Ad description
Six posters for Wahed Invest Ltd, an online Halal investment platform, seen in September and October 2024 on various Transport for London (TfL) services, including London Underground tubes and buses:
a. The first poster featured images of two men pointing upwards with their index fingers, and US dollar banknotes on fire. Large text stated, “Join the Money Revolution” above the advertiser’s logo. Smaller text stated, “Capital at risk. Wahed Invest Ltd is authorised and regulated by the Financial Conduct Authority”.
b. The second poster featured similar images as seen in ad (a) of two men pointing upwards with their index fingers, and US dollar banknotes on fire. Large text stated, “Join the Money Revolution”.
c. The third poster included the same text and small print as ad (a). The image showed a man holding an open briefcase filled with US dollar and Euro banknotes on fire.
d. The fourth poster included the same briefcase image as ad (c), and the same small print as the other ads. A large heading stated, “Withdraw from Exploitation”. Text below stated, “Charging people to borrow money was once called exploitation. Sadly, that perception has changed and now interest has caused a massive wealth gap, enriching the few while the majority get poorer. Join the growing community moving their money to a fairer system, one that serves you! Download Wahed now. Join the Money Revolution”.
e. The fifth poster included the same briefcase image as ad (c). Large text stated, “Withdraw from Riba”. Smaller text stated, “Join the Money Revolution. Capital at risk”.
f. The sixth poster included the same text and small print as ad (a). It featured a similar image seen in ad (a) of one man pointing upwards and US dollar and Euro banknotes on fire.
Issue
Seventy-five complainants challenged whether the ads were offensive.
Response
Wahed Invest Ltd believed that although their ads were thought-provoking, they were not offensive.
They explained they were a digital investment platform which allowed consumers who were predominantly Muslim to invest in an ethical manner which aligned with their faith and values. They said a major component of their platform was that it did not charge consumers interest on loans. They explained that their ads often used the term ‘Riba’, which was an Arabic word that meant ‘excess’ and was commonly used to describe the prohibition of interest under Islamic law.
Wahed Invest provided links to several articles on their website, as well as external reports, which they believed highlighted the ways in which interest, or Riba, contributed to social and financial inequality. They also believed inflation was not a properly understood concept and provided a survey which supported that view. They believed it was important to educate people to properly understand interest. They believed Muslims who held the belief that interest contributed to financial inequality had limited options for where to store their money and understood that some often requested for financial institutions to not pay them interest. They believed that, due to rising inflation, consumers who followed Islamic law by not accepting interest on savings suffered from further long-term wealth inequality than those who did accept interest. They said their advertising stated, “Interest has caused a massive wealth gap, enriching the few while the majority get poorer”.
They said the burning of banknotes within their ads was designed to be a powerful visual illustration that money stored in a way that was growing at a rate lower than inflation created a decrease in value and purchasing power in real terms. The purpose of the ads was therefore to show that, when inflation grew faster than the rate of savings, money was akin to ‘going up in flames’. They believed all viewers, including those who were not Muslim, would have understood that expression. They said the ads had not criticised specific groups and that they used US dollar and Euro banknotes because they were amongst the most recognised currencies in the world. The purpose of the ads was to promote ethical investing as defined by Islamic law.
Wahed Invest acknowledged that currencies were a symbol of national identity but believed the burning of banknotes was not offensive and was portrayed in popular culture, like film and TV. They also believed the burning of money was a commonly understood concept. For example, due to hyperinflation, there had been famous examples of people burning money. They said popular phrases such as ‘money to burn’ and ‘burning a hole in my pocket’ were used to describe someone who had money to spend. They also said the phrase ‘burn rate’ was used to describe how quickly a company was spending money. They believed that, had the idea of burning money been a cause for widespread offence, such language or visual representations would not be as commonly used or as easily understood in society as it was.
TfL said their advertising partners, which included Global, reviewed all campaigns before they were approved to run on the network. They said in some cases, such as with ads (a)–(f), TfL also reviewed campaigns internally. They believed the ads complied with TfL’s ad policy and the CAP Code. They received some complaints about the ads and had paused all campaigns from Wahed Invest pending the outcome of the investigation.
Global said they reviewed the ads internally and submitted them to the CAP Copy Advice team, who considered they were unlikely to raise issues under the CAP Code. They said they had not received any complaints about the ads. The ads were no longer appearing.
Assessment
Upheld
The CAP Code stated that ads must not contain anything that was likely to cause serious or widespread offence. Particular care must be taken to avoid causing offence on certain grounds, including race (which includes nationality).
We acknowledged Wahed Invest’s view that the burning of banknotes illustrated that money which grew at a rate lower than inflation decreased in value in real terms. The ads represented the expression that viewers’ money was ‘going up in flames’ and that images of burning money were commonly encountered.
However, regardless of whether viewers would have understood that message or understood it as a defiant act designed to show a challenge to financial institutions, the currencies which were burned in all of the ads were clearly visible as US dollar and Euro banknotes. In the case of the US dollars depicted, in all instances the ads showed the words “The United States of America” in flames. The ads were shown on several sites across the TfL network, including on London Underground tubes, which was an untargeted medium, and they were therefore likely to be seen by many people. It was also a service regularly used by tourists. Due to the vast number of people who used TfL services and because London was a tourist hotspot, people from the United States or Eurozone countries would have seen the ads.
We considered some viewers, particularly people from the United States or Eurozone countries, would have viewed their nation’s currency as being culturally significant and a symbol of their national identity. Although we acknowledged Wahed Invest’s view that they had not directly criticised a specific group, and that depictions of burning banknotes were commonly encountered, we considered the burning of banknotes would have caused serious offence to some viewers. We therefore concluded that the ads were likely to cause serious offence.
The ads breached CAP Code (Edition 12) rule 4.1 (Harm and offence).
Action
The ads must not appear again in the forms complained of. We told Wahed Invest Ltd to ensure that future ads did not cause serious offence, including by featuring images of burning US dollar or Euro banknotes.
