ESG Enforcement Tracker

Key facts:

The ASA investigated a poster and three paid-for LinkedIn posts for Lloyds, following a complaint from Adfree Cities that these were misleading on the grounds that they omitted significant information about Lloyds’ contribution to carbon dioxide and greenhouse gas (GHG) emissions.

The poster featured an image involving growing seaweed with the text: “Growing the business as fast as the seaweed used to make their packaging. Right now, good things are happening at [business name]”.

Two LinkedIn posts advertised Lloyds’ partnerships with Projects for Nature. The first with the wording, “We’re partnering with Projects for Nature to support nature recovery and engage communities across projects in England”; the second explaining that its funding “will support three projects that include: Creation of a 100-mile natural recovery corridor along three rivers in Sussex, helping boost biodiversity, reduce flooding and enhance the rural economy; Natural flood management in Cumbria, including re-wiggling rivers, planting trees and restoring wetlands; Working with partners and tenant farmers in the Peak District to establish more trees, healthy peatlands, thriving wetlands and grasslands and improve soil health and water quality”.

The third paid-for LinkedIn post was focused on Lloyds’ efforts to make its own operations more sustainable, “What are we doing to help accelerate the transition to a low carbon economy?”, with further explanatory text that to “reduce our reliance on fossil fuels and putting the weight of our finance into clean and renewable energy […]”. A video embedded in the post featured an animation that showed electricity from a power station being used to power business and domestic buildings and an electric vehicle (EV). The EV drove through agricultural land and a growing woodland. The video then cut to an image of the Earth with the superimposed text, “Helping Britain Prosper”.

The ASA found that the poster and first two LinkedIn posts were not misleading. While the poster featured a business which was developing a product that was likely to be seen as having an environmentally beneficial focus, the ASA considered that consumers would understand it to be a case study in how Lloyds supports businesses develop and expand, rather than being an example of Lloyd’s green business financing, more generally. It was therefore unlikely to be interpreted as making wider environmental claims about Lloyds’ business practices.

Equally, the ASA considered that consumers would interpret the LinkedIn posts about its partnership with Project Nature as being limited to a claim about Lloyds’ contribution to the platform and not wider environmental claims about its business practices.

The third LinkedIn post was found to be making wider claims about Lloyds’ financing of clean and renewable energy, and contribution towards a low carbon economy, including by helping its customers become more sustainable. Specifically, the ASA considered that the claim that Lloyds was putting the “weight of [its] finance” into renewable energy combined with the imagery was misleading, in the absence of any qualifying information. Investment in and financing of areas of climate risk comprised a notable amount of the company’s activities and would continue to do so in the near future. The ASA held that this was material information that was omitted and therefore the post was likely to mislead. The complaint was upheld.