Green IO
#23 Greenwashing and friends with Harriet Kingaby and Mathieu Jahnich
September 5, 2023
Our regular Green IO host Gaël Duez meets Harriet Kingaby and Mathieu Jahnich to get the low-down on greenwashing, and, more importantly, how to avoid it. Mathieu Jahnich is a consultant and researcher, and also a lecturer at Sciences Po, Paris, where he teaches responsible communication & marketing on several Masters programs. Harriet Kingaby is a strategic communications expert who focuses on responsible marketing and communications at the intersection of advertising, human rights and climate change. Together they cover multiple questions: How do you define greenwashing? How can companies effectively talk about their CSR actions and their move towards sustainability without falling into the trap of greenwashing? ... With concrete examples of best practice, and real-life case scenarios, Harriet and Mathieu also touch on the legal landscape, and the current and forthcoming changes that all businesses must be aware of. Don’t want to fall into the greenwashing trap? Listen in to find out more. ❤️ Subscribe, follow, like, ... stay connected the way you want to never miss an episode!
Our regular Green IO host Gaël Duez meets Harriet Kingaby and Mathieu Jahnich to get the low-down on greenwashing, and, more importantly, how to avoid it.
Mathieu Jahnich is a consultant and researcher, and also a lecturer at Sciences Po, Paris, where he teaches responsible communication & marketing on several Masters programs. Harriet Kingaby is a strategic communications expert who focuses on responsible marketing and communications at the intersection of advertising, human rights and climate change.
Together they cover multiple questions: How do you define greenwashing? How can companies effectively talk about their CSR actions and their move towards sustainability without falling into the trap of greenwashing? ...
With concrete examples of best practice, and real-life case scenarios, Harriet and Mathieu also touch on the legal landscape, and the current and forthcoming changes that all businesses must be aware of.
Don’t want to fall into the greenwashing trap? Listen in to find out more.

❤️ Subscribe, follow, like, ... stay connected the way you want to never miss an episode!

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Harriet’s and Mathieu's sources and other references mentioned in this episode:


[00:00] Gaël
“Hey boss, could we display our greener [website] hoster on the website?”. “Not so sure, I'm afraid of greenwashing.”
“Hey, boss, could we train our people in eco-design without bragging about it?” “Well, not sure. I'm afraid of being accused of green hushing.”
“Hey, boss, could we have a greener business travel policy?” “Well, not sure. I'm afraid of being labeled a green picker.”
“Hey, boss, will you ever give me some green light?” “Well, not sure. I don't want to be accused of green lighting.”
“That's a bad joke, boss.” “I know, but I'm not the boss - ‘Legal’ are bosses, and they are crazy scared with all these new laws.” 

Hello, everyone, does this chat sound familiar? With regulations piling up, it will become even [more] familiar. This is why I'm super excited to welcome two renowned experts on greenwashing in this episode: Harriet and Mathieu.
Harriet is based in London, and she has been the co-chair of the Conscious Advertising Network for more than five years. That's the media side of the coin. But she's also now the head of ACT Climate Labs, a project powered by Media Bounty, which aims to improve the communication on climate change. That's the tooling side of the coin. And before she took up these positions, she had a long list of experiences in PR, communications and branding with a sweet spot for sustainability. For instance, I discovered she used to hold a position as a sustainability strategist in 2012 - 10 years ago, that was not common. Kudo for this.
Mathieu is based in Paris. If you don't know where to find him, try LinkedIn; he spends quite a lot of time there busting false green claims and educating people via his straight- to-the-point posts and comments. Since he graduated with a PhD in Didactics and Science Communication (sounds very impressive), he has spent the following 20 years combining research and action as a consultant, focusing latterly almost 100% on responsible communication.
Welcome Harriet. Welcome, Mathieu. Thanks a lot for joining Green IO today. 

02:12 Mathieu  
Thank you, Gaël. 

02:13 Harriet  
Thank you for having us. 

02:15 Gaël  
So, to set the stage, I'd like to ask you my usual question. How did you become interested in sustainability? Did you experience some kind of lightbulb moment?

02:25 Harriet
So, at school, we were a class of kids who weren't particularly well behaved, I have to say, and one of our science teachers was obsessed with climate change. We worked out, as a kind of collective of 30 kids, that the only way to derail a lesson and to not have to do our science work was to get him talking about climate change. And I guess the flip side of that was that he was absolutely fascinating. And he was so passionate about it. It made me really interested in the topic, and I ended up studying environmental science at university and, spoiler, I am not very good at the science side, but I can talk about it. And so, from there, through doing some technical jobs and working that out, and then being pinched by the PR team, because I could actually talk about some of the science behind what we were trying to do, I've ended up here. And I'm forever grateful to Mr. Brown, my chemistry teacher for that.

