Summary of Council decision:
Two issues were investigated, both of which were Not upheld.
A TV ad and poster ads for the cinema release of the film Venom: Let There Be Carnage:
a. The TV ad, seen in October 2021, showed a variety of scenes from the film. Included were scenes of a man morphing into a monster creature whilst making a loud growling sound, the monster attacking a car being driven by a woman, and a close up of the monsters’ face. The scenes were accompanied by a voiceover, which stated, “You are a cancer to everyone who ever loved you. Let me eat him. He’s a serial killer and he’s got an alien inside of him”. The text “VENOM LET THERE BE CARNAGE” appeared on-screen towards the end of the ad.
The ad was cleared by Clearcast with a post 7.30 pm scheduling restriction.
b. An outdoor poster ad, seen in October 2021, featured an image of the faces of two men, where one half of each face had been replaced with a monster’s face. Text stated “VENOM LET THERE BE CARNAGE”.
c. A poster ad, seen on the London Underground network in September and October 2021, included the same image and text as ad (b).
d. A poster ad, seen on the side of buses in October 2021, included the same image and text as ad (b).
The ASA received 16 complaints. Many of the complainants reported that their young children had been distressed by the ads:
1. Three complainants challenged whether the TV ad, ad (a), had been responsibly targeted.
2. Fourteen complainants challenged whether the poster ads, ads (b) to (d), had been responsibly targeted.
1. Columbia Pictures Corporation Ltd t/a Sony Pictures did not provide any comments additional to those provided by Clearcast.
Clearcast said they had approved the ad with a post-7,30 pm scheduling restriction, meaning that it should only air after 7.30 pm. They said the scheduling restrictions applied to the ad were consistent with the restrictions they normally applied to film trailers with scenes of a similar nature. They applied the restriction because the ad included visuals of morphing faces and aggressive behaviour of two men fighting, including a non-bloody shot of one of them biting the other. The ad did not include any visuals of injuries or any scenes of torture.
They applied the same criteria that they had applied to TV ads for the prequel film, “Venom” because the portrayal of the main character was similar in both ads. Although the ASA had received complaints about similar TV ads for the prequel film, the ASA had considered that the ads had been given appropriate scheduling restrictions.
In their view the ad did not warrant a higher restriction of post-9pm.
2. Sony Pictures said the image shown in the three poster ads represented the main narrative of the film - the characters played by Tom Hardy and Woody Harrelson were hosts for an alien creature. They said the images were fantastical. The ads did not contain any images of blood, weapons, scenes of violence, any reference to death or any other fearful or distressing images. The ads also did not contain a tagline.
In their opinion, the images were not excessive, they simply relayed the main narrative of the film. There was a significant amount of wording in the ads, including the film’s title, the two actors’ names, the films’ cinema release date and that it could be watched in IMAX, which made it clear to consumers that the images in the ads were from a film release and not based in, or on, reality.
They said the ad was very similar to one that had been used for the prequel “Venom” in 2018. Although the ASA had received complaints about the poster ad for the prequel film, the ASA had considered that the ads were suitable for an untargeted medium.
Global (the media space owner) said they submitted the ad in advance to CAP’s Copy Advice team, who had advised that the ad was unlikely to breach the Code. They understood Transport for London (TfL) were also satisfied the ad complied with their regulations. Global said that the ad did not breach their own internal guidelines.
1. Not upheld
The ASA considered that the ad contained scenes of mild violence and horror including clips of the actor morphing into, and of, the monster creature. We considered that some children might have found these, coupled with the background music and voiceover dialogue, unsettling. However, the ad did not contain scenes of explicit or bloody violence, or serious horror. We considered that it was unlikely to cause fear or distress to older children, but that it was likely to cause fear and be distressing to young children.
The ad was subject to scheduling restrictions that prevented it from being shown in or adjacent to programmes commissioned for, principally directed at or likely to appeal to children under 16, or before 7.30 pm. We considered those restrictions were sufficient to ensure that the ad was unlikely to be seen by young children, and we had not seen any evidence that the ad had been broadcast or served against that restriction. We therefore concluded that the ad had been appropriately scheduled and did not breach the Code.
We investigated ad (a) under BCAP Code rules
Advertisements must contain nothing that could cause physical, mental, moral or social harm to persons under the age of 18.
Advertisements must not distress the audience without justifiable reason. Advertisements must not exploit the audience's fears or superstitions
(Harm and offence),
Advertisements that are suitable for older children but could distress younger children must be sensitively scheduled (see Section 32: Scheduling).
(Children) and 32.3 32.3 Relevant timing restrictions must be applied to advertisements that, through their content, might harm or distress children of particular ages or that are otherwise unsuitable for them. (Scheduling), but did not find it in breach.
2. Not upheld
The ASA acknowledged that Global had taken advice from the CAP Copy Advice team on an example of the image and copy used in the three poster ads. Their view was that it was unlikely to be considered a breach of the Code.
Ads (b) – (d) appeared as outdoor posters and were therefore likely to be seen by people of all ages. We acknowledged that the image in the ads, which showed the two main character’s faces morphed with half a monster’s face, could be upsetting for some children. However, we considered that the image, which did not contain any overtly violent or threatening imagery, was unlikely to be considered realistic by most people.
We considered the image to be relatively mild and unlikely to cause widespread distress to children. We therefore considered that the posters were suitable for display in an untargeted medium, even where they were likely to be seen by young children. We concluded that ads (b) – (d) did not breach the Code.
We investigated ads (b), (c) and (d) under 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) and 4.2 4.2 Marketing communications must not cause fear or distress without justifiable reason; if it can be justified, the fear or distress should not be excessive. Marketers must not use a shocking claim or image merely to attract attention. (Harm and offence), but did not find them in breach.
No further action necessary.