Advertisment
A video on the advertiser’s YouTube channel featured a man building a bet using the ‘Bet Builder’ feature.
MVO: The first bet builder of the new football season is here, and Josh built his, his way.”
The character ‘Josh’ is shown sitting on park bench looking at odds on his phone. His dog is beside him spinning around. The scene moves to a woman sitting at two computer screens looking at data, she’s on the phone to someone via a headset. She says, “All this data points to….”
Josh is then shown in a supermarket shopping, on the phone to someone: He says “Doncaster?”
A woman at the end of the aisle behind him, shouts “I’m from Doncaster!”
Josh is then shown lying on an examination table in a hospital/doctor’s surgery, a doctor is examining his stomach. He asks the doctor, ‘how’s my gut feeling?’
The Doctor says, “very reliable”.
Josh is then shown in a kitchen with his parents, he says “I’ve got some difficult news, I’m betting on us to lose. Have you seen the odds?”
The woman whispers ‘traitor’.
Josh is then shown parachuting out of an airplane.
MVO – “whatever lengths you go to to build your bet builder”
Josh is looking at a football pitch via binoculars while freefalling through the air.
He says, “I knew it, he’s not match fit”. He then uses his phone to make or amend a bet.
MVO – “we give you a free bet for first 3 weeks of the premier league. That’s Ladisfaction from Ladbrokes.”
An on-screen footnote included the following:
“1 Free Bet per week per player”.
The Video Description
“Whatever lengths you go to…
You build your Bet Builder; we give you a free bet – that’s Ladisfaction!
18+. Terms and conditions apply.”
Complaint
The complainant considered that the advertisement was portraying an obsessive user of the product as a satisfied customer by pairing the narrative and imagery of the advertisement with the phrase “whatever lengths you go to”, which they considered was irresponsible and inappropriate for a gambling product and they also considered that the bet featured, a bet builder, was encouraging users to continuously gamble and the offer of a free bet was encouraging users to use the bet builder.
Response
The advertisers said that for many, part of the appeal of having a bet was the thought process involved in making a selection with everyone having their own unique way of doing it. They said that the advertisement played on that in a light-hearted way by showing some of the steps the character Josh took or considered when making a selection. They said that given that some of these steps included going to a doctor to check on his “gut feeling” and jumping out of plane with a parachute to spy on a team’s training session in order to assess whether a player was match fit, the tongue-in-cheek tone was obviously a comic exaggeration and tied into the “whatever lengths you go to” strapline used.
They said that the strapline plus the overall tone of the advertisement was there to emphasise enthusiasm for engaging in the Bet Builder feature, not to encourage excessive gambling. They clarified that Bet Builder was a feature that allowed users to combine selections into one single bet, not several bets and was commonly used within the industry as it was essentially an example of an accumulator bet. They said that use of comic exaggeration in advertising was common, and they believed permissible so long as it was not likely to mislead or imply unrealistic outcomes. They said that clearly the actions of the character Josh should not be taken at face value and that not everyone was going to copy his behaviour. They believed the tone of the advertisement, plus the use of figurative language in the strapline (“whatever lengths you go to”) fell within this accepted creative practice.
The advertisers said that no socially irresponsible behaviours were shown. The character Josh did not experience any financial harm. As to any view that there may be social or emotional harm done to him by his family’s disapproval of his betting against their team, they did not believe this to be the case as the scene was clearly done in a mock-serious and ultimately humorous way. They said that there were no depictions of the behaviours of the character Josh taking priority over his friends or any professional or educational commitments. They also said that whilst he may have his family’s disapproval for betting against their team, they did not believe this showed his behaviours as taking priority over his family, it just showed a difference of opinion on one particular match (not every match) and again was in keeping with the mock-serious and humorous nature of the scene. They said that the overall humorous and exaggerated tone of the advertisement counteracted the idea that the advertisement was showing gambling as indispensable to him or was taking priority in his life, and that no real-world examples of this were shown.
The advertisers said that they agreed that humour, exaggeration or even hyperbole should not override their responsibilities when advertising gambling products and felt they were aligned with the ASA’s approach here (as reflected in its General Principles) which focused on the overall impression created on a reasonable viewer. They did not believe the impression of the advertisement by a typical adult was likely to cause harm.
The advertisers said that they took safer gambling seriously and to ensure the right tone, the advertisement had gone through extensive internal review before launch involving Legal and Compliance teams and through all stages from ideation, script stage, shooting and final edits. They said that the advertisement had been broadcast on TV and went through approvals prior to broadcast without any issues flagged. Also, as required under Section 10.10 of the Code, they said that all their gambling advertisements included a clear responsible gambling message and reference to recognised sources of help and guidance for gambling responsibly.
Conclusion
Complaint Not Upheld
The Complaints Council considered the detail of the complaint and the advertisers’ response.
The Council noted that the advertisement had featured a character taking various steps, including a visit to his doctor and jumping out of an airplane, to build a bet builder bet and that these steps had been shown alongside the tagline ‘whatever lengths you go to’.
The Council noted that the free bet offer terms within the advertisement had stated that the offer was for 1 free bet per player per week.
While the Council appreciated the concerns raised by the complainant, they considered that the content of the advertisement had been set in a tongue-in-cheek manner, with the actions of the character clearly being exaggerated. The Council also noted that the bet featured was equivalent to an accumulator bet and was not multiple bets taking place over a short period of time and that the free bet offer was limited to one free bet per player per week. Taking account of this, and of the delivery, style and tone of the advertisement, the Council did not consider that the advertising was in breach of the Code on the grounds raised by the complainant.
Action Required:
No further action required