03:29 Gaël
You just need one teacher to change the world. And that's a very good story. And what about you Mathieu?

03:37 Mathieu 
Well, it was like, an opportunity, I was sensitive to environmental issues. Because mostly when I was young, I spent a lot of time doing outdoor sports. I was very keen on doing sciences, and so that was my studies - in hard sciences. And then I read some kind of research paper, talking about how the media are talking about environmental issues. And I said, 'Wow, that's very cool, it seems something that is relevant and useful for society. And I would like to do that”. And I applied for funding, and so then I could do my PhD on those subjects. So that's how I became focused on this matter of environmental communications.

[04:24] Gaël  
So, it has been since your PhD 20 years ago, that you care about environmental communication.

[04:31] Mathieu  
Yes, nearly 25 years ago.

[04:36] Gaël
I was trying to be a good host here, but okay, let's go for the hard truth: 25 [years]. So, I'd like to use the opportunity of having both of you here to ask you some clarifying questions, and maybe my first and most obvious one is: what is greenwashing and all the other subspaces, which appeared recently? Maybe Harriet, could you shed some highlights on all these new terms?

[05:10] Harriet  
Yes, of course. So, there are quite a few different ways of defining greenwashing. And there are lots of different frameworks that actually you can use to look at [it]. But there are some particularly egregious practices that we commonly see. So actually, it's less common than you think to see just lies out there in the world. What we often see driving greenwashing is not necessarily organizations sitting down and saying 'How can we mislead consumers' (though we definitely see that). Often you might see an overexcited marketing team who were really proud of something that the organization has done, who actually, (I think, with the best will in the world), spotlight it, ignoring the other stuff that the organization does. So, think of an airline company, for example, talking about their vegan meals. And the problem is with even these quite innocent (well, I say, innocent, this is not innocent) but, you know, these kinds of well-meaning things, is that they mislead consumers. And that's the heart of this. And Matthieu, I know you've got very strong opinions about it. So, things like spotlighting issues that aren't relevant, things like shifting blame onto the consumer. Now, that's a very measured one. Think about Coca-Cola telling you their bottles are recyclable, but [they are] actually not doing anything about reducing the [amount of] plastic bottles that they produce. You gave examples within your introduction, Gaël, where actually organizations don't talk about all the good stuff that they do, they are afraid, and then they are missing out on an opportunity not only to normalize the fact that organizations are considering sustainability, but also to talk to consumers about ways that they can [be] better. So, at the core of this all, is, actually organizations talking about these issues in a way that's not helpful, doesn't enable consumer behavior change, doesn't change the behavior of the organizations themselves. And it's confusing, confusing and misleading. And the EU, in updating their green claims quite recently found, I think, that 40% of green claims are completely unfounded, use vague and misleading language. I mean, that's a huge one [misleading language] that we'll get into in a little bit. And so, what's happening is, actually, this is not helping the cause, consumers are overwhelmed. They're stressed out when they try and make these choices. And you know, frankly, as marketers, we've got to do a lot better.

[07:43] Gaël
That's crystal clear. And fun fact, I didn't know that green lighting existed. I made it as a joke. 

[07:53] Mathieu 
Oh, yes - it exists!

[07:55] Gaël
Okay. That's excellent. I'm cleverer than I thought. Okay - I'm actually luckier than I thought. Well, thanks a lot Harriet. Wow, quite a lot of definitions and concepts... And Mathieu, she mentioned that you have got a strong opinion on it as well. Could you share it with us, please?

[08:16] Mathieu
Yes, when I'm talking with brands, whether CSR teams, or marketing, or communications team or even the legal department, I am defining greenwashing as any message that may mislead the public about the true ecological quality of a product or service, or, about the reality of the company's sustainable development policies and approach. So, greenwashing is something that could be relevant at the product or service level, or at the corporate level. And then yes, you have different ways of falling into this trap. And I gave a number of examples. And so, this can be something very tricky. And I just tried to make sure that these people understand that it's a matter of: will the public be able to understand the quality of my product or my CSR strategy, or do I mislead or give false information or [do I give] unclear proof, etc.

