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A TV advertisement for The People’s Postcode Lottery captured the attention of the regulator in charge of advertising in the UK, the Advertising Standards Authority (ASA). The ad in question featured Emma Willis, a popular TV personality and presenter and aired back in November 2023.
In light of the advertisement, the Authority challenged whether or not Willis may appeal to those under the legal gambling age, which is 18. As a result, the ASA has conducted an assessment and requested the Postcode Lottery to submit evidence supporting why the TV personality did not appeal to those under the age of 18.
Per the existing regulations in the UK, any gambling ads must not appeal to children or young adults. It is a responsibility of the licensed operators to adhere to those rules, ensuring that their marketing communication targets audiences above the age of 18 and is unlikely to appeal to children or young adults.
Responding to the ASA’s query, the Postcode Lottery cited the CAP and BCAP Advertising Guidance which designates individuals “with direct connections to under-18s through their role, like children’s TV presenters or film stars, as high risk.” The company explained that a majority of the programs Willis participated in targeted adult audiences, despite some appearances on “The Voice Kids” and “The Voice,” as well as other programs where she recently presented. Ultimately, the Postcode Lottery cited Broadcaster’s Audience Research Board (BARB) data, highlighting that the programs that the presenter participated in were not of strong appeal to children.
Supporting their statement that Willis did not have a strong appeal to children, the Postcode Lottery disclosed Facebook and Instagram data from the presenter’s following. They said that Willis had more than 672,000 followers on Facebook and more than 1,970,000 followers on Instagram.
Out of the total followers on Facebook, only 1,344 people or 0.2% were between the ages of 13 and 17, while 13,812, or 0.7% of Willis’ followers on Instagram were within the same age group, the People Lottery explained. Moreover, the company explained that the presenter’s posts were adult-oriented and promoted adult-focused brands via paid advertising or promoted her appearances on social media.
The ASA has also evaluated the likelihood of the presenter appealing to young adults or children. Additionally, the Authority has considered the shows and brands Willis engaged with and presented recently. Notably, the ASA concluded that her appearance on The Voice Kids and The Voice “did not make her of strong appeal to under-18s.”
Additionally, the ASA said that it was satisfied with Willis’ number of followers on social media under the age of 18 which was “low and not indicative of her strong appeal to children or young people.” As a result, the Authority concluded that the presenter did not have a strong appeal to children or young adults, acknowledging that the People Lottery’s ad did not breach the gambling advertising regulations in the country.
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