The material covers tactics regularly used by brands—and a few specific instances in which ads were banned by the U.K.’s Advertising Standards Association (ASA).
For example, HSBC ads claiming that the bank was helping clients transition to net zero and planting trees to capture carbon were banned by the ASA for omitting the fact that the bank is a significant funder of fossil fuel projects. A series of airline ads from Air France-KLM, Etihad Airways and Lufthansa from late 2023 were also highlighted for misleading consumers about the true impact of their operations—another example of factual omissions.
“I would not be surprised to see lots of companies start to say if you’re creating advertising for us, we want to be certified,” said Jeff Greenbaum, advertising lawyer and managing partner at Frankfurt Kurnit Klein & Selz. “We want you to have a basic understanding of how greenwashing can occur.”
Within each category of greenwashing are also more specific descriptions of the tactics used. Over-indexing, for example, is a type of factual omission that describes when a company focuses its marketing on a very small percentage of its overall business—like oil companies creating major ad campaigns around algae-based fuel, projects that constituted a tiny fraction of their budgets and were ultimately canceled.
Paltering, a type of factual distortion, happens when a company uses phrases that are “based on selective truths, but that end up suggesting something that on balance is not true and not verified by science,” explains the IAE Charter for Greenwash Prevention, released in tandem with the Green Shield training. Examples of paltering language include phrases like “cleaner burning,” “eco-friendly” or “climate-conscious,” the course explains.
‘It’s a matter of time’
Founded in 2021 by Wally Snyder, Linda Thomas Brooks and Susman, the IAE serves a purely educational purpose within the industry.
While trade groups like the 4As, ANA or other trade associations can lobby and advocate for their members in the political realm, the IAE’s 501(c)3 nonprofit status prevents it from engaging in those activities. The group released the first ethics training for advertising, marketing and communications professionals in March 2022.
“It’s a matter of time before agencies are named as third parties within some of those suits,” said Christine Arena, former evp at Edelman and founder of social impact production company Generous Films, pointing to precedent in other harmful industries like tobacco and opioids, where agencies were held liable for harmful client work.