[09:28] Gaël
Mathieu, do you follow, here, I found this article, so, there are several researchers who wrote an article on a systemic review of greenwashing, published in "Environmental Science Europe", [authors: Vieira de Freitas Netto, Marcos Felipe Falcão Sobral, Ana Regina Bezerra Ribeiro & Gleibson Robert da Luz Soares] - I need to check my notes, I must admit -  but anyway, they were explaining that you've got the deeper systemic review and the meta distinction between company-level greenwashing and product level greenwashing. And they also made a sub-distinction between 'executional' and 'claim'. Is it a framework that you use somehow as well?

[10:10] Mathieu
Not really. Of course, we are talking about that, because sometimes companies are asking for my advice regarding sustainability claims related to a product. And sometimes it's about the whole CSR strategy. But I believe that they have to understand the philosophy of the issue regarding greenwashing. And that is, "do I give enough information?", and, "Am I clear enough about what I do?", and "What are the characteristics of my products and services and my strategy?". I try not to be too complicated about definitions, about categories, you see, but to take examples, and to make them better understand why people could react like this, or like that, in reading their content. And it could be text, or images, of course, or both. So, I tried to leave the posture that could be too analytic, and to go to something more practical.

[11:27] Gaël
And could you give us one example (and I will ask Harriet to share another one after) about good practices, like you said, that you need to give the consumer the right information, the good information, not to mislead them. But how do you do that?

[11:43] Mathieu
So, in my opinion, the first point I would like to say is that it's really important to give good examples, because it's easier to criticize. To do this [to criticize], it is not good - ‘this is misleading’, ‘you should not have written this like that’, etc. And so, it is important to show good inspiring examples. But that doesn't mean that the company itself is green, it is just that this particular campaign or this particular message is well written. And it's interesting to see both creativity and the respect of deontology [following of rule-based ethics], and, of course, about [respecting] the law. So, some examples. It's also a kind of posture of communication. When I read the content of LinkedIn posts, for example, I can understand that the company in question has understood the ecological issues as a whole, and also that the company is not only focusing on climate for example, and on climate, they are not talking about neutrality, etc. And for some good examples in the tech sector, I'm sure you know about Infomaniak [a major European cloud provider]. Something that is interesting, is that they've got an environmental page, and the title is "We pollute - yes, we know our activity is polluting, and what do we do to reduce that?".  They are not trying to hide the fact that maybe they are compensating, or even that's why they do. So that is interesting. In another sector, in the apparel sector, there is a brand called Organic Basics. If you go to the environmental report or CSR report, there is a chapter about "our fuck-ups". And that's something very interesting, in my opinion, because they [Organic Basics] are okay to talk about what they wanted to do. And what they have failed to do about certain goals, that certain goals were not relevant, such as the goal of neutrality. Now, they admit it was not a good idea to set a target for neutrality, and from now on they will be talking about the reduction of the carbon footprint, for example.

[14:08] Gaël
What is interesting with these examples is (though I don't know if it will be the case for the entire episode), but I'm pretty sure you picked Organic Basics for their entire CSR strategy, but actually in the tech sector, and especially in the sustainable design sector, they are pretty famous for their websites. 

[14:30] Mathieu
Yes, their websites, very good, yes. Now because they're very good, and that's interesting, because they are talking about what they do in a way that is original. And they are trying to propose new ecommerce websites. And that's very good.

[14:53] Gaël
I think they try to be very consistent, and I guess, because I'm not an expert in communication, that is something very important. Maybe Harriet, do you want to comment on it, and also share some positive examples, as it's way easier for people to understand.

