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Advertiser: National Lottery
Medium: Internet (Company Website), Radio, Television
ASAI Code 7th Edition: 2.4(c), 4.1, 4.4, 4.9, 4.10, 4.12
Three advertisements in this campaign were complained about.
A radio advertisement featured a man and a woman conversing in which the man claimed that an anti-gravity water slide was unbelievable. The woman, Marian, agreed and stated “Do you know what else is unbelievable?...That 90% of the money spent on the National Lottery goes back into the community.” The man expressed disbelief at this figure, but Marian insisted on its veracity, proceeding to explain that “Most of it goes into prizes, of course, good causes get a big chunk, and there’s all the shopkeepers too! 90%!” The man, now convinced, agreed that this was unbelievable and Marian quips “but true!”. A voiceover at the end of the advertisement explained that the 90% figure was based on most recent audited accounts.
The television advertisement featured a variation of the above interaction, with Marian as a shopkeeper dealing with a female customer. When the customer placed her lotto ticket on the counter, Marian mentioned about the fact that “90% of National Lottery money goes back into the community”. The customer expressed disbelief and soon word spread across the village that Marian was talking “gibberish” and needed a doctor. When the ‘doctor’ appeared, he used a lie detector test on Marian to discover that she was telling the truth about the 90% figure. At the end of the advertisement, a screen appeared with a line at the bottom saying “2020 financials were 58% prizes, 27% good causes, 5% retailer commission”.
The advertisement seen on the advertisers’ website featured an image with a lottery ticket broken into four parts, the size of each corresponding to the percentage portion. The largest piece of the ticket said “58% Prizes”, with the other pieces saying “27% Good Causes”, “5% Retailers” and “10% Running Costs and Profit”. Written on the left side of the ticket in large writing was the question “Did you know 90% of your money goes back into the community?”, while small writing at the bottom of the image stated, “Per the 2020 Financials and %’s are approximate”.
13 complaints were received in relation to the advertising campaign raising the following issues:
Complainants considered that there was a lack of substantiation and transparency surrounding the statement that 90% of the money spent on the National Lottery went back into the community.
Complainants considered that retailers did not constitute the community, especially larger organisations which were funded by shareholders.
Two complainants contended that the money did not go back into the community, but to the Ontario Teachers Pension Fund.
The advertisers explained that the National Lottery operated only within the Republic of Ireland and the use of the term ‘the community’ or ‘community’ was entirely consistent with the plain ordinary meaning of the word. They said the term community was defined in Merriam Webster’s Collegiate Dictionary 11th Ed as “society at large” and defined in the Oxford English Dictionary as “The civic body to which all belong; the public; society”.
The advertisers said it was factually accurate to state that 90% of all National Lottery money went back into the community in the form of (1) Good Causes funding; (2) total prizes paid to players across all National Lottery games; and (3) commissions paid to National Lottery retail agents as evidenced by the past audited accounts below.
2020 2020 2021 2021 €'m % €'m % Sales €918.9 100% €1053.7 100% Prizes €528.9 58% €585.9 56% Good Causes €253.6 28% €304.0 29% Retailer Commission €49.3 5% €55.3 5% Total Community €831.8 91% €945.2 90%
The advertisers said that they were also satisfied that prize-winners and retailers were also appropriately included within the ambit of the term ‘community’. They said that the National Lottery had a diverse community of retailers numbering circa 5,430 across the country and that these retailers were an important part of the fabric of the community within which we all lived and of which Irish society was formed. The advertisers grouped the National Lottery’s retailers into a number of categories including Multiples, Convenience, Forecourt, Independents and Post Offices. They said their retail network was 88% Irish owned and operated. Of the remaining retailers who were not wholly Irish owned, the advertisers confirmed that these had Irish subsidiaries and employed local staff who worked and lived in the community and said that these typically had complex local supply chains and made a significant impact on the economy and contributed in a myriad of ways to the community.
The Complaints Committee considered the detail of the complaint and the advertisers’ response.
Issue 1 – Not Upheld.
The Complaints Committee noted the information provided in the audited accounts and accepted that the 90% figure was correct. The Committee therefore considered that the advertisements were not in breach of the Code on the ground raised by the complainants.
Issue 2 – Not Upheld.
In addition to the dictionary definition received from the advertisers in relation to the meaning of the term ‘community’, the Committee considered that the inclusion of a breakdown of ‘Prizes’, ‘Good causes’ and ‘Retail commissions’ in each advertisement, clearly communicated what constituted ‘community’ for the purposes of the advertising. They also noted the information provided in relation to the role played by retailers within Irish society. The Committee therefore considered that the advertisements were not in breach of the ASAI Code on the ground raised by the complainants.
Issue 3 – Not Upheld.
The Complaints Committee noted that the advertising clearly identified the % of contribution to each element and did not consider that there was a breach of the Code on the basis suggested in the complaints.
No further action required.