Background

Summary of Council decision:

Eight issues were investigated, all of which were Upheld.

Ad description

Three websites for pay-per-bid auction site, Swoggi, seen on 2 August 2016:

a. The home page of the main website, www.swoggi.co.uk, featured a list of live auctions, including the Barbecue Weber 57cm which stated the current bidding price at £0.63; the Senseo Touch 3D Electric shaver - Philips, which stated “Price … £0.43 (instead of £285.00)”; and Blender Morphy Richards, which stated “Price … £0.01 (instead of £40.00). The listings on the home page were linked to the individual product pages, which stated the current bidding prices and “worth up to: £90” for the barbecue, “worth up to: £285.00” for the electric shaver, and “worth up to: £40” for the blender.

The page titled “About Us” included a “Contact us” section which showed an address in the UK.

b. A website named “MoneyExpert£”, ww2.moneyexpert360.com/conso/, was headed “How to save up to 80% on retail price”. The home page featured a link to an article, titled “CAN YOU REALLY SAVE UP TO 90% ON BRAND NEW IPHONE 6, IPAD AIR 2 AND MACBOOKS?” The article stated that some journalists had investigated what pay-per-bid auction sites were, some of the deals they had found on Swoggi and the discounts that could be obtained. The article also included the text “Use the following voucher code to get 50 free credits! Code: AUG50. Offer will expire soon, hurry up!” and included a link to the Swoggi home page. Small text in grey at the bottom of the page stated “Please note that this page is an Advertorial. Even if what is related is true and reflecting the benefits of the website”.

c. The website partner.swoggi.co.uk, which was linked to the MoneyExpert£ website, displayed a sign-up page for Swoggi. It featured a carousel of product images for a KitchenAid standing electric mixer with text that stated “sold for: £39.00 BEST PRICE GUARANTEED”; iPhone 6s with text that stated “sold for: £29.00 BEST PRICE GUARANTEED”; iPad Air 2 with text that stated “sold for: £19.00 BEST PRICE GUARANTEED” and a Nikon D5300 with text that stated “sold for: £49.00 BEST PRICE GUARANTEED”. The top of the page displayed logos of the Mirror, the Independent and the Times newspapers, with text that stated “Signup [sic] for FREE”. Further text at the bottom of the page stated “1 Choose your product > 2 Click on Bid > 3 Nobody outbids you? At the end of the timer, you win the auction!”

Issue

The ASA challenged whether:

1. the “instead of” and “worth up to” price claims in ad (a) were misleading and could be substantiated;

2. the claims “how to save up to 80% on retail price”, “save up to 90% on brand new iphone 6, ipad air 2 and Macbooks” and “discounts, which can go up to 90% of the retail value” in ad (b) were misleading and could be substantiated;

3. the claimed prices at which the items featured in ad (b) were sold for and the “sold for” prices in ad (c) were misleading and could be substantiated;

4. Ad (a) was misleading, because it did not make clear their geographical address in Singapore;

5. ads (a) and (c) were misleading, because they did not make clear the nature of the service offered by Swoggi, or the cost of individual bids and credit packages;

6. ad (b) was obviously identifiable as a marketing communication, because it was presented as an article written by an independent third party;

7. the claim “Code: AUG50. Offer will expire soon, hurry up!” in ad (b) was misleading because the same offer was repeated on a monthly basis; and

8. the use of the logos of The Mirror, The Independent and The Times newspapers in ad (c) misleadingly implied that Swoggi was endorsed by those publications.

Response

1. Sophora Media Ltd t/a Swoggi stated that they based their “instead of” and “worth up to” price claims in ad (a) mostly on Apple products and the standard prices listed on the Apple website. They further stated that in general, if a product was available on the Amazon website, they would quote the RRP price listed on Amazon for that product accordingly. They might also refer to the prices quoted on the manufacturers’ websites, if that information was available.

They provided a screenshot of Google search results which detailed some of the prices offered by online retailers, for the Weber Barbecue featured on the Swoggi website, and a Braun epilator. They did not provide any documentary evidence in relation to the Morphy Richards blender.

2. Swoggi provided a spreadsheet, which covered the period from February to August 2016 and which included details of the auctions such as the products won, the retail value of the products/prices on which the “instead of” and/or “worth up to” price claims were based, the amounts of bid credits paid by the auction winners, the total costs paid by the auction winners and the percentage of savings achieved by the winners. They stated that the spreadsheet demonstrated that more than 10% of customers were able to achieve the claimed “up to” discounts.