[15:09] Harriet
Yes, I completely agree. Let's talk about what's good. I mean, it's not [just] in the tech sector. But I do think that Oatly, with their, and excuse this [language], but their ‘Fuck Oatly’ kind of campaign, are really, really interesting in terms of the way that they are radically transparent about what their fuck-ups have been, essentially, and where they've got things wrong, and where there's either been a backlash where consumers have felt misled. And what's interesting, I think, is at least that Oatly's consumers, they are vocal, they are probably way more switched-on to environmental issues than your average [consumer]. But, you know, I think can be where some of the fear comes from, when organizations are trying to talk about their green credentials, is that they go "Oh, my gosh, there could be a backlash". You will always have people who are supercritical, that's the nature of passion. But what Oatly have done is they've really owned that, they've listed their failures, and they've said, "Look, this is how we've learned in response, and by the way, here's some of the press, and here's some of the comments that we've received, so you know what we've talked about".  And I think things like that, the brand is very, very good at being honest, talking, and turning that into a real a real virtue. And I just think it's very good. And I think, if more organizations were honest about their mistakes and addressed them in that way head on, then I think we could have a much more mature conversation, because also, people could learn from others. On a much more subtle note, there is a really great example recently of Samsung, in their washing machines range, actually using the legal status of the energy consumption of a particular product to talk about why that product was better, that the product had a benefit to consumers and was environmental. So, the organization leaned into the, the A-ratings, the re-'high rating' of their washing machine, and actually use that to make a green claim about how this can help consumers. And I think not from a fancy "we're a super environmental leader" kind of way, but more of "we've got a claim here, that's factually correct, that looks at the full usage cycle of the product and is beneficial to consumers". I think that's a really, really good example. So, you don't have to be a super ethical brand, and you don't have to be doing something that's completely beyond the pale to make a really good solid green claim that consumers can really see the benefit of.

[18:06] Gaël
Actually, I wanted to ask you the questions a bit later. But it's so fascinating that I'd like to ask you if you would be okay to work pro-bono for a non-existing [fictional] company today. But I would love to give you two or three cases where I've been struggling with the people I was working with, on how we should or we should not communicate? And of course, it's mostly examples coming from the tech sector. But I guess you can apply it to all sectors, so would you be okay to be our advisors today?

[18:43] Harriet
Let's do it.

[18:44] Mathieu
Yeah, sure. 

[18:46] Gaël
So, a very easy one to start as a warmup is: I want to put something on my website claiming that I've got a low carbon website. Unfortunately, sometimes people use a green website and actually that's the case, you know, you can use the Whole Grain carbon website estimator, or the ratings, and you've got a good rating. So that's an honest claim. Okay. The problem is, your IT department, (you're in the transport sector, for instance), and the IT department is something like 5% of the entire greenhouse gas emissions of your company, scopes 1, 2 and 3 included. What would you advise a company to do? Should they put on the label? They don't put on the label? Should they put it on, combining a specific way to communicate that it's not the main [source of] emissions but still, they are making some effort? What would be your advice, from both of you? Maybe starting with Mathieu...

[19:53] Mathieu
My advice would be, if you have somewhere where I can understand what is your strategy to lower your impact regarding climate change, and also other impacts, okay, because unfortunately, climate change is not the only ecological issues we are facing, then this claim regarding the low impact website is interesting, because it's true and because every single act counts. The idea is to put this information with regards to the whole strategy, and so we understand, as visitors of your website, or as clients of this company, that this is not your main action to reduce your impacts, and that you are clear about that.

[20:46] Gaël  
The orders of magnitude are explained.

[20:50] Mathieu
Yes, it cannot be the only element regarding your CSR strategy. But if it's one element among others, and that we do understand that the majority of impacts are elsewhere, then it's okay to put it on your website.

[21:05] Gaël
Okay, Harriet do you want to add something?

[21:07] Harriet
So yes, I would say, what Matthieu said, obviously, and then adding that extra element of your audience on there, because obviously, as you know from when you learn your skills as marketers, you always start with your audience. I would say that all of what Matthieu said, but also [any communication is] tailored and is adding value to your audience. So, whether your audience is a stakeholder, whether it's a b2b customer, or whether it's a consumer, that they can understand exactly what is being said, exactly what the benefit is, not only to the wider environment, but also to themselves. Because I think it's very, very important that when we're communicating all of this stuff, we absolutely we have that theory, that structure right, but we don't forget the mark, you know, what we've been taught in marketing, we don't forget to add value for the audience that we are talking to.

[22:04] Gaël 
That's very interesting that you mentioned the audience, because actually, that connects with my second case example, which happens quite a lot. You are a startup, maybe a scale-up. But not that big, you know, in the tech sector, and you don't have that much leverage, all your tech stack is on AWS, Google Cloud, or whatever. You do what you can, but you're in this kind of growth mode, etc., that could, we could discuss a lot about the growth mode of other tech sectors. But that's not the point here today. Anyway, there is this huge challenge of employer branding and committing your employee beyond just what your startup is trying to achieve. And being very sincere, you've got the HR, the lead, who comes back to you and says, "Well, we've run all this training, or this awareness workshop, like for example, the Digital Collage, or Climate Fresk, etc., we've been truly committed to that, because 100% of our employees have followed those workshops, and we allow them some time also to volunteer, etc., and I need to be more vocal about it. Because I need to strengