Background
Summary of Council decision:
Two issues were investigated, both of which were Upheld
Ad description
A TV ad and a Video on Demand (VOD) ad for Ladbrokes:
a. The TV ad, seen on 17 December 2024, featured a voice-over that stated, “This is a Ladbuck, the new way to get rewarded at Ladbrokes, and these are some of the 100 million Ladbucks that will be dropping weekly. Collect them on our free to play games and choose rewards like free spins, free bets and more. Over 100 million Ladbucks dropping every single week. Plus you can even use them to play your favourite games for free in our Ladbucks arcade. Like Fishin Frenzy and Goldstrike. Start collecting at Ladbrokes.com.” The ad featured imagery of coins that displayed the initials ‘Lb’, as well as text that stated “100m LADBUCKS”, FREE BETS” and “FREE SPINS”.
b. The VOD ad, seen on Channel 4 on Demand on 23 December 2024, was the same as ad (a).
Issue
Two complainants who believed the term ‘Ladbucks’ was likely to be of strong appeal to those under 18 years of age, challenged whether:
- ad (a) breached the BCAP Code; and
- ad (b) breached the CAP Code.
Response
1 & 2. LC International Ltd t/a Ladbrokes said both ads promoted ‘Ladbucks’, which was their rewards programme. Ladbucks were tokens, depicted as coins, that consumers collected for free by participating in selected promotions, which were then used to redeem offers within the ‘Ladbucks Store’ or the ‘Ladbucks arcade’. They could only be used by logged-in, verified over-18 consumers. They stated tokens could not be purchased, had no monetary value and expired if not used. They explained that Ladbucks did not have a general market value with an exchange rate, and they could not be universally used across all products on the Ladbrokes site. They said each eligible product or offer had a set value, which was in contrast to in-game currency products.
Ladbrokes said that, in the context of their rewards programme, the term Ladbucks was chosen as a play on the word Ladbrokes, and because it referenced, through the use of the term bucks, that it had value on the Ladbrokes website. They believed the term ‘bucks’ was known as a colloquialism for dollars and was widely used to refer to money or a unit of currency in many contexts, which included video games. They said that the word had no origins in youth culture and believed that it was not of inherent strong appeal to under-18s. They highlighted that both ads had targeting restrictions to reduce the likelihood of children viewing them.
Ladbrokes believed that the term was not associated with any coins from videogames which were popular with under-18s. They said that ‘V-bucks’ from Fortnite and ‘Robux’ from Roblox were in-game currencies that had to be purchased before being used to buy in-game items. They also said that certain elements of Robux required parental consent and, for subscription services, the purchaser must be over 18. Therefore, the only similarity between those coins and Ladbucks coins was the term bucks. They had reviewed the rewards programme in its entirety and believed there was no risk of the term being associated with Fortnite or Roblox.
Ladbrokes said many other industries used reward schemes for consumers and the concept was not unique to video games which were popular with under-18s. They also said that as a licensed gambling operator that offered casino and poker products, using imagery of a ‘poker chip’ should not be considered imagery that was of strong appeal to under-18s. Therefore, they believed there was nothing in the imagery or the content of the ads that shared similarities with either of those games.
They did not believe the term “lad” referred to a boy or young man and said their brand had never been used in that context. They also said the term “lad” itself was not specifically mentioned by the complainants.
Clearcast did not believe the term Ladbucks in ad (a) appealed strongly to children. They understood that the coin was Ladbrokes’ version of free prize tokens within their rewards programme, and that they could have been used on certain promotional offers until they expired. They did not believe the tokens were similar to in-game currencies, in which those tokens had to be purchased.
Channel 4 believed ad (b), which was broadcast on their streaming service, was compliant with the Code.
Assessment
1. & 2. Upheld
The BCAP and CAP Code stated that gambling ads must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture. Because the ads had appeared in mediums where under-18s could not be entirely excluded from the audience, they needed to comply with that rule.
BCAP and CAP guidance, “Gambling and lotteries advertising: protecting under-18s”, stated that marketers should exercise particular caution when depicting product features similar to recognisable video games, online games popular among under-18s, or common features of such games in general. It also stated that content linked to activities that were very popular or common among younger people (in terms of their direct participation and viewing) was at risk of being of strong appeal to under-18s.
