Ad description
A paid-for X (formerly Twitter) post for TotalEnergies, seen on 21 May 2024, featured an introductory caption that stated, “Uncover how TotalEnergies’ electricity start-up accelerator program has supported start-ups like Nash Renewables”. A video embedded in the post detailed TotalEnergies’ work with the company NASH Renewables and included images of wind turbines and people working in an office. A voice-over, from NASH Renewables’ co-founder, stated, “[There are] more options to design one particular wind farm than […] atoms in the universe. So, with NASH, it's trying to figure out through algorithms what the optimal way to build a wind or solar farm is […] Getting the stamp of TotalEnergies for this new way of thinking, of course, brought our company massively forward.” On-screen text then stated, “THE ROADS TO CARBON NEUTRAL […] A SPECIAL PRESENTATION BY”, followed by the TotalEnergies logo and the text “Pioneers for 100 years”.
Issue
Adfree Cities challenged whether the ad was misleading because it omitted material information about the overall environmental impact of TotalEnergies’ business activities.
Response
TotalEnergies SE said the ad was part of an episode of their series The Roads to Carbon Neutral, which aimed to highlight case studies that demonstrated TotalEnergies’ profile as a multi-energy company, committed to transitioning towards increasingly decarbonized sources of energy. The ad focused on NASH Renewables and their participation in TotalEnergies’ business start-up accelerator programme, the ON programme, through which they, and other businesses involved in renewable energies and electricity, received investment and support. They said that NASH Renewables joined the programme in December 2022 and TotalEnergies acquired the company in December 2023.
TotalEnergies explained that the ad ran as a paid-for ad on both X and another social media platform for a two-week period, and was targeted towards users interested in energy, technology and innovation, ‘business opinion leaders’, people capable of influencing the actions or opinions of a number of individuals by virtue of their reputation, media visibility or expertise, and investors. The ad was targeted towards those interested in energy, technology and innovation via a keyword method, which served the ad to users actively using at least one predefined keyword in either their searches, their recent posts or posts they had interacted with. They said the targeting of the ad towards business opinion leaders and investors was based upon an interest-based method. That involved selecting various predefined interest groups offered by X, which were reflective of a user’s active behaviour on the platform, to focus the ad towards the desired audience. They said the ad, in its paid-for form, was not seen by general users of X. The vast majority of users who encountered the ad would have been particularly well-informed and knowledgeable in relation to the general nature of an energy company’s business model, and would have an appreciation that the practices shown in the NASH Renewables case study were just one of a number of steps being taken in order to reduce TotalEnergies’ carbon emissions.
They said the name of the series The Roads to Carbon Neutral, reflected the variety of solutions that could be taken to achieve carbon neutrality, and that process was ongoing. The video and a URL below it linked to a webpage that made clear the aim of the series was to present various initiatives that could contribute, without suggesting any single one was sufficient, to achieving carbon neutrality in the future. They said the ad’s video focused on the work of NASH Renewables and how TotalEnergies’ ON programme supported it, and did not make a claim, or an implicit suggestion, about TotalEnergies’ environmental credentials. On the webpage the ad linked through to, the full episode was available, and the wording used on the page was aspirational, balanced and explained how NASH Renewables was contributing towards TotalEnergies’ net zero ambitions without exaggerating their contribution.
TotalEnergies said that due to the constraints of the medium used for the ad, further information about TotalEnergies’ business practices could not be given within it. As a result, their website made clear they were involved in oil and gas, and renewable energies, and from there information could be found about their current and planned production and sales energy mixes, as well as their broader greenhouse gas reduction targets.
TotalEnergies said the ad did not include any broad or ambiguous ‘green’ claims. The claim “The Roads to Carbon Neutral” would be understood in relation to their own business practices, which included the production of oil and biofuels, natural gas and green gases, renewables and electricity. They wanted to be a major player in the energy transition and to achieve carbon neutrality by 2050. By 2030 they aimed to have reduced their sales of petroleum products by 40% (compared to 2019 sales), and they aimed for petroleum products to make up 30% of their sales by 2030 (compared to the 65% share they comprised in 2015). They were set to meet these objectives, as 43% of their 2023 sales comprised petroleum products (compared to 65% in 2015) and 10% of low carbon energies (compared to 2% in 2015). In 2023, 31.7% of their annual capital expenditure was directed towards low carbon activities, with $4 billion allocated to developing electricity generation from wind capacity up to 2030. Alongside that, they had also invested $100 million annually into carbon sinks, such as forestry, regenerative farming and wetlands protection, which would have a cumulated lifespan cost of $725 million, and were investing in geological carbon storage. From that, they said the intention of the claim was to communicate that TotalEnergies were in the early stages of their journey towards carbon neutrality.
TotalEnergies said they were on a legitimate and credible pathway towards net zero carbon emissions, and that they considered it important they communicate the steps they were taking, while being mindful of their obligation to tell a balanced story that did not omit information or present it in a misleading manner.
