Ad description
A national press ad for energy company Equinor, seen in June 2023, stated “Wind, oil, gas, carbon capture […]” and “IT’S ALL PART OF THE BROADER ENERGY PICTURE”. A footnote at the bottom of the ad stated “Equinor has been delivering energy solutions to the UK for 40 years, and we are now working to help the UK achieve a smooth energy transition […] we’re producing the oil and gas the UK needs now; and will be powering millions more homes with wind, capturing and storing carbon safely […]. It’s broad energy for a brighter future”.
Issue
The ASA challenged whether the ad was misleading because it omitted significant information about the overall environmental impact of Equinor’s business activities.
Response
Equinor ASA said the ad was part of a targeted brand campaign intended to build awareness of their company, which had been operating in the UK for 40 years. The ad highlighted Equinor’s contributions to the UK beyond oil and gas, including their renewable energy and carbon capture activities. They said the ad was a one-off that had been published in The Economist magazine. It did not advertise any consumable product or service, and was not aimed at the general public, but at decision-makers and their influencers, a group that included politicians in government and opposition, as well as advisors and journalists. They said that group would not make decisions based solely on the information featured in the ad, and would carry out their own due diligence, which could include scrutinising Equinor’s policies and plans.
Equinor said the ad did not feature subjective or vague terms, and stated facts about the fields in which Equinor was involved, and signalled their recognition that a transition towards cleaner fuels was necessary and would occur. The transition to cleaner energy required investment, innovation, and a broad mix of energy sources, and that it was essential to strike a balance between providing energy security while also enabling that transition.
Equinor highlighted that the words “oil” and “gas” appeared prominently in the ad, and the text at the bottom of the ad stated they were “producing the oil and gas the UK needs now”. Additionally, it featured an image of an oil and gas worker on an oil rig, looking out to another oil rig. The ad did not engage in a discussion of the merits or environmental impact of oil and gas production versus energy from wind power or carbon capture and storage. Its aim was to show that Equinor was engaged in a broad energy mix, and illustrated the activities in which Equinor was involved.
Equinor’s ambition was to become net zero by 2050. To that end, they were engaged in cutting emissions from oil and gas production and developing new technology to accelerate decarbonisation. They were also leveraging digitalisation and technology to reduce production emissions and the carbon footprint of their offshore oil and gas production. They were a partner and operator in the Sherringham Shoal, Dudgeon, Hywind Scotland, and Dogger Bank windfarms – the latter of which was still under construction – and a partner-licence holder in the Endurance Carbon Capture and Storage hub. They were also involved in several UK projects to decarbonise heavily industrialised regions such as the Humber, Teeside, and Peterhead – for example, their H2H Saltend Project that would supply local industry and power plants with hydrogen and feature a small onsite CCS facility, as well as plans to build additional hydrogen production capacity in the Humber by the end of the decade. They said they had taken advice from the CAP Copy Advice team.
Assessment
Upheld
The CAP Code 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, as well as politicians and public policy professionals. The ASA therefore considered members of those groups were the ad’s likely audience. While the ad was not for a directly purchasable product or service, we considered it was likely to raise Equinor’s profile and influence readers’ opinions of Equinor as a brand by increasing awareness of their activities and plans in the UK.
Readers of The Economist were likely to have an awareness that many companies in carbon-intensive industries, including the oil and gas sector, were in the process of investing in renewable alternatives to fossil fuels to help governments, businesses, and consumers reduce their emissions in response to the climate crisis and in their transition to net zero. Those who were concerned about the environmental impact of activities related to higher-carbon energy sources would be interested in seeking out, supporting, or promoting businesses, including oil and gas companies, who were making meaningful progress towards transitioning away from higher-carbon products and services, including those investing in renewable energy production, such as wind farms, and technology such as carbon capture and storage (CCS).
However, ads were likely to mislead if they exaggerated the contribution that lower-carbon initiatives played, or would play in the near future, as part of the overall balance of a company's activities when making claims about green initiatives.
The ad featured an image of a worker on an oil rig, with another oil rig visible in the distance. Text in the body of the ad included “Wind, oil, gas, carbon capture”, and further text at the bottom of the ad stated “we’re producing the oil and gas the UK needs now; and will be powering millions more homes with wind, capturing and storing carbon safely”. We considered the overall impression of the ad was that Equinor’s current and near future business activities in the UK included providing energy sourced from a mix of fossil fuels such as oil and gas, and renewable sources such as wind, as well as capturing and storing carbon dioxide.
The claim “Wind, oil, gas, carbon capture”, gave equal prominence to each of those activities. In the absence of sufficient qualifying information that, together with the further text at the bottom of the ad, was likely to be interpreted to mean that CCS and energy sourced from windfarms formed a significant proportion of Equinor’s current and near future activities, alongside oil and gas.
We understood Equinor were a partner-investor in several UK windfarms, and were involved in several CCS projects in the north-east of the UK. Equinor’s 2022 Integrated Annual Report (the Report) stated that their total scope 1 and 2 operated greenhouse gas (GHG) emissions were 11.4 million tonnes CO2e (carbon dioxide equivalent). Equinor also held significant interests in international oil fields, including the UK’s Rosebank oil field, in which it held a 40% stake, which had increased to 80% in 2023. We understood from the report that their oil and gas production stood at around 2,039 thousand barrels of oil equivalent per day in 2022. Additionally, the Report stated that in 2022 their capital expenditure on renewable investments stood at 14%, growing to 30% by 2025. Furthermore, we understood from the Report that large-scale global oil and gas investment and extraction formed the vast majority of Equinor’s business activities and would continue to do so in the near future.
While the ad was clear that the UK energy blend was in transition, it gave the overall impression that CCS and energy sourced from windfarms formed a significant proportion of Equinor’s business activities, alongside oil and gas. We therefore considered further information about the overall proportion of Equinor’s business model that comprised renewable energy and CCS was material information that should have been included. Because the ad did not include that information, we concluded it omitted significant information and was therefore likely to mislead.
The ad breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), and 11.1 (Environmental claims).
Action
The ad must not appear again in the form complained of. We told Equinor ASA to ensure their future ads featuring environmental claims did not mislead by omitting significant information about the proportion of their business activities that comprised renewable energy and CCS, or the role those activities played in their current business.
