A Tweet on Coral’s Twitter page, seen in March 2020, featured the text “We’re as passionate about the bet as you are. So, get your stake back as a free bet if your horse fails to finish. #CoralRacing 18+, T&C’s Apply”. A link to a video ad was captioned “Have another go” and began with horses racing and superimposed text which stated “STRONG, FAST, RELENTLESS, RIDERLESS”.
The scene then featured a jockey about to fall off his horse. Further text stated GET A FREE BET BACK WITH FAIL TO FINISH” while a voiceover repeated it. A man watching looked disappointed until he looked at his phone and smiled. The voiceover stated, “For the passion of the bet: Coral Racing.”
IssueThe complainant, who believed the ad encouraged repeated gambling, challenged whether the ad was irresponsible.
LC International Ltd t/a Coral stated that they did not believe the ad encouraged repeated or socially irresponsible gambling. They said the ‘Fail to Finish’ promotion required consumers to place a real-money single or each-way bet of £1 or more on an eligible race. If their horse failed to finish the race, the consumers would receive a free bet token matching their bet value up to £10 and the promotion provided a form of insurance on the bet in the event that the horse failed to finish. They said that this was a recognised industry campaign mechanic that was not designed to encourage repetitive play.
Consumers were not obliged to take up the offer and did not have to use additional funds to qualify for the offer if they decided to have another go. The promotion was therefore not designed to cause financial or social harm. They did not consider that the ad applied undue pressure to place another bet or encouraged gambling any more than what a consumer would normally gamble. They said that the tweet aimed to highlight the prize of the promotion, while keeping within a certain character count and without encouraging socially irresponsible behaviour. They did not consider that the video implied that the decision to gamble had been taken lightly. They said that the “have another go” claim only appeared on the tweet in question, not on any other parts of their broader “Fail to Finish” campaign and that the claim and ad would not be used again. Coral said that the ad also featured the GambleAware website, age restriction and the Senet banner, “When the fun stops, stop”.
They acknowledged that the ASA’s Advertising Guidance on Gambling Advertising stated that marketers should take care to avoid approaches that trivialise gambling and avoid the impression that the decision to gamble should be taken lightly. They said that their ad adhered to this standard.
The CAP Code stated that marketing communications for gambling must not portray, condone or encourage gambling behaviour that was socially irresponsible or could lead to financial, social or emotional harm. CAP and BCAP’s Advertising Guidance on ‘Gambling Advertising: responsibility and problem gambling’ also stated that marketers should take care to avoid trivialising gambling and avoid the impression that the decision to gamble should be taken lightly, for example by not encouraging repetitive participation.
The ASA understood the ad promoted a “Fail to Finish” offer which gave consumers a free bet token matching their bet value up to £10 in the event that their horse failed to finish. We acknowledged that the “Fail to Finish” promotion did not oblige consumers to take up the offer and that consumers did not have to use additional funds to qualify for the offer. However, we considered that the claim “Have another go”, together with the video ad which featured a man whose mood was instantly lifted following a free bet back, gave the impression that the decision to gamble had been taken lightly and was therefore likely to encourage some consumers to take up the offer repetitively. For that reason, we concluded that the ad was likely to encourage gambling behaviour that was potentially harmful and therefore breached the Code.
The ad breached CAP Code (Edition 12) rule 16.3.1 16.3.1 portray, condone or encourage gambling behaviour that is socially irresponsible or could lead to financial, social or emotional harm (Gambling).
The ad must not appear in its current form. We told LC International Ltd t/a Coral not to present their promotions in ways that were likely to encourage repetitive participation in gambling.