Ad description
Three tweets on the @WillHillBet Twitter feed.
(a) One ad featured an image of a child, jumping in the air while holding a golf club and ball. The tweet stated "#TheMasters has started! #yippee".
(b) The second ad featured an image of two large teddy bears wearing crowns on the back of a lorry. One wore a blue rosette, the other a pink one. Text stated "Seen our teddy bears around London today? Send us your pics with #BOYorGIRL & you could win a Grand National Free bet".
(c) The third ad featured teddy bears similar to those in ad (b) in front of the Houses of Parliament which was tweeted to other Twitter users responses to the bears in ad (b). The text stated "Definitely wearing crowns #BOYorGIRL".
Issue
The complainant challenged whether the ads were likely to be of particular appeal to children and was therefore irresponsible.
Response
WHG (International Ltd) t/a WillHillBet (William Hill Betting) said that the use of the image of a child in ad (a) and the teddy bears in ads (b) and (c) were not acceptable and had implemented procedures to ensure the issues were not repeated.
Assessment
Upheld
The ASA welcomed William Hill Betting's assurance that they had taken steps to ensure that similar issues to that in ads (a), (b) and (c) would not arise in future. In relation to ad (a), the CAP Code stated that marketing communications for gambling products must not include a child or a young person. Because a child featured in ad (a) we considered it breached the Code.
The Code stated that marketing communications for gambling products must not be likely to be of particular appeal to children or young people. We noted that ads (b) and (c) appeared in the few weeks before the birth of the Duke and Duchess of Cambridge's second child when there was a lot of speculation about the gender of the royal baby. That was conveyed by one of the teddy bears wearing a blue rosette, the other, a pink one and both were wearing crowns. We considered that the general speculation, rosettes and crowns were likely to have appeal for a wide age range, including children. Nevertheless, we considered that regardless of those elements and the context in which the ads appeared, the images of the large teddy bears which formed the central focus of the ads, would have been seen as children's toys and were therefore likely to be of particular appeal to children. We therefore concluded that ads (b) and (c) breached the Code.
The ad breached CAP Code (Edition 12) rules
1.3
1.3
Marketing communications must be prepared with a sense of responsibility to consumers and to society.
(Responsible advertising),
16.1
16.1
Marketing communications for gambling must be socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited.
16.3
16.3
Marketing communications must not:
16.3.12
16.3.12
be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture
16.3.14
16.3.14
include a child or a young person. No-one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role. No-one may behave in an adolescent, juvenile or loutish way.
Individuals who are, or seem to be under 25 years old (18-24 years old) may be featured playing a significant role only in marketing communications that appear in a place where a bet can be placed directly through a transactional facility, for instance, a gambling operator's own website. The individual may only be used to illustrate specific betting selections where that individual is the subject of the bet offered. The image or other depiction used must show them in the context of the bet and not in a gambling context.
(Gambling).
Action
The ads must not appear again in their current form. We told William Hill Betting not to use images of children or images that were likely to appeal to children or young people in future gambling ads.
