Ad description
A Facebook post seen on the Mecca Bingo (Luton) page in May 2025. The post stated, “NAME THE TOM HANKS FILMS”. It then featured 10 separate films, alphabetically labelled A. to J., populated with emoji’s that had to be deciphered to name the relevant film. The post included emojis of a teddy bear, child’s face, mermaid, rocket and an aeroplane.
Issue
The complainant challenged whether the ad was irresponsible because the use of emojis was likely to appeal strongly to people under 18 years of age.
Response
Mecca Bingo Ltd (Mecca) said the ad was a social media post created by an external agency in 2022. Since that time Mecca had issued updated internal guidance around the use of emojis and a number of social media ambassadors, trained on the guidance, had been created to serve specific regions of venues. In 2024 a full review of their social media library had been undertaken but the particular post was not identified for removal.
They explained the post was likely seen by active followers of the Mecca Bingo (Luton) account, where followers would have to self-declare as over 18. They provided demographic data from Meta for the account. That showed the audience was predominantly over 25 years of age with only 2.9% of followers in the 18 to 24 age bracket.
They said regarding the specific post they did not believe the emojis, or the wider content of the post, had strong appeal to children or young people. The post featured a wide range of emojis and their sole purpose was to provide clues to decipher Tom Hanks films. They said they did not believe Tom Hanks, or the vast majority of his films, had strong appeal to, or association with, youth culture.
The post was also organic, not paid for, and it did not advertise a specific event or promotion. It was primarily intended as a means of customer engagement.
They stated that while they did not believe the post breached the Code, because the liberal use of emojis no longer aligned with their marketing strategy, they had permanently deleted the post and it would not be used in the future. They had also reissued guidance on emojis in marketing communications across their business and were conducting a wider review of their social media library to ensure continued compliance.
Assessment
Not upheld
The CAP Code stated that gambling ads must not be likely to be of strong appeal to people under 18, especially by reflecting or being associated with youth culture.
The post involved using emojis as clues to decipher films that Tom Hanks starred in. However, the ad did not include an image of Tom Hanks.
CAP guidance stated that child-oriented cartoon content or animated styles and characters like 'cuddly’ or ‘cute’ animals, princesses or pirates with exaggerated features were high-risk content which should be avoided.
The 10 puzzle questions appeared on a green background with text in a simple white font. We considered that emojis themselves had a cartoon-like appearance and acknowledged that specific emojis might also represent objects which would be associated with younger children’s interests; for instance, the ad included emojis of a teddy bear, a mermaid, and a rocket, as well as some depictions of sport, including a football. However, those emojis were no more prominent than the others, which included the Italian flag, an SOS sign and a briefcase. There were 32 emojis in total, with the vast majority showing everyday objects or symbols. We considered that, in the context of a puzzle game requiring people to name a broad spectrum of films, the range and use of emojis were unlikely to have strong appeal to children or young people by reflecting or being associated with youth culture.
We therefore concluded that the ad did not breach the Code.
We investigated the ad under CAP Code (Edition 12) rules 16.1, 16.3 and 16.3.12 (Gambling), but did not find it in breach.
Action
No further action necessary.