3. Swoggi provided screenshots of the closed auctions for a KitchenAid standing electric mixer, an iPhone SE 16GB, an iPad Pro 32 GB and a Canon Powershot SX400 camera, as listed on their main website www.swoggi.co.uk.

Swoggi stated that the claimed prices at which the items featured in ad (b) were sold for and the “sold for” prices in ad (c) did not take into account delivery costs, because they had not charged delivery costs for UK clients since March 2016.

4. Swoggi explained that the UK company was 100% owned by the company based in Singapore and that they used the address for the UK company on their website for marketing purposes.

5. Swoggi explained that the cost of individual bids varied; the cost of bids was usually £0.50 each, but it could be £0.00 for VIP auctions. They provided partial screenshots of a product auction listing on the home page, which stated “£0.50 15 seconds” underneath the live auction price, and of the individual auction page, which showed the same text under the live countdown timer. They also provided a partial screenshot of a web page which set out the different credit packages and the associated costs.

6. Swoggi said the article titled “CAN YOU REALLY SAVE UP TO 90% ON BRAND NEW IPHONE 6, IPAD AIR 2 AND MACBOOKS?” in ad (b) was an advertorial sponsored by Swoggi.com as stated at the bottom of the page. They also referred to another article on the website titled “Can you really save up to 90% on brand new iPhone6s, iPad Pro and macbooks [sic]?” They also stated that this article was an advertorial sponsored by Swoggi.com, which was stated at the top of the page.

7. Swoggi stated that the amount of credit offered differed, on average, every two to three months, while the coupon offer code changed every month for the ease of users.

8. Swoggi stated that their advertorial communications had appeared on all three newspaper websites. They said that they were no longer active on those newspaper websites and could only provide partial screenshots of those advertorials. They provided tracking figures from their network platform, which they stated showed those newspapers were advertising for the Swoggi website from February to August 2016.

Assessment

1. Upheld

The ASA considered that consumers were likely to understand that the “instead of” prices included in most of the live auctions listed on the home page, and the “worth up to” price claims on the individual auction pages in ad (a), represented the prices at which the featured products were generally sold across the market by other retailers at the time the ad was seen. For example, we considered that consumers were likely to expect from the claim “Instead of £285.00” on the home page, and “Worth up to: £285.00” on the individual auction page, made in relation to the Phillips 3D SenseoTouch 3D Electric Shaver that the product had been generally sold across the market at £285.

For the examples of the Barbecue Weber 57cm and the Senseo Touch 3D Electric shaver - Phillips, we noted that Swoggi had carried out an online search of the products on Google to ascertain the prices at which other retailers were selling the items. For the Barbecue Weber 57cm, we noted that the screenshot included seven prices listed on Google shopping. However, it was unclear whether the prices shown related to the particular model of barbecue advertised on Swoggi, as we understood that there was more than one model by the same manufacturer that was 57 cm in grate size. We considered that the evidence provided was not sufficiently robust to show that the barbecue advertised and auctioned on Swoggi had been generally sold across the market at £90.

In relation to the Senseo Touch 3D Electric shaver - Phillips, we noted that the screenshot of the Google search results, which included some of the prices displayed in Google shopping that ranged from £106.99 to £120.60, were conducted for the product Braun Silk-epil 9 Skin Spa Wet and Dry Epilator. Because the evidence submitted did not relate to the product advertised, we considered that it was inadequate to demonstrate that the shaver advertised was generally sold across the market at £285.

In relation to the example of the Morphy Richards blender, we noted that Swoggi had not provided any documentary evidence to support the “instead of” and “worth up to” price claims. We further noted that the blender was no longer available for sale on the market and therefore it would not be possible to demonstrate the price at which the product was generally sold. On that basis, we considered that the “instead of” and “worth up to” claims for the product had not been substantiated.

For the above reasons, we considered that Swoggi had not provided adequate documentary evidence to demonstrate that the “instead of” and “worth up to” prices made in relation to the products sold, were the prices at which they were generally sold across the markets by other retailers. We therefore concluded that the claims were misleading.

On that point, the ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  (Misleading advertising),  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation),  3.17 3.17 Price statements must not mislead by omission, undue emphasis or distortion. They must relate to the product featured in the marketing communication.  (Prices) and  3.40 3.40 Price comparisons must not mislead by falsely claiming a price advantage. Comparisons with a recommended retail prices (RRPs) are likely to mislead if the RRP differs significantly from the price at which the product or service is generally sold.  (Price comparisons).

