Nearly 10 months after initiating an investigation into advertising by the Royal Society for the Prevention of Cruelty to Animals (RSPCA), the Advertising Standards Authority finally published the Council's Adjudication concerning the complaint by the Adfree Cities about the RSPCA's respect "For Every Kind" campaign on Wednesday 7th May. Having worked with the RSPCA to defend this complaint, it's gratifying that the ASA concluded that the complaint should be 'Not Upheld', but the process has been frustrating and the drafting of the adjudication raises its own concerns.
The RSPCA's 'For Every Kind' Campaign
The campaign was launched to coincide with the RSPCA's 200th anniversary year, and to support its re-brand and new brand strategy. "For Every Kind" is a rallying cry to invite every kind of person to be kind in every possible way to all animals. It is not a campaign about any particular kind of animal, whether domestic pets or farm animals, nor is it about any particular part of the RSPCA's wide range of work, from lobbying government to improve statutory protection for animals, through to the prevention of animal cruelty.
The campaign comprised a YouTube video on the RSPCA's account (which you can link to below), a TV ad and a poster ad. The video and TV ad executions showed various animals, including some computer-augmented ones, singing an adaptation of Aretha Franklin's classic hit, "Respect". The ads end with on-screen text which states, "EVERY ANIMAL DESERVES OUR KINDNESS. RESPECT. RSPCA FOR EVERY KIND. SEARCH. SHARE. SUPPORT".
The complaint by Ad Free Cities
We have written before about the way that the pressure-group Adfree Cities has become adept at using the ASA to further their aims. According to our research, they have lodged complaints about at least 14 advertisers since November 2021, including banks, petro-chemical companies, car manufacturers, and an airport operator. In other words, mainly against 'high carbon' businesses or their financiers. Of these 14 complaints, one was not investigated because the ASA concluded there was no case to answer; 9 were upheld; 2 were upheld-in-part; and 2 were not upheld, including this latest one against the RSPCA. This strike rate could mean that Adfree Cities are very skilled at making their complaints; or it could mean that the ASA are rather too susceptible to their arguments; both two things could be true at once.
On this occasion, Adfree Cities teamed up with Animal Rising, another pressure group which was formerly known as Animal Rebellion, a splinter group from Extinction Rebellion. And their target was not a high-carbon business, but the oldest and largest animal welfare organisation in the world, which also happens to be one of the largest charities in the UK.
Although the 'Issue' section of the complaint was re-drafted by the ASA several times between sending the original complaint notification on 31st July 2024 and publishing the Final Adjudication on 7th May 2025, they eventually settled on "Adfree Cities, and two other complainants, challenged whether the ads misleadingly represented the welfare standards afforded to animals farmed under the RSPCA Assured scheme." Most of the previous complaints by Adfree Cities centered around the concept of 'misleading omissions'. For example, their complaint about the HSBC ad was that it trumpeted their investment in green energy, but omitted any mention of the bank's significant investment in fossil fuels, i.e., classic greenwashing through green spotlighting. On this occasion, however, the issue was not that the RSPCA's campaign did not mention the RSPCA Assured scheme, but that it misleadingly represented the scheme's welfare standards. To my mind, that argument is unsupportable because there are no express or implied references to the scheme, so there should never have been an investigation.
The background to the complaint was that Animal Rebellion had broken into a number of farms which were allegedly part of the RSPCA Assured scheme and garnered evidence of what they claimed to be mistreatment of animals. However, some of the farms that they had raided were no longer members of the RSPCA Assured scheme, and others had never been!
There is also a fundamental ideological difference at work. For their part, Animal Rising believe that everyone should become vegan, and no animal welfare scheme would ever be consistent with that ambition. The RSPCA, by contrast, believes that, as the overwhelming majority of the British public do not want to become vegans, the best way to protect the welfare of farm animals is to institute a voluntary scheme for farmers which raises animal standards above the legal minimums, but which is not so onerous that participation becomes commercial unviable for farmers. This is significant because the CAP Code says that the ASA will not arbitrate between competing ideologies, but it has arguably allowed itself to get dragged into that debate on this occasion, albeit unwittingly. The good news for lobsters is that all parties can agree that dropping them into boiling water while they are still alive should now be off the menu!
Going down the rabbit hole
The fundamental problem with this investigation is that rather than assessing the content of the campaign itself, the ASA allowed itself to be pushed into an investigation of Adfree Cities' allegations about the deficiencies of the RSPCA Assured scheme. The simple fact is that the campaign makes no mention of RSPCA Assured. Furthermore, the scheme accounts for less than 5% of the RSPCA's activity, and therefore did not need to be included to avoid a misleading omission.
It is gratifying that having conducted a forensic examination of RSPCA Assured and the allegations of Adfree Cities, the ASA ultimately concluded that, "We had not seen evidence that non-compliance with RSPCA Assured standards was a widespread issue in the RSPCA Assured scheme. We also acknowledged that in any assurance scheme some members would encounter compliance issues. We noted that furthermore, remedial policies and actions were in place and were activated for farms that encountered compliance issues. We concluded that the ads were unlikely to mislead about the care standards afforded to animals at RSPCA Assured farms."
It is troubling, however, that it has taken 10 months to resolve this investigation, not least because Adfree Cities were allowed to raise additional points after the first Draft Recommendation was distributed to the parties before Christmas. Defending the investigation has taken considerable time and money and disrupted the RSPCA's marketing and fund-raising. And even now, Adfree Cities are threatening a request for Independent Review, so perhaps the RSPCA should not count their chickens. However, in view of the recent Annual Report by the ASA and the statistics provided by Sir Hayden Philips about his work as the Independent Reviewer which we covered last week, it's more likely that Adfree Cities will find that their goose has been cooked.
Having taken the best part of a year to investigate a series of allegations that do not relate to the content of the ads, the ASA has published a decision of more than 2,500 words, most of which set out the spurious and irrelevant allegations by Adfree Cities, followed by the RSPCA's rebuttal and the ASA's affirmation of the RSPCA's position. Unfortunately, however, those spurious allegations have been memorialized by the ASA and will live on the ASA's website for the next five years. This is very unfair to the RSPCA and largely gives Adfree Cities and Animal Rising the oxygen of publicity that they crave.
Take the bull by the horns
The time has come for the ASA to look at its procedures for handling complaints by pressure groups. At the moment, their position is that if the issue raised is considered to be a valid one by the ASA, then they will accept the complaint. That is not unreasonable, but on this occasion, the ASA allowed Adfree Cities to have a second bite of the cherry when the first Draft Recommendation concluded that their complaint should not be upheld. This resulted in the RSPCA incurring significant additional delays, expense and inconvenience. The investigation was always misconceived, because the complaint was never really the RSPCA's advertising, but about the operation of the RSPCA Assured scheme.
It is perfectly fair for Adfree Cities and Animal Rising to advocate for veganism, but the ASA should not be providing a platform for their arguments about the legitimacy of farming of animals for food when that did not form part of the RSPCA's campaign. The ASA needs to be more rigorous in deciding when a complaint is simply a pretext for a lobby group to air its grievances. And if it does decide to launch an investigation, it needs to be as robust in its dealings with the 'professional complainant' as it is with the advertiser.
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