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Six marketing emails from featured images of women. Some wore underwear and posed provocatively. Others were naked with sports clothing painted onto parts of their body.


The complainant challenged whether the ads were offensive, because they were explicit and objectified women.


FIFA4Coins did not respond to the ASA's enquiries.



The ASA was concerned by FIFA4Coins' 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 provide a response to our enquiries and told them to do so in future.

The e-mails featured a series of images, which showed women each holding a football in a variety of poses. In some of the images, the women were naked and their body was painted to give the appearance that they wore a sports kit. In others, the women wore sports clothing tailored to partially reveal their breasts, or underwear/swimwear and were posed in a sexually provocative way. The ads had not been targeted over and above the email recipients' subscription to the advertisers' database as a result of previous purchases.

In all examples, the images of the women were sexual in nature and in two of the ads, one in which a woman crouched naked on all fours and another in which a naked woman lay on her back with her legs apart and her hands covering her genitals, the images were sexually explicit. In view of the sexual content, the ads were unsuitable for a general audience. In addition, in all ads the images of the women were used to promote the advertised product, a FIFA Coins collection. In view of the sexual nature of the images, which was explicit in some cases, and given that they bore no relevance to the product, we considered that their inclusion in the ads was likely to be seen as offensively objectifying women.

We concluded that the ads were likely to cause both serious and widespread offence.

The emails breached CAP Code (Edition 12) rule  4.1 4.1 Marketing communications must not contain anything that is likely to cause serious or widespread offence. Particular care must be taken to avoid causing offence on the grounds of race, religion, gender, sexual orientation, disability or age. Compliance will be judged on the context, medium, audience, product and prevailing standards.
Marketing communications may be distasteful without necessarily breaching this rule. Marketers are urged to consider public sensitivities before using potentially offensive material.
The fact that a product is offensive to some people is not grounds for finding a marketing communication in breach of the Code.
 (Harm and offence).


The emails must not appear again in their current form. We told FIFA4Coins to ensure that their marketing did not contain imagery that was likely to cause serious or widespread offence and referred the matter to CAP's Compliance team.

CAP Code (Edition 12)

1.7     4.1    

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