The ASA first assessed if there were online games which featured tokens depicted as coins, and whether they were very popular with children and strongly associated with youth culture, before considering if features of those coins had noticeable parallels with a Ladbuck.
We understood that several online games popular with under-18s, such as Roblox and Fortnite, had their own in-game currencies, which were called Robux and V-bucks respectively. Those currencies, which could be both purchased and earnt through gameplay, were depicted as coins, and spent within in-game stores, usually on cosmetic items that enhanced gameplay. According to Ofcom’s 2024 report into media use and attitudes, 60% of children aged between 3 and 17 years gamed online, whilst 89% of 11–18-year-olds gamed online weekly. Overall, categories of games that were most popular included building games, such as Roblox, followed by games played against others, such as Fortnite. We also understood that many under-18s engaged with content related to both those games via YouTube, Twitch and TikTok. Data from the Academy of Animated Arts showed Fortnite had the most combined YouTube and Twitch weekly viewing hours of any game. Roblox had over 32 million daily active users under the age of 13 at the end of 2024. In addition, 24% of children aged 10–12 years played Roblox in the UK.
Based on that data, we considered a significant number of under-18s were likely to be familiar with those games and their specific features, which included reward schemes that involved earning and using coins in associated game stores. For those reasons, we considered both games and their associated features were strongly associated with youth culture.
Given that context, we assessed whether the term Ladbucks, through its name and in conjunction with how the coin was depicted in the ads, was likely to be of strong appeal to under-18s due to its similarities to those in-game currencies.
We first assessed the similarities between the names of the coins. We considered the term Ladbucks, through the suffix ‘bucks’, had strong similarities to the in-game currencies Robux and V-bucks. We acknowledged Ladbrokes’ view that the term bucks was a well-known colloquialism for dollars and we did not consider the use of the word bucks in isolation to be of strong appeal. However, we also understood the term V-buck was a shortened version of ‘Vindertech’ buck, which was a fictional company in Fortnite. Similarly, we considered the word ‘lad’ had been taken from the company name Ladbrokes to create the name of their token. Therefore, we considered the construction of the token names, enhanced the similarity between the names of the coins, which due to the popularity of those games with children, many under-18s were likely to recognise. In addition, whilst we accepted the use of the prefix ‘lad’ was for its link to the brand, and we did not consider the brand’s name itself to be of appeal to children, we also considered that ‘lad’ was a colloquial term for a boy or young man. In the context of the ad and its use alongside the word buck, the word lad would have also been recognised and of appeal to some under-18s.
We next assessed the overall depiction of the tokens. The style of both the Ladbuck and V-Buck had similarities with a poker chip. The Ladbuck token’s design was round, shiny around the edges with an initial in its centre. Those were features that were all present in the design of a V-buck. Whilst a ‘Robux’ was at the time the ads were seen, a different shape, we understood it was still sometimes depicted in its previous form, which again resembled a poker chip with the initial ‘R’ and a dollar sign in the middle. Although we acknowledged that Ladbrokes offered poker and casino games, we considered it was not the use of poker chip imagery in isolation, but the use of the token’s imagery when used in conjunction with the term Ladbucks, that was likely to have been recognisable and perceived by many under-18s as similar to those in-game currencies of online games that were of strong appeal to under-18s.
In addition, we noted the Ladbucks tokens could be used in the online Ladbrokes store and arcade and that was likely to be reminiscent of the way in-game currencies Robux and V-bucks were used. Therefore, we considered that was likely to further enhance its appeal to children through its resemblance to tokens used in gaming, with which they would likely be familiar.
For those reasons we concluded the name Ladbucks, when considered alongside the imagery and the application of the coin in the ads, was depicted in a manner which was similar to features in video games popular with children. We therefore considered the term in the ads was likely to be of strong appeal to under-18s and breached the Code.
On those points, ad (a) breached BCAP Code rules 17.4.5 (Gambling) and ad (b) breached CAP Code (Edition 12) rules 16.1 and 16.3.12 (Gambling).
Action
The ads must not appear again in their current form. We told LC International t/a Ladbrokes not to include content in ads that was reflective of youth culture or which had strong appeal to those under 18 years of age.
