Ad description

A website for the Principal Hotel Company,, seen on 29 September 2017. One section of the website was for the "De Vere Horsley Estate" which included photos of the grounds, facilities and rooms with a principal image of a country manor. The "Rooms" section included details and a number of photos for each category of accommodation.


The complainant challenged whether the main guest room listings for De Vere Horsley Estate were misleading because they did not make clear that these rooms were in a separate training centre from the manor.


Principal Hayley Ltd t/a Principal Hotel Company said De Vere Horsley Estate was an “estate” made up of multiple buildings and the website’s home page introduction made it clear that it comprised the old mansion and the new Management Centre in Horsley Place. They said the heading on the home page specifically referenced a “unique business retreat and hotel in East Horsley, Surrey” and the body copy mentioned “the addition of a contemporary Management Centre”.

Principal Hotel Company said the website’s booking engine clearly stated where each room type was located (the Towers or the adjacent management Centre, Horsley Place) and the main guest room listing clearly stated in the first line of the room description that it was “located within our adjacent training centre”. They said that was also prominently stated on the “Rooms” subsection of the website.

Principal Hotel Company said they made it clear which building a guest was booked into by splitting the room types between the buildings – only the Deluxe rooms and Suites were available within the Towers. Guest rooms and Superior rooms were only available in Horsley Place, reflected in the price of the rooms.

Principal Hotel Company said photos of the Management Centre bedrooms (guest rooms and superiors) could be found on the “Rooms” subsection of the website, through their booking page and the image gallery. There were also photos of other areas of the Management Centre such as the Management Centre Bar. They said that while they did not have an exterior photo of Horsley Place, there was a photo on the website’s main gallery that showed a bird’s eye view of the entire estate that clearly labelled the “original mansion house, modern Management Centre and the court building”. They said the reason it was included in the bird’s eye view was so that consumers could see the relationship between the buildings that were contained on the Estate.

Principal Hotel Company said that their image gallery showed other areas of the estate such as Horsley Court and its business lounge with appropriate image descriptions. They said the website was a multi-purpose site and the home page image was wholly appropriate as it was where a lot of the events and weddings took place. They said that they would add an additional qualification to their home page “When it’s time to unwind, our collection of modern bedrooms await, whether you choose to stay in the historic towers or the contemporary Horsley Place.”

During the investigation Principal Hotel Company agreed to amend their advertising to include emboldened text alongside each of the room listings that stated the room type locations and on the website’s booking engine.



The ASA noted that the ad featured the headline “De Vere Horsley Estate. A striking 19th century mansion house in the heart of the Surrey countryside” alongside a large photo of the mansion house. In the absence of additional information to indicate otherwise, we considered consumers would understand that, should they make a booking, they would stay in the advertised mansion house.

We noted a series of images under the tab “Rooms” found at the top of the website’s home page, provided descriptions of the hotel’s guest rooms and stated that they were located in Horsley Place, which we understood was separate to the advertised mansion house. However, we considered that text was not particularly prominent and consumers were unlikely to understand without further information that Horsley Place was separate to the mansion house.

We noted there were no images of Horsley Place attached to the guest room listing and there was only one external picture on the website, which was a bird’s eye view that also included the mansion house. Although Horsley Place was mentioned in a caption beneath the photo, it was not clear which building it referred to and there were no photos of what the building looked like from the ground.

Because the majority of photos on the website were of the mansion house, with no external photos of Horsley Place beyond the bird’s eye photo and limited indication that the guest rooms were not located in the mansion house, we considered that consumers would understand that the guest rooms would be in the mansion house. Because that was not the case, we concluded the ad was likely to mislead.

The ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  and  3.3 3.3 Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, the  medium and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means.
 (Misleading advertising) and  3.9 3.9 Marketing communications must state significant limitations and qualifications. Qualifications may clarify but must not contradict the claims that they qualify.  (Qualification).


The ad must not appear again in its current form. We told Principal Hotel Company to prominently state if rooms were not in the mansion house.

CAP Code (Edition 12)

3.1     3.3     3.9    

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