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 206 fun 206 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.Issue
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 trading as 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 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 (CAA) said they approved the ad on the condition of its being restricted to screening with 12A films and above.
ASA Assessment: Complaint upheld
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 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.
