Summary of Council decision:

Two issues were investigated, both of which were Not Upheld.

Ad description

A TV ad for Robin Hood Bingo featured an actor playing Robin Hood and two actresses dressed in medieval outfits. Robin said to them, "Greetings ladies. Come, join me at Robin Hood Bingo. I'll give you my free bingo coins every day." The women exclaimed "Free bingo coins every day? You're the best Robin Hood Bingo!". Robin replied, "I know. But that's not all. I'm also giving away £25 free play!" One woman replied, "£25 free play?" Robin said "It's as true as my pants are tight." A male voice-over stated, "Robin Hood Bingo. You play, we give away." One of the women then said, "Robin, are those my tights?" Robin replied "Yes."


The viewer challenged whether:

1. the ad was irresponsible because it was likely to be of particular appeal to under 18-year-olds; and

2. the ad breached the Code because she believed the two actresses were, or appeared to be, under 25 years old.


1. Robin Hood Bingo (RBH) believed that the ad complied with the Code. They explained that the ad was designed with reference to the historical figure of Robin Hood, as portrayed by the actor Errol Flynn in the 1938 film "The Adventures of Robin Hood" and the lead character of the ad was intended to look like the film character. The reference to the film, expressed through the character's clothing, behaviour, look and language, was intended to appeal to an older target audience (primarily housewives) who were more likely to relate to it than younger audiences. The ad depicted a suave, charismatic, 30-something male character (mimicking the Errol Flynn original) who interacted with the female characters in a manner and dialogue which was atypical of today's youth and which was designed to appeal to an older audience. This was further complimented by the medieval 'swashbuckling' styling which, again, lent itself to an older audience. That is why RBH had taken the decision not to have a cartoon Robin Hood or use a more recent depiction of the character.

RBH believed the female characters were depicted in a manner which appealed to an older female audience. By way of example, RBH pointed out that the male character referred to the female characters as "ladies" (a salutation reserved for older women) rather than "girls" or similar. The style of the female characters' costumes, for example, the full-sleeved floor-length dresses with trains, head dress, rings and handkerchiefs, would have been foreign to younger viewers. Furthermore, the women's reaction to the male character could be described as a medieval "swoon" rather than a more modern reaction to which younger people could relate.

RBH believed their entire approach to this ad steered far clear of appeal to viewers who were under 18 years.

Clearcast believed the ad complied with the Code. They considered it had general appeal and did not have particular appeal to under 18s. They pointed out that the story and character of Robin Hood had historical and medieval roots and adult themes of socialism and paganism which were unlikely to be of interest to most under-18s. The story of Robin Hood was not a fantasy fairy tale, unlike for example, Snow White and the Seven Dwarves. Furthermore the style of the ad was that of the golden age of cinema, harking back to the original Technicolor production by Warner Bros in style. They considered this would resonate more strongly with older viewers than younger viewers. Overall, Clearcast considered the style, historical references and production of the ad was clearly aimed at over-18s.

2. RBH provided a copy of the casting brief for the ad which stated that the female actresses "should be aged 28–35". They said that in accordance with the casting brief, the actresses were 27 and 29, well over the age of 25. They also pointed out that the ad contained super-imposed text which explained their 18+ policy and this appeared when the two female characters were on screen. RBH provided confirmation of the actresses' dates of birth.

Clearcast believed the actresses appeared to be over 25 in the ad and understood that they were aged over 25.


1. Not Upheld

The ASA understood that the ad had been designed to appeal to an older audience and the lead character had been based on Errol Flynn's character in the 1938 film "The Adventures of Robin Hood" rather than on a contemporary portrayal of Robin Hood. We considered that the ad made no associations with youth culture; the actors were dressed in medieval-style costumes, and their behaviour and dialogue were of a different era. For example, we noted that Robin used old-fashioned language such as "Greetings ladies. Come, join me ... ", and the female actresses were fanning their faces with handkerchiefs and acting in a coy and coquettish manner around Robin. We also considered that the humour used in the ad, in particular the comment about Robin's tights, was more likely to appeal to an older audience than a younger audience. We noted Clearcast's comment that Robin Hood was not a fantasy fairytale character which was likely to have had more appeal to young people and we agreed. We concluded that the ad was not likely to have particular appeal to under-18s and was not therefore irresponsible.

On this point, we investigated the ad under BCAP Code rules  1.2 1.2 Advertisements must be prepared with a sense of responsibility to the audience and to society.  (Social responsibility) and  17.4.5 17.4.5 be likely to be of particular appeal to under-18s, especially by reflecting or being associated with youth culture
 (Gambling) but did not find it in breach.

2. Not Upheld

We noted that the two female actresses were aged 27 and 29, although at the time the ad was filmed, the younger actress would have been 26. We considered that the styling of the actresses, in period costumes with minimal make-up, did not give the impression that they were under the age of 25. Although the actresses were behaving in a girlish and coquettish manner in the ad, we considered that they did not appear to be under the age of 25.

On this point, we investigated the ad under BCAP Code rule  17.4.6 17.4.6 feature anyone who is, or seems to be, under 25 years old gambling or playing a significant role. No-one may behave in an adolescent, juvenile or loutish way.  (Gambling) but did not find it in breach.


No further action necessary.


1.2     17.4.5     17.4.6    

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