Summary of Council decision:

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

Ad description

A poster for a shopping centre, seen on the side of a bus, featured a photograph of a woman wearing underwear and bunny ears, holding some shopping bags. The headline stated "Get more than you bargained for this Easter". Text underneath stated "With up to 60% OFF! Fashion Show 2pm Tue 2nd & Wed 3rd April. Wedding Fair 5th - 7th".


The complainant challenged whether the ad:

1. was offensive and demeaning to women; and

2. was irresponsible and unsuitable for public display where it could be seen by children.


1. & 2. Junction One Ltd (Junction One) said they were surprised and disappointed to learn of the complaint about, what they thought was a light-hearted, humour-led campaign. They explained that the poster had appeared on 25 buses within the Greater Belfast area. It was part of an Easter-themed campaign, which included a TV ad featuring a "hen-pecked" husband and his wife, and was based on the creative proposition "Get More Than You Bargained for ...". Junction One provided a copy of the TV ad and explained that it contained a humorous twist stemming from the misconception of the term "bunnies", with the wife thinking of chocolate bunnies and the husband focusing on two women who were promoting the shopping centre dressed as "Easter bunnies".

They said they had been mindful of the Code and sensitivities in relation to advertising that featured images of a model wearing overtly sexual underwear who adopted a pose that could be deemed provocative. They said they had taken care to select a tasteful image by choosing a model wearing lingerie in the style of a modest, understated bikini, while striking a cheeky, tongue-in-cheek pose in keeping with the humorous theme of the overall campaign. Regarding the degree to which the model's breasts were exposed, they believed the level of exposure was no more than that which would have been on display had she been wearing a bikini or one-piece swimwear or many mainstream dresses or tops. They said they had deliberately used an image featuring a conservative lingerie design.

They believed the poster was suitably targeted as they wanted to address primarily adults 18 to 45 years of age and they believed a bus-side poster would achieve that. They accepted that some children would have been exposed to the poster, but such exposure would have been minimal. They said that had the poster been used on billboards, they would have ensured that poster sites would have been positioned away from schools and other establishments where children would have been prevalent. They believed the medium used and bus routes would mean that this was not an issue.


1. Not upheld

The ASA noted that the poster featured an image of a woman wearing underwear and bunny ears and that she was standing with a hand on one hip and shopping bags in the other hand. We noted that the image was unrelated to the product being advertised, although we understood the poster was part of a wider campaign including a TV ad which featured models dressed as "Bunny girls". We considered that the image, in the context of the claim "Get more than you bargained for this Easter", was sexually suggestive although we noted it was not gratuitous or explicit. We considered that although some consumers might have found the image distasteful, it was unlikely to cause serious or widespread offence on the basis that it was demeaning to women.

On that point, we investigated the ad under 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) but did not find it in breach.

2. Not upheld

We noted that the poster was untargeted and had wide reach, since it featured on the sides of 25 buses within Greater Belfast and would therefore be seen by children. We considered that children, especially young children, were unlikely to understand the sexual connotations posed by the text "Get more than you bargained for this Easter" when viewed in conjunction with the image. We also considered that because the image alone was only mildly sexual and was not gratuitous or explicit, the ad was not irresponsible or unsuitable for public display where it could be seen by children.

On that point, we investigated the ad under CAP Code (Edition 12) rule  1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society.  (Social responsibility) but did not find it in breach.


No further action necessary.

CAP Code (Edition 12)

1.3     4.1    

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