ESG Enforcement Tracker

Key facts:

In November 2023, the ASA upheld a complaint against the travel company, Intrepid Travel Group UK, in relation to its advert in the London Underground featuring the text: “People & Planet-friendly small group adventures since 1989”, alongside images of the Giza Pyramids. The advert included a link to the company’s website that could be accessed by consumers and contained qualifying information regarding their environmental credentials.

The company made reference to its wider environmental credentials, including its certification as carbon neutral by Climate Active for business operations and services, the carbon offset projects it supports, the fact it offsets the entirety of its annual emissions footprint and that it has been carbon neutral since 2010.

Intrepid Travel also provided details of a number of schemes which it considered substantiated its positive impact on the environment. These were, it said, reflective of their daily business operations, such as its Seven Point Commitment Plan and Science Based Targets Initiative (SBTi) membership to reduce greenhouse gas emissions.

The ASA explained that, in accordance with the CAP Code, the basis of environmental claims must be clear, and that unqualified claims could mislead if they omitted significant information. The CAP Code further required that absolute claims were supported by a high level of substantiation.

The ASA considered that the advert misled and minimised the effects of Intrepid Travel’s holidays on the environment, in that these claims would not be interpreted by consumers in the narrow sense of the tour offering only, in that it did not include international travel to those destinations.

The ASA decided that the advert breached the Code, as the basis of the claim had not been made clear and no evidence had been provided to support the absolute claim based on the full life cycle of the product as it would be understood by consumers.