Assessment
Upheld
The CAP Code stated that marketing communications must not mislead by omitting material information. It also stated unqualified environmental claims could mislead if they omitted significant information.
TotalEnergies (formerly known as Total until 2021) had placed targeting parameters on the ad to direct it towards an audience that comprised those interested in energy technology and innovation, business opinion leaders and investors. However, we considered the methods used, keyword and interest-based targeting, meant that the ad was seen by a general consumer and business audience, rather than a business-only audience. In addition, the targeting parameters were broad and, within the audience as a whole, there was unlikely to be a consistent level of knowledge between the respective members of each group. The ad was only seen by members of the targeted groups. However, we considered they still comprised a general audience as the targeting parameters did not ensure delivery to those with a substantially different level of knowledge and understanding to that of a general consumer and business audience in a wider context.
The ad, its video and caption, linked NASH Renewables, and their work to help optimise the design of wind and solar energy farms, with TotalEnergies via their ON business start-up accelerator programme. The caption stated, “Uncover how TotalEnergies’ electricity start-up accelerator program has supported start-ups like Nash Renewables”. The video featured imagery of wind turbines and referred to NASH’s work and how TotalEnergies had supported them. The ad concluded with the claim “THE ROADS TO CARBON NEUTRAL […] A SPECIAL PRESENTATION BY” and displayed the TotalEnergies logo.
We considered the likely overall impression of the ad, relating to both the claims and imagery in the caption and the video, was that a significant proportion of TotalEnergies’ business activities, which included the ownership of NASH Renewables, was focused on the development and expansion of renewable energies, including through supporting other companies in doing so, and that was directly driving TotalEnergies towards being carbon neutral. We understood that videos automatically played on X. However, that setting could be changed, and videos may not automatically play for all users. Nonetheless, the ad’s caption alone created the impression that TotalEnergies’ business activities were predominately focused on the development of renewable energies and companies associated with its development, such as NASH Renewables. The name of the series, ‘The Roads to Carbon Neutral’, which featured at the end of the video, would not be understood as indicating the significance of TotalEnergies’ green activities, including the ON programme, in proportion to their wider business practices.
We acknowledged that TotalEnergies website, which was accessed by clicking the video once it was playing or the URL beneath it, contained further information about their ON start-up accelerator programme and TotalEnergies’ wider business activities. However, we considered the ad was not limited by time or space to the extent that information which contextualised the significance of their green activities and progress could not have been included. The caption had used 117 characters of a possible 280, and the video was 30 seconds in length. Additionally, that website was different to the one referred to in the video, www.roadstocarbonneutral.com. While the latter website suggested TotalEnergies was attempting to lower its environmental impact, it did not make clear the significance of their progress towards carbon neutrality in relation to their wider business activities.
The ad’s audience was likely to have an awareness that many companies in carbon-intensive industries, including the oil and gas sector, aimed to dramatically reduce their emissions in response to the climate crisis. We considered that consumers were increasingly concerned about the environmental impact of activities related to higher-carbon products and services. They would be interested in seeking out businesses, including oil and gas companies, that were making meaningful progress towards transitioning away from higher-carbon products and services. Business audiences would be interested in suppliers and investors who were transitioning towards lower-carbon products and services. However, both general consumers and business audiences were unlikely to be aware of the details of that in relation to specific companies. Ads for companies in higher carbon sectors that focused on their green initiatives were therefore likely to mislead consumers if they did not include details of the contribution that lower-carbon initiatives played as part of the overall balance of a company's current or near future activities.
TotalEnergies had set itself objectives to reduce the absolute amount of petroleum products it sold, and the proportion of those products in their total sales. We acknowledged they were investing in carbon sinks and geological carbon storage, and renewable and low carbon energies. They also expected to reduce their fossil fuel output by 2030. However, we understood that a significant proportion of the energy products TotalEnergies produced and sold were fossil-fuel related products. As per TotalEnergies’ Sustainability and Climate 2024 report, in 2023, 90% of their sales arose from petroleum and gas products. Additionally, in 2030, they were targeting for 30% of their sales to comprise oil, 50% gas, and 20% low-carbon molecules and electricity. The report also stated that their total Scope 1 and Scope 2 greenhouse gas emissions from sites and assets they either operated, or in which they held an equity stake, were 84 million tonnes CO2e (carbon dioxide equivalent). In 2023 TotalEnergies were responsible for 1.5% of global oil production and had allocated 68.3% of their capital expenditure towards fossil fuel energies and 31.7% to lower-carbon activities.
The ad focused on lower-carbon energy products. Although TotalEnergies were taking steps to diversify their energy production, as consumers and business audiences were likely to view the ad as reflective of their current activity, information about the proportion of TotalEnergies’ overall business model that comprised lower-carbon energy products was material information that should have been included. In the absence of that information, we concluded the ad was 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, the video and caption, must not appear again in the form complained of. We told TotalEnergies SE to ensure their future ads that focused on environmental initiatives did not mislead by omitting material information about the proportion of their overall business activities that comprised lower-carbon activities.
