A cinema ad for Responsible Gambling Trust, seen in February 2017, showed a young woman sitting on her bed while an older man sat on a desk in the corner of the room. The older man said, in a sinister and menacing way, “What is it? What is it? It’s just a bit of fun. Hey [laughs] it’s just a bit of fun. It’s just a bit of fun. Remember that rush. The best feeling you’ve ever had. Your words, it was perfect, you said it was. It was 10 out of 10; it was 100 out of 100. You tingled, you tingled. Your whole body was tingling. Don’t tell me you don’t remember that, you remember that, you remember every second of that. You of all people need to have a little bit of fun. Fun … fun … fun. You are a great winner; I’m not just saying that. I’m saying it, you’re a great winner. [Laughs] You and me let’s go, let’s do it again, let’s do it again. You love it there, I love it there; you always win there. You’re a winner there, you and me now. That place that you’ve never felt so good.” During the monologue close up shots focused on his eyes and mouth. After the monologue, the girl went over to the desk where the man had disappeared and a laptop was revealed in his place. On the screen a bingo game was shown and she appeared to sign in and play. Large text then stated “BeGambleAware.org”.
The complainant, who believed the role of the male character could be interpreted as predatory and sexually abusive, objected that the ad was likely to cause offence and distress.
Responsible Gambling Trust t/a BeGambleAware said they provided a brief to agencies where they insisted on safeguards including testing the ad with the target age range (15- to 24-year olds) to give assurance that the ad did not inspire viewers to gamble, or was too unnerving and therefore would obscure the message, or to be mistaken for ads against gambling, rather than about the risks of problem gambling. They said in the light of the classifications given by British Board of Film Classification (BBFC) and Cinema Advertising Agency (CAA), they decided to target only 18s or over with the ad. They said they deliberately only agreed to show the ad in cinemas before the film ‘Trainspotting 2’, an 18+ rated film about hard drug addiction.
They said while it was uncomfortable to watch, the “Voices” campaign was designed to stick in consumers’ minds (as with other hard-hitting public awareness campaigns such as Talk to Frank, DrinkAware, anti-smoking campaigns, etc.) in order to resonate and raise awareness/be effective in the long term. They believed the campaign personified one’s “inner demon” – a voice that told an individual to carry on when they should stop, that they were lucky, that they were special. This inner voice was depicted as the same character across their advertising: “Machine” – showed a young man fighting internally with a fruit machine in a sociable environment; and “Online” – which showed a woman battling against the urge to gamble online in her bedroom.
They said that the menacing character in question was a figment of his victims’ imagination (something which became clear at the end when he disappeared to reveal the object of their distraction – the online Bingo app) and, as such, he was not, on a literal level, a physical entity, but a metaphor for the insidious, corruptive nature of a creeping, nagging gambling problem.
They explained the character was the same in both ads, so the parallel being drawn with sexual corruption was likely based on the fact that an older man featured in a scene with a younger girl. They believed the complaint spoke to both the sex and age prejudices that exist in people’s minds, sensitivities that had been heightened by recent media exposure. They questioned whether the complaint would have been made if the character was a woman. They believed the ad might challenge perceptions, and in doing so draw additional focus on a dark and hidden addiction. They said the ad did not directly intend to cause offence, nor was this in the design of the script.
They said the speech was crafted to convey the deeply personal and destructive persuasiveness of addiction – in each ad, adapted to play on the vanities and insecurities of the victims. The physicality and ambiguity of the language led the viewer to draw their own conclusions – a mechanism designed to create cut-through. However, given the context of the wider ad and the reveal at the end, they believed it was not overly misleading or inappropriate. They said when considered alongside the second ad in the campaign it was clear that the content related to problem gambling, not sexual abuse and that this was resolved within the ad with the BeGambleAware.org reveal at the end. They argued that public awareness about problem gambling justified and outweighed any potential for offence that might be caused.
