ESG Enforcement Tracker

Key facts:

The ASA ruled that Shell Energy’s paid LinkedIn advertisement did not breach the CAP Code as the ad was unlikely to mislead and the basis of the environmental claims was clear.

The ad included a caption which stated, “Discover the progress we’re making together with Baker Hughes to help reduce their emissions and decarbonise their operations in Italy. Progress happens together”. It linked to a landing page which contained further information on Shell Energy’s work with Baker Hughes and other corporate customers. The ad also featured a video containing imagery of the sun and solar energy, along with on-screen text.

The ASA found that, despite Shell Energy using tools to direct the ad to a specific readership, the ad was seen by a mixed audience. Given that the content of the ad was focused on business solutions provided by Shell Energy which were not available to general consumers, the ASA concluded that the ad was a business-to-business marketing communication and was likely to be understood as such by its audience.

The ASA considered that readers would understand that the ad was a case study in how Shell Energy was helping business clients decarbonise their operations and the progress they were making together in that regard. It would be unlikely for the audience to interpret the message as representative of Shell’s wider consumer-facing brand activity or as a comment on its own carbon transition plans.

Under the CAP Code, a marketing communication must not materially mislead or be likely to do so. Unqualified environmental claims could mislead if they omit material information.