Who: Advertising Standards Authority (ASA), Committee for Advertising Practice (CAP) and LC International Ltd t/a Coral (Coral)
Where: United Kingdom
When: 3 August 2022
Law stated as at: 22 September 2022
Coral released an advert in March 2022, which featured footage of a horse race, showing spectators excitingly cheering and shouting in the crowd, a lively commentator, bold slogans and the Coral logo.
The advert was challenged by two complainants, who stated that it breached the UK Code of Broadcast Advertising (BCAP Code) by portraying, condoning or encouraging gambling behaviour that was socially irresponsible or could lead to financial, social or emotional harm.
Coral responded to these complaints by arguing that they wanted to appeal to horse racing fans by capturing the trackside excitement and atmosphere at horse racing events. They noted that these feelings of excitement were typically associated with large sporting events and were not indicative of problem gambling. Furthermore, there was no reference to betting throughout the advert, nor did it mention any of Coral’s products, services or promotional offers. The brand logo was the only identifiable sign to betting throughout. Coral firmly believed that the advert did not encourage betting or portray gambling as fun, therefore the advert was not irresponsible and did not disproportionately affect vulnerable groups.
The ASA concluded that, despite the advert not explicitly referring to betting, there were visible Coral banners throughout, such as on the saddle of the horse and on the voice-over at the end, therefore it found that the advert did promote betting on horse racing with Coral.
The ASA reasoned that the catchphrase “Coral, get closer to the action” indicates that engaging with the gambling operator would enhance each spectator’s horse racing experience, making it feel exciting and appealing to the viewer. Furthermore, the voice-over addresses the viewer in second person and refers to “your horse” winning, which the ASA argued could disproportionately affect those struggling with a gambling addiction. The ASA noted that these kind of phrases paired with the dramatic music, close-up imagery and audio-visual effects would recall the highs associated with successful bets for viewers with gambling issues. Finally, the phrase “how long have you waited for those gates to crash open” alludes to an intense anticipation for the races, which is suggestive of problematic gambling.
CAP’s advertising guidance on gambling states that certain marketing approaches are likely to have a disproportionate response on problem gamblers. Marketers should take all reasonable steps to protect these vulnerable viewers by not encouraging them to gamble more than they otherwise would. In light of this guidance and the BCAP Code, the ASA concluded that there was a significant risk that the advert disproportionately affected this vulnerable group by positioning betting as an exciting and fun activity: therefore, the advert was deemed socially irresponsible.
Why this matters:
The ASA continues to be mindful of the impact that gambling and betting marketing can have on vulnerable groups, such as problem gamblers and those at risk from such behaviours. Gambling operators must take all reasonable steps to prevent adverts posing a risk to these vulnerable individuals and ensure that advertising meets general standards of responsibility to protect wider audiences. This ruling shows that a careful balance needs to be struck by gambling operators when portraying any excitement or thrills associated with gambling in their advertising. Marketing approval processes should include reviewing marketing through the eyes of a vulnerable individual.