environmental Resource Management (ERM) Ltd.

Having calculated Skys carbon emissions, TCNC then calculated the rate, in pounds per tonne, of Sky's carbon offset; that figure represented the sum Sky paid to TCNC which it in turn invested in accredited projects.  Sky said those projects consisted of a portfolio of energy efficiency and renewable energy products worldwide that offset the amount of carbon the organisation would produce over the life of their five-year "CarbonNeutral" plan.  They said the offsets were either Certified Emissions Reductions (CERs) or Voluntary Emissions Reductions (VERs).  CERs were verified to the standard set out in the Clean Development Mechanism (CDM) which was established by the Kyoto Protocol and was seen as the international quality benchmark for carbon offsetting projects. VERs conformed to the standards set out in the Voluntary Gold Standard (VGS) or the Voluntary Carbon Standard (VCS).

Sky explained that, when a company's carbon emissions were reduced to net zero in accordance with the CarbonNeutral Protocol, the organisation was deemed to be carbon neutral and use of the CarbonNeutral registered trademark was awarded.  Sky said they used the trademark to show that their carbon neutral status had been conferred on them by an independent third party and to show that they were carbon neutral.

Sky submitted detailed dossiers of evidence including details of their agreement with TCNC and their key offsetting programmes, a copy of the CarbonNeutral Protocol and a copy of their CarbonNeutral certificate.

Clearcast said Sky provided comprehensive substantiation for the claim "CarbonNeutral".  They were satisfied that it supported the claim and they endorsed Sky's response.

Assessment

Not upheld

The ASA noted Skys comments.  We considered most viewers and readers were likely to interpret the claim "CarbonNeutral" to mean that Sky had taken steps to reduce to net zero the carbon emissions from its business activities that were within its reasonable control and offset any remaining emissions through robust and verifiable schemes. We noted the complainants were concerned because they believed Sky were unlikely to have taken particular types of emissions into account when setting the boundaries for calculating their carbon footprint.

We understood that there was no generally accepted definition of carbon neutral but that the claim could be evaluated against generally accepted best practice.  We therefore took independent expert advice. The expert said the GHG Protocol was an internationally recognised standard which encompassed the variables which needed to be taken into account in assessing a companys carbon footprint.  He said it was the most widely used accounting tool for emissions and was therefore a core element of generally accepted best practice in terms of accounting and reporting GHG emissions as part of a carbon neutrality claim.  The expert said Sky had fully employed the principles of the GHG Protocol in the assessment of its emissions and calculation methodologies: Sky had taken into account Scopes 1 and 2 and some Scope 3 emissions - emissions from its premises (gas, oil and fuel), company owned vehicle emissions, emissions from operational electricity consumption and emissions from employee business travel.  He concluded that, by including some Scope 3 emissions in its carbon footprint calculations, Sky had in fact sought to go above and beyond generally accepted best practice.

Our expert advised that a number of key factors needed to be taken into account when considering whether an offset was robust.  He explained that factors such as additionality, validation, verification, project type, timing of credits, leakage and double counting should be considered.  We noted CERs were verified and regulated according to the CDM, established by the Kyoto Protocol and so were verifiable. In relation to the VCS and VGS offsets purchased by Sky to counteract its remaining carbon emissions, the expert advised that the VGS VER was comparable in quality to CERs and that the VCS was broadly comparable in quality, although there was further work to do in one or two areas.

We noted Sky, in calculating its carbon footprint, had taken into account emissions from its vehicles and, although they had not taken into account emissions from their set-top boxes because they were a Scope 3 emission outside of Skys direct control, we noted they had offset other Scope 3 emissions.  We considered that Sky had followed generally accepted best practice methodology in terms of boundary setting and calculation methodologies for emissions accounting and reporting.  We noted offsets were to be either certified (CERs) or from projects that complied with one of the Standards (VCS or VGS) within the voluntary market that were evaluated and validated to a sufficiently high level.  We therefore concluded Sky had substantiated the claim.

We investigated the national press ads under CAP Code clauses 3.1 (Substantiation), 7.1 (Truthfulness) and 49.2 (Environmental claims) and the TV ad under CAP (Broadcast) TV Advertising Standards Code rules 5.1 (Misleading advertising), 5.2.1 (Evidence) and 5.2.6 (Environmental claims) but did not find them in breach.

Action

No further action necessary.

Adjudication of the ASA Council (Broadcast)

Adjudication of the ASA Council (Non-broadcast)