ASA ruling on Shell Energy UK: LinkedIn dual audience matters

The ASA has ruled that Shell Energy UK’s LinkedIn ad promoting a decarbonisation partnership was not misleading, despite concerns over its environmental messaging. The decision clarifies how claims should be framed on platforms like LinkedIn, which reach both business and consumer audiences. This article explores the ASA’s reasoning and offers practical guidance for businesses making environmental claims in professional settings.

The ASA has dismissed a complaint regarding Shell Energy UK’s LinkedIn ad. The ad featured a video highlighting Shell’s partnership with Baker Hughes to decarbonise operations in Italy. The complainant argued that the ad gave a misleading impression of Shell’s overall environmental impact.

As well as being another interesting example of how to get green claims right, the ASA’s comments regarding LinkedIn advertising are very informative.

LinkedIn audience: business or consumer?

Although Shell argued that its ad was targeted at a business-to-business (B2B) audience, the ASA noted that LinkedIn is accessible to both consumers and professionals.

The ASA pointed out that LinkedIn is not a closed B2B platform, it's publicly accessible and widely used by consumers, especially those interested in sustainability, energy, and corporate responsibility. This meant the ASA had to consider whether a consumer viewing the ad might be misled, even if the ad was intended for a professional audience. 

The ASA acknowledged that Shell had used LinkedIn’s targeting tools to reach senior professionals in relevant commercial roles but appeared to conclude that this didn't change the fact that the ad was accessible to consumers. Ultimately, the ASA concluded that the ad’s limited and specific business orientated claims, combined with its contextual clarity and supporting links, were sufficient to avoid misleading.

ASA’s decision: Complaint not upheld

The ASA concluded that the ad did not breach the CAP Code. Key factors in the decision included:

• Expressly business solution claims: The ad focused on business solutions was targeted at a B2B audience likely to understand the limited scope of the claims.
• Specificity of the claim: The ad clearly referred to a specific partnership with Baker Hughes and did not imply broader environmental performance and the accompanying imagery reflected this.
• Supporting information: The ad linked to further details which helped to clarify the claims made.

This sets an important precedent in that:

• Regulators will assess ads based on actual accessibility, not intended audience
• Advertisers cannot rely on platform tools to target their audience
• Specific precise Environmental claims are more likely to be acceptable

Implications for businesses

For legal and marketing teams, this is a timely reminder that platforms like LinkedIn are subject to ASA enforcement. The ruling suggests that content on this platform will not necessarily be treated as B2B advertising – even if it's targeted. 

This ruling offers reassurance to businesses engaging in B2B environmental marketing, but also underscores the need for care:

• Know your audience: Tailor messaging to the level of understanding and expectations of your target group.
• Be specific: Avoid broad or unqualified environmental claims.
• Provide context: Use links or supplementary materials to explain the scope of your claims.
• Stay up-to-date with compliance obligations: Monitor ASA rulings and CAP guidance to ensure your advertising remains within regulatory boundaries.

If your business is planning to make environmental claims in advertising, especially in B2B contexts, speak to our regulatory and advertising lawyers. You can also read our advertising and marketing page for further insights.