2. Upheld

We considered that consumers were likely to understand the claims “how to save up to 80% on retail price”, “save up to 90% on brand new iphone 6, ipad air 2 and Macbooks” and “discounts, which can go up to 90% of the retail value” in ad (b), to mean that they would always be able to achieve savings, and in some circumstances, they could obtain 90% savings, including for the products referred to in the claims. We further considered that references, such as “Swoggi is so confident that you will get these discounts that they provide voucher codes for free credits …”, further reinforced that impression. We also considered that consumers were likely to expect from the wording “retail price” and “retail value” in the claims that the claimed savings were based on the prices at which the products were generally sold across the market.

We noted from the sales data provided that Swoggi’s calculations on the percentage of savings achieved by customers had been based on the total cost of the auction price and the costs of bids that they had used to bid, against the ‘retail value’/RRPs of the products. While the data indicated that approximately 33% of all customers had achieved savings of 90% or more, we noted that some customers had not obtained any discounts at all. Further, we had not seen any evidence to demonstrate that the RRPs on which the savings claims had been based were prices at which the products had been generally sold across the market.

For the above reasons, we considered that the claims “how to save up to 80% of the retail price”, “save up to 90% on brand new iphone 6, ipad air 2 and Macbooks” and “discounts, which can go up to 90% of the retail value” in ad (b) had not been substantiated and concluded that they were misleading.

On that point, the ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  (Misleading advertising),  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation),  3.17 3.17 Price statements must not mislead by omission, undue emphasis or distortion. They must relate to the product featured in the marketing communication.  and  3.22 3.22 Price claims such as "up to" and "from" must not exaggerate the availability or amount of benefits likely to be obtained by the consumer.  (Prices), and  3.40 3.40 Price comparisons must not mislead by falsely claiming a price advantage. Comparisons with a recommended retail prices (RRPs) are likely to mislead if the RRP differs significantly from the price at which the product or service is generally sold.  (Price comparisons).

3. Upheld

We noted ad (b) included the following claims: “An iPad Air 2 for £30, or an iPhone 6 for £40”; “So they joined an auction for the iPad … to win it for only £57.76”; “A brand new, still under warranty Apple iPad Air 2 … for less than £60”; and “the iPad Air 2 at only £91.04”. Ad (c) included the following claims: “Sold for £39.00” for the KitchenAid mixer; “Sold for £29.00” for the iPhone 6s; “Sold for £19.00” for the iPad Air 2; and “Sold for £49.00” for the Nikon D5300. We considered that consumers were likely to understand that the prices stated in those claims represented the total amounts that successful bidders had paid in order to win those items in previous auctions, and that they would have a reasonable chance of making comparable savings if purchasing that item, or similar, in future.

Because we understood that consumers were required to purchase bids in order to participate and therefore additional costs were applicable, and it would be possible for Swoggi to calculate the cost of the bids placed given that the claimed “sold for” prices would have been based on closed auctions, we considered that the additional costs of purchasing the bids should be incorporated into the those “sold for” prices.

We noted that Swoggi provided screenshots of the closed auctions for a KitchenAid standing electric mixer, an iPhone SE 16GB, an iPad Pro 32 GB and a Canon Powershot SX400 camera, as listed on their main website www.Swoggi.co.uk. We considered that those were insufficient to demonstrate that the “sold for” prices for the products advertised reflected the full costs borne by the successful bidders, and in any event, they did not relate to the products for which the prices claims in question were made.

Because we considered that evidence submitted was inadequate to show that the “sold for” prices represented the total amounts that successful bidders had paid in order to secure the items, we concluded that the “sold for” prices claims were misleading.

On that point, the ads 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),  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation),  3.17 3.17 Price statements must not mislead by omission, undue emphasis or distortion. They must relate to the product featured in the marketing communication.  and  3.18 3.18 Quoted prices must include non-optional taxes, duties, fees and charges that apply to all or most buyers. However, VAT-exclusive prices may be given if all those to whom the price claim is clearly addressed pay no VAT or can recover VAT.  Such VAT-exclusive prices must be accompanied by a prominent statement of the amount or rate of VAT payable.  (Prices).

4. Upheld

We noted that the prices on the Swoggi website, which was a ‘.co.uk’ website, were quoted in British pounds sterling. We also noted the address listed on the ‘Contact us’ page, and also in the terms and conditions, was an address in London. While the top of the website included small text that stated “Swoggi international” and displayed various flag icons, including the Union Jack, we considered that consumers were likely to understand from the above elements that Swoggi was a UK based company.

We understood that Sophora Media Ltd was a UK registered company. Notwithstanding that, we noted the UK address listed in ad (a), which was the registered office address at the time the ad was seen, was a virtual office address with a mail forwarding service, and that Swoggi conducted its operations from Singapore.

Because the website gave an overall impression that Swoggi was a company based in the UK, and because we understood that this was not the case, we concluded the ad was misleading.

On that point, the ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.    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.
   3.4 3.4 For marketing communications that quote prices for advertised products, material information [for the purposes of rule 3.3] includes:  and  3.4.2 3.4.2 the identity (for example, a trading name) and geographical address of the marketer and any other trader on whose behalf the marketer is acting  (Misleading advertising).

5. Upheld

We considered that the prominent banner at the top of the home page in ad (a), which stated “1 I register 2 click on the register I’m interested in 3 I win”, was likely to give an overall impression that consumers would be able to bid on auction items as soon as they had registered for an account without having to pay additional costs. We noted that text “£0.50 15 seconds” was stated underneath the live auction prices of the items listed at the top of the home page, and underneath the live countdown timer on which individual auction page. However, we considered that because the font size of that text was very small relative to surrounding text, it was likely to be missed by consumers. Further, in the absence of any other information relating to the costs of bids on those pages, we considered that it was unclear what “£0.50 15 seconds” referred to in context, and therefore was unlikely to counter the impression that consumers would only need to register with Swoggi before bidding for items, without any attached costs.

In relation to ad (c), we noted that the banner positioned below the product image set out the three steps “1 Choose your product > 2 Click on Bid > 3 Nobody outbids you? At the end of the timer, you win the auction”. While text at the top of the page stated “Free Bidding with VIP auction”, we considered that without any other information included on the page, we considered that consumers were likely to understand that they would only need to follow those steps to bid on auction items straightaway and that no additional costs would apply.

We noted Swoggi’s comments that the cost of an individual bid was usually £0.50 and it could be £0.00 for VIP auctions. The partial screenshot of a page on the Swoggi website which they provided was of a page that set out the cost of various credit packages, and which was only accessible after consumers had registered for an account. That page indicated that there were two non-VIP credit packages: £15 for 30 credits; and £28 for 56 credits. There were also VIP credit packages which ranged from £50 for 100 credits to £300 for 600 credits, with varying numbers of additional ‘bonus’ credits that consumers could use in ‘free’ VIP auctions, depending on the costs of the corresponding VIP credit packages.

We considered that information about the nature of Swoggi’s service, the costs of individual bids and credit packages was material information that consumers required in order to make an informed decision about whether or not to participate in Swoggi’s auctions, and therefore should have been presented sufficiently clearly in the ads before consumers proceeded to sign up for an account. Because such information was not available to consumers until after they had registered with Swoggi, we considered that both ads (a) and (c) were misleading.

On that point, the ads 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  3.18 3.18 Quoted prices must include non-optional taxes, duties, fees and charges that apply to all or most buyers. However, VAT-exclusive prices may be given if all those to whom the price claim is clearly addressed pay no VAT or can recover VAT.  Such VAT-exclusive prices must be accompanied by a prominent statement of the amount or rate of VAT payable.  (Prices).

6. Upheld

We noted that ad (b), which was a website named MoneyExpert£, featured different sections titled ‘Saving tips’, ‘New trends’, ‘Health’, ‘Shopping’ and ‘Travel’. The website also contained a number of articles titled, for example, “An iPad 80% off: my experience on the auction site Swoggi” and “Can you really save up to 90% on brand new iPhone 6, iPad Air 2 and MacBooks?”, the content of which referred to the Swoggi website. It also included articles that appeared to provide general tips, such “Our 5 safe weight loss tips” and “5 Tips to save money on your holidays”. The website also featured a prominent graphic, with text that stated “COMPANY REVIEWED swoggi CONSUMER RATING 4.2 BEST Possible 5.0 OFFICIAL RATING of Money Expert 360”. We considered that the above elements gave an overall impression that the website was an independent consumer affairs news and advice website. We further noted that articles that referred to Swoggi, for example one that was titled “CAN YOU REALLY SAVE UP TO 90% ON BRAND NEW IPHONE 6, IPAD AIR 2 AND MACBOOKS”, included references that conveyed the experience of some journalists investigating ‘auction’ sites and using Swoggi for the first time. Those included “But the prices advertised seems too good to be true, so some journalists investigated these new sites … After researching which one of the different competitors to test, they came to the conclusion that Swoggi seemed to be the best candidate”, “Once journalists registered, a very simply and quick process, they received their free credits, and started to look at the current auctions” and “Journalists started out this test as a sceptic, but … they can say without a doubt that this new form of online shopping is a GREAT way to save money”. We considered that those references further reinforced the overall impression that the website was an independent, third-party consumer news site and that the articles about Swoggi were genuine reviews written by journalists.