They also provided a statement issued by the BBFC about the content of the ad which said “In the public information film a woman lies on a bed in a sparsely furnished, rather bleak bedroom as a man sits on a desk, which is set back from the bed. The two characters do not have any physical contact and only the man speaks. The man encourages the woman to gamble by persistently reminding her of the buzz it offers and by suggesting that she deserves a little bit of fun. The woman is conflicted as to whether or not to give into her desire to gamble. Whilst she is reluctant, worried and nervous at the beginning, following the man's persistent exhortations, she smiles, puts aside her qualms, opens her laptop (which appears where the man was seated), and logs onto an online gambling site. The suggestion of inner turmoil and conflicted feelings on her part, as well as some slightly creepy aspects to the man's monologue on the pleasures of gambling mean the film was most appropriately placed at PG for the mildly unsettling tone and for the suggestion of addiction-related psychological turmoil. The BBFC also noted that the film contains a strong anti-gambling message.”
The Cinema Advertising Association said they approved the ad on the condition of its being restricted to screening with 12A films and above. They said they were aware of the unnerving tone created by the presence of the man seated on the desk, together with the nature of his monologue which they believed was redolent of intrusive seduction. They said they believed the viewer would initially interpret the situation or “seduction” as sexual, emphasised by the bedroom setting and the demeanour of the teenager who adopted a defensive, foetal position. They said they believed more mature children would be likely to understand the parallel the ad sought to draw between sexual seduction and what can be the self-seductive reaction to having the odd win on a gambling site. They believed, however, that children younger than 12 would have to have an adult on hand who could explain the complexity of the content. They believed this rationale was supported by the ubiquity of online gambling and the relative ease with which teenagers online can pretend to be older than they really are in order to access gambling sites.
They felt that the warning the ad conveyed about being drawn into online gambling was sufficient justification for the degree of distress that might be caused. They also believed that although some small number of viewers may feel offended by the parallel drawn between sexual seduction and being seduced by the thrill of an early win on a gambling site, that offence would be neither serious nor widespread. They believed the ad sought to get its important ‘gamble aware’ message across by highlighting the commonality of innocence and ignorance on the part of a young, novice gambler and that of a target for a sexual predator.
They also noted that the ad received a BBFC certificate ‘PG’. They said they had not received any complaints to date about the ad.
The ASA considered that until the reveal in the final moments of the ad, viewers were unlikely to understand what the ad was promoting. We considered that, after the reveal, most viewers would understand that the male character was a metaphor or representative of an inner monologue. We noted that the advertiser’s intention was to demonstrate a woman in her bedroom battling against the urge to gamble online, but we considered that for much of the ad this purpose was ambiguous and unclear.
We acknowledged the CAA’s view that there were parallels drawn between sexual seduction and being seduced by the thrill of an early win on a gambling site. That view was supported by the threatening and coercive language used, the predatory manner by which the monologue was delivered and the female character’s positioning and behaviour, indicative of fear and shame. However, we considered that up until the reveal there was no information or other explanatory features in the ad that would provide the viewer with context for why they were viewing what they were viewing. We considered that, because of the lack of context, the ad reproduced a scenario of abuse. We considered that viewing such a scenario of abuse, notwithstanding the use of metaphor and the fact the ad was only seen before the film 'Trainspotting 2' which was about drug addiction, was likely to cause serious or widespread offence.
We also considered that viewers would find the sexually coercive and abusive scenario shocking and distressing and that victims/survivors of abuse would find the ad highly distressing and/or traumatic. We did not consider that the advertiser’s intention (as presented in the ad) justified the distress experienced by viewers generally, and the distress caused to this vulnerable group in particular.
We therefore concluded that the ad was offensive and breached the Code.
The ad breached CAP Code (Edition 12) rules
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. and 4.2 4.2 Marketing communications must not cause fear or distress without justifiable reason; if it can be justified, the fear or distress should not be excessive. Marketers must not use a shocking claim or image merely to attract attention. (Harm and Offence).
The ad must not appear again in its current form. We told Responsible Gambling Trust to avoid using similarly offensive and distressing material in their future advertising.