Ad description

A web page on seen on 8 January 2018, stated “Easily compare quotes from UK’s top funeral plan providers, plans start from as little as £7.87/Week…COMPARE QUOTES FROM UK’S TOP FUNERAL PLAN PROVIDERS”. Below the text were logos for four funeral plan providers.


Funeral Plan Market Ltd challenged whether the claim “Easily compare quotes from UK’s top funeral plan providers” was misleading and could be substantiated.


Adiko Advertising Ltd t/a did not respond to the ASA’s enquiries.


The ASA was concerned by Adiko Advertising Ltd’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule  1.7 1.7 Any unreasonable delay in responding to the ASA's enquiries will normally be considered a breach of the Code.  (Unreasonable delay). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in future.


We considered that consumers would understand from the claim “Easily compare quotes from UK’s top funeral plan providers” that they would be able to obtain and compare quotes from the listed funeral plan providers directly on the website. We understood from the complainant that once an online form was completed, the customer was offered a single quote by telephone. In the absence of evidence to demonstrate that the website provided consumers directly with quotes from the listed funeral plan providers that they could then compare, we concluded that the claim was misleading.

The ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.    3.3 3.3 Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, the  medium and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means.
 (Misleading advertising) and  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation).


The ad must not appear again in its current form. We told Adiko Advertising Ltd not to imply that consumers could obtain and compare quotes from the listed funeral plan providers directly on their website if that was not the case. We referred the matter to CAP’s Compliance team.

CAP Code (Edition 12)

1.7     3.1     3.3     3.7    

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