We noted Swoggi’s comments that individual articles which promoted their website contained text above and/or below the article content stating that those were advertorials. For example, the article titled “How to save up to 80% on retail price” included text above the heading that stated “Sponsored Content Provided By Swoggi Advertorial”, with further text in grey below the article that stated “Please note that this page is an Advertorial. Even if what is related is true and reflecting the benefits of the website”.

However, we noted that the home page did not contain any indications that any of the articles which promoted Swoggi were ads. In addition, we considered that the text that stated the articles were ‘Advertorials’ were likely to be missed by consumers when they clicked through from the home page, as the font size of that text was very small. We did not consider they were sufficient to counteract the overall impression that the website and the articles were independent editorial piece written by an independent party.

Further, we noted Swoggi’s comments that those ‘Advertorials’ were content sponsored by them. However, we noted that Swoggi appeared to have full control of the MoneyExpert£ website, as all clickable links on the website directed users to the main Swoggi website, the contact email address given was a Swoggi Support email address and the terms and conditions for the website were identical to those found on the main Swoggi website. Notwithstanding that certain articles on the MoneyExpert£ website had been labelled as ‘Advertorials’, we considered that the way ad (b) had been presented implied that they were acting for purposes outside their trade and profession, and that the ad was not obviously identifiable as such. We therefore concluded that ad (b) was in breach of the Code.

On that point, the ad breached CAP Code (Edition 12) rules  2.1 2.1 Marketing communications must be obviously identifiable as such.  and  2.3 2.3 Marketing communications must not falsely claim or imply that the marketer is acting as a consumer or for purposes outside its trade, business, craft or profession; marketing communications must make clear their commercial intent, if that is not obvious from the context.  (Recognising marketing communications).

7. Upheld

We considered that consumers were likely to understand the claim “Code AUG50, Offer will expire soon, hurry up!” to mean that the offer of 50 free credits was time-limited and that it would be available for the month of August (at the time the ad was seen), after which the voucher code would expire. We therefore expected to see documentary evidence to demonstrate that the offer in question was only available for that particular month.

We noted Swoggi’s comments that the amount of free credits in the offer differed every few months and that they changed the voucher code every month. However, we noted that the same offer of 50 free credits remained for five months after the ad was originally seen, and that we had not received any documentary evidence showing that the offer had been time limited. Because we considered that consumers were likely to understand from the claim that the offer would only be available for the duration of August, and that we had not seen any documentary evidence to demonstrate that this was the case, we concluded that the claim was misleading.

On that point, the ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  (Misleading advertising) and  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation).

8. Upheld

We considered that consumers were likely to understand the use of the logos for the Daily Mirror, the Independent and the Times newspapers in ad (b) to mean that the Swoggi website had been independently reviewed and recommended, or endorsed, by those newspapers in editorial content.

We noted Swoggi’s comments that their website had been featured in those newspapers in advertorials. We also noted that their evidence consisted of partial screenshots of the advertorials that they referred to, and data indicating user traffic generated from advertising on some of the newspaper websites in question. However, we did not consider that the evidence submitted adequately demonstrated that the Swoggi website had been independently reviewed and recommended, or endorsed, by the Daily Mirror, the Independent and the Times newspapers. We therefore concluded that the use of those logos in ad (b) was misleading.

On that point, the ad breached CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.  (Misleading advertising) and  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation)

Action

The ads must not appear in their current forms again. We told Sophora Media Ltd t/a Swoggi to ensure that material information, such as the costs of individual bids and credit packages, the nature of their service, the delivery costs, and their geographical address, were made clear in their ads. We also told them to ensure they did not make “instead of” or “worth up to” price claims that were likely to be understood as the prices at which the products were generally sold; savings claims that were based on ‘retail’/RRP prices; “sold for” prices that were likely to be understood as the final price that successful bidders had paid; claims regarding expiry of offers; and claims that implied they were endorsed by the Mirror, the Independent and the Times, unless they held adequate evidence to substantiate them. We also told them to ensure that their ads did not imply that they were acting for purposes outside their trade and profession, and that ads should be made identifiable as such.

CAP Code (Edition 12)

2.1     2.3     3.1     3.17     3.18     3.22     3.3     3.4     3.4.2     3.40     3.50     3.7    


More on