Advertisment
The advertisement was seen both on television and ahead of screenings of ‘A Haunting in Venice’ and ‘Five Nights at Freddy’s’ in the cinema. The commercial depicted various young adults in differing situations such as in a supermarket, sitting on a couch, at a basketball court, in a bar, in a café, and in a laundromat, each one using the 888 application on their smart phones. Onscreen animations detailed the various elements which could be bet on via the application, such as virtual slot machines and roulette wheels, as well as sport such as football, horse-riding, ice hockey and card games.
A voiceover stated:
“Dive into the 888 experience…because it’s made to blow minds!
It’s made to unwind!
It’s made to excite!
It’s made to unite!
It’s made for the newbies…and for the OGs!
It’s made for YOU!”
At this point, one of the actors interjected and stated, “It’s just made to play!”, to which the voice over responded, “Yeah, that works!”.
The advertisement ended with a depiction of the brand logo on a graffitied background reading, ‘888 – Poker, Casino, Sport’ as well as the strapline ‘Made to Play’.
The 18+ symbol and ‘BeGambleAware.org’ web address was located on the top right of the screen throughout the commercial.
Complaint
Three complaints were received against the advertisement with three issues being identified.
Issue 1:
The complainants saw the advertisement in the cinema before the films ‘A Haunting in Venice’ which had a 12A IFCO film classification and ‘Five Nights at Freddy’s’ which had a 15A IFCO film classification. They considered that the advertisement could be seen to target children as it was broadcast before films well beneath the 18 years old IFCO film classification.
Issue 2:
The complainant considered that as the advertisement depicted young people appearing to play games on their smartphones as opposed to betting, this made it difficult to ascertain that the advertisement was promoting a gambling service and that this could appeal to children.
Issue 3:
A complainant saw the advertisement on television. They felt that the advertisement gave the impression of promoting gambling as safe and a fun way to relax. The complainant objected to the impression created and said that as gambling was addictive, it was never safe.
Response
The advertisers reverted and addressed each complaint individually.
Issue 1:
In relation to the first issue, the advertisers said that the Cinema Advertising Association Ltd. (CAA) restricted the ‘888 Casino Hero – 60’ advertisement via the Gambling Route.
They explained that the Gambling Route corresponded with ASA Code section 10.17 (g) which stated ‘Marketing Communications should not; Be directed at those aged below 18 years through the selection of media or context in which they appear, or be placed in or through media, or parts of media, that are specifically intended for children (inserts, supplements, special (radio and TV) programmes, cinema films, etc.)’.
The advertisers clarified that the Gambling Route ensured that no gambling advertisement could accompany feature films attracting a national audience profile of more than 25% under-18s. They said that the CAA would therefore state that they deemed the advertisement was compliant with the gambling section of the ASA Code. The advertisers provided a letter from the CAA as confirmation of their approval.
Regarding ‘A Haunting in Venice’, the advertisers said that this film was profiled against ‘Death on the Nile’. They said that this had an 18+ profile of 91% and so was deemed suitable for inclusion in this package.
The advertisers explained that to estimate the expected audience profile of ‘Five Nights at Freddy’s’, the 18+ profile of multiple films in that genre were assessed, which all had a profile far above the minimum requirement of 75% over 18s.
They said that the film they felt most suitable as an indicator of the audience split (‘M3gan’), had an audience of 94% over 18s. The advertisers said that therefore, according to the assessment, the advertisement was scheduled in compliance with the Gambling section of the ASA Code.
Issue 2:
The advertisers did not specifically address this issue.
Issue 3:
The advertisers said that the television commercial was approved by the television channel’s Copy Clearance. The advertisers provided email confirmation of this approval from the channel’s Copy Clearance.
They did not provide comments regarding the issue that the advertisement created the impression that gambling was a safe and fun way to relax.
Conclusion
The Complaints Committee considered the detail of the complaints and the advertisers’ response.
The Committee noted the Code requirement that marketing communications should not be directed at those aged below 18 years through the selection of media or context in which they appear, or be placed in or through media, or parts of media, that are specifically intended for children (inserts, supplements, special (radio and TV) programmes, cinema films, etc.) (10.17(g)).
Issue 1 – Not Upheld.
The Committee noted the audience profiles provided for both films which demonstrated that each film had an audience profile of over 90% 18+. In light of this, the Complaints Committee did not consider that the advertising was targeted towards children and therefore did not consider that the advertisement breached the Code on the basis suggested in the complaints.
Issue 2 – Not Upheld.
The Committee noted the advertisement featured various casino games such as poker and a blackjack wheel and used the term “Made to play” both in voiceover and on screen. While the Committee also noted the details provided in regard to the placement of the cinema advertisement, and how it was approved to air during both movie screenings, they noted that no response had been provided on this aspect of the complaint. Notwithstanding this, the Committee considered that smartphone use was increasingly commonplace, and that while the depiction of people playing games on their smartphones could attract children’s attention, they considered that it was clear that the games being depicted were gambling. The Committee also did not consider that the content was such as to be of particular interest to children. On this basis, they did not consider that the advertisement was in breach of the Code on the basis suggested in the complaint.
Issue 3 – Not Upheld.
In relation to the issue raised that the advertisement gave the impression that gambling was a safe method of recreation, the Committee noted that this issue was not addressed in the response. The Committee considered that care was required to ensure that advertising for gambling products did not depict gambling as recreational or an escape from problems. They noted that in line with the Code requirements, the advertisement featured a source of information about gambling and gambling responsibly for viewers, as well as an 18+ symbol. While noting that the advertisement depicted the app users as relaxed and enjoying themselves individually, on balance, the Committee did not consider that the advertisement breached the Code at the issue raised in the complaints.
ACTION REQUIRED:
No further action required. The Complaints Committee advised continuing care to ensure that advertising for gambling products did not depict gambling as an escape from problems.
