HSBC sees UK ad campaign banned on greenwashing grounds

HSBC has been the subject of many climate campaigns in recent years, with calls for stronger plans to phase down fossil fuel financing

The watchdog announced the decision today (19 October) after making an interim ruling on the two adverts earlier this year.

Displayed on bus stops in Bristol and London in the run-up to COP26, the advert campaign used the tagline “climate change doesn’t do borders”. One of the adverts stated HSBC’s aim to finance the planting of two million trees in the UK, in partnership with the National Trust, and the other highlighted its plan to finance billion of dollars of low-carbon activities this decade.

Campaign group Adfree Cities challenged the adverts and received support from dozens of other individuals and groups. In total, 45 complaints were made to the ASA. The complaints argued that the advertising campaign omitted broader information about the climate impact of HSBC’s financing activities, meaning that those who viewed it would likely conclude that HSBC has a positive environmental impact.

A particular cause for contention was that HSBC is believed to have provided $87bn in financing to fossil fuel companies between the start of 2015 and the end of 2021. It will continue to finance coal in OECD nations this decade and beyond that in other countries.

“Customers… would not expect that HSBC, in making unqualified claims about its environmentally beneficial work, would also be simultaneously involved in the financing of businesses which made significant contributions to carbon dioxide and other greenhouse gas emissions,” the ASA stated.

HSBC, in its defence, stated that it has aligned its policies for phasing down fossil fuel finance and finance to other high-emission sectors in line with a 1.5C-aligned, net-zero-by-2050 pathway. It argued that historic and continued financing in high-carbon sector was not, in and of itself, in conflict with the net-zero transition.

HSBC also argued that the adverts highlighted “two tangible initiatives” and that most viewers would not likely see them as comments on their broader environmental impact. Representatives for the bank pointed out that the ads called on viewers to ‘search HSBC sustainability’ for more detailed information.

The ASA ultimately upheld the complaint. It stated that the adverts were misleading on the grounds of omitting ‘material’ information.

This is believed to be the ASA’s first greenwashing ruling for the financial sector. The watchdog has forced several companies in consumer-facing sectors, including airlines and consumer goods, to pull adverts in the past.

Commenting on the ruling, Andrew Terry of law firm Harbottle & Lewis said: “Assessing the overall environmental contribution of a massive business like HSBC is more complex and nuanced than assessing the impact of a bottle of detergent.  The ASA may be correct on this occasion – they may have felt that the data made it easy to show that HSBC’s green efforts were outweighed by its contribution to greenhouse emissions.

“And, fundamentally, it is right that businesses in the financial sector should be stopped from misleading customers about their approach to environmental issues. The problem is that publicising particular projects that are clearly environmentally beneficial is obviously positive – it increases engagement and public awareness that these are important issues.  The ASA needs to be careful that where the picture is more nuanced, it does not gag businesses from talking up genuine successes, because there are historic projects that are being wound down.”

A survey of more than 200 UK-based marketing professionals, published this time last year, revealed that half are worried that communications around the sustainability ambitions and actions of companies would be perceived as greenwashing.