Ad description
A magazine ad for Barclays Investment Bank, seen on 25 September 2024, featured the headline “POWERING a more sustainable future”. Text beneath stated, “Our team of experts provide a broad spectrum of strategic advice and financing solutions to clients across the energy value chain. From M&A to capital raises and risk management, we're helping power the transition to a low-carbon future”. Beneath that was an image showing members of the team and text stated their job titles, which included the Global Co-Heads of Barclays’ Sustainable Banking Group, the Global Head of Barclays’ Energy Transition Group and the Co-Head of Energy & Climate Technology. Text beside a QR code stated, “Start Powering Possible with our insights on nature-based solutions”.
Issue
The complainant challenged whether the ad was misleading because it omitted significant information about Barclays’ contribution to carbon dioxide and greenhouse gas (GHG) emissions.
Response
Barclays Bank plc said the ad was only shown in the UK in The Economist magazine, a publication whose readership were financially literate and concerned with current affairs, international business, finance, economics, politics, technology and culture. That readership would have understood the ad was promoting Barclays Investment Bank’s offerings and was not suggesting Barclays did not support clients in high-emitting sectors. They said the ad was placed in The Economist in order to target Barclays Investment Bank’s client base, which comprised corporate, government and institutional bodies. The ad targeted the senior leadership of those organisations, as they could instruct their organisation to take advantage of the offerings made available by Barclays Investment Bank, which were not available to retail consumers.
They said the ad’s reference to the “energy value chain” incorporated all types of energy production, including upstream, midstream and downstream fossil fuels. The ad’s headline was not an absolute claim as it referred to “a more” sustainable future, and did not over-promise a total remedy, instead it was qualified by the reference to the “broad range of strategic advice and financing solutions”. They said the “powering a more sustainable future” and the “helping power the transition to a low-carbon future” claims would have been understood as meaning Barclays Investment Bank could help their business clients meet their own goals in transitioning to a lower-carbon future.
They said the basis of the environmental claims was clear, that Barclays Investment Bank were offering advice and financing to their clients to help them move towards "a more sustainable future" and "power the transition to a low-carbon future". To the extent the ad made any claims relating to sustainability, those claims were based on a verifiable strategy. They said examples of that included Barclays Investment Bank acting as the financial advisor to a company focused on fleet electrification and battery storage solutions in a sale of a majority equity interest; they were a joint underwriter to a major utility on its capital raise where the net proceeds were intended to be used on the issuance for green investments; and they provided interest rate and inflation hedging when supporting a client's acquisition of offshore transmission assets connected to an offshore windfarm.
Assessment
Not upheld
The CAP Code stated that 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. It also stated that unqualified environmental claims could mislead if they omitted significant information.
The ad appeared in The Economist magazine, which was read by consumer and business readers. The ASA therefore considered members of those groups would see the ad.
The ad was for Barclays Investment Bank, as referenced above the headline, and targeted the senior leadership of its client base. While the ad may have also been seen by general consumers who would recognise Barclays as a high street bank, it was focused on Barclays Investment Bank’s operations, which were not available to retail consumers. We therefore considered the ad was a business-to-business marketing communication and was likely to be understood as such by its audience.
The ad featured the claims “POWERING a more sustainable future”, “Our team of experts [pictured, which included the Global Co-Heads of the Sustainable Banking Group, the Global Head of the Energy Transition Group and the Co-Head of Energy & Climate Technology] provide a broad spectrum of strategic advice and financing solutions to clients across the energy value chain. From M&A to capital raises and risk management, we're helping power the transition to a low-carbon future”, and “Start Powering Possible with our insights on nature-based solutions”. We considered readers would interpret those claims as meaning that Barclays Investment Bank employed experts which supported clients involved in energy production and distribution with advice and financing solutions to help those clients to meet their own goals in transitioning towards lower-carbon models, partly through insights into nature-based solutions.
The ad focused specifically on the services of the Barclays Investment Bank’s expert team, which were being promoted to readers in a business-focused publication who had responsibility for and were interested in seeking advice and financing solutions to support the transition of their own company towards a lower-carbon future. Readers were likely to interpret the ad as being solely about the potential benefits of these services. They were unlikely to interpret the message, which included references to supporting clients interested in making a transition to a low-carbon future, as representative of Barclays’ wider brand activity, its own carbon transition plans, or the advice and funding provided by Barclays to its overall client base.
As such, the omission of information to explain Barclays’ overall contribution to carbon dioxide and greenhouse gas emissions was unlikely to mislead.
We investigated the ad under CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), and 11.1 (Environmental claims) but did not find it in breach.
Action
No further action necessary.
