Two HSBC advertisements promoting the company’s climate change response have been banned by the UK Advertising Standards Authority (ASA) for omitting reference to the HSBC’s continued financing of fossil fuel projects and links to deforestation.
This is the first greenwashing decision against a bank and represents a clear warning around advertising sustainable finance and net zero goals.
The relevant adverts were bus stop posters which read:
- "Climate change doesn’t do borders. Neither do rising sea levels. That’s why HSBC is aiming to provide up to $1 trillion in financing and investment globally to help our clients transition to net zero”, and
- "Climate changes doesn’t do borders. So in the UK, we’re helping to plant 2 million trees which will lock in 1.25 million tonnes of carbon over their lifetime".
The ASA considered that consumers would take those advertisements to mean that HSBC was:
- making, and intended to make, a positive overall environmental contribution as a company,
- committed to ensuring its business and lending model would help support businesses to transition to models that supported net zero targets, and
- undertaking an environmentally beneficial activity by planting trees which would make a meaningful contribution towards the sequestration of greenhouse gases in the atmosphere.
It judged this impression to be misleading in circumstances where:
- HSBC was financing companies generating emissions equivalent to around 65.3 million tonnes of carbon dioxide per year for oil and gas alone, and
- HSBC intended to continue funding thermal coal mining and power production to 2040.
The ASA did not accept HSBC’s arguments that transition financing of these industries was necessary, taking the view that because HSBC had not been clear about this position, consumers would not be aware of it and that it was, therefore, a material omission from the advertising.
The UK and New Zealand advertising and fair dealing guidance is very similar, so while this may be a high water mark, we would expect similar regulator interest here.
It is crucial that advertising claims are considered in context. It is often what is missing from a claim, rather than what is said expressly, that makes it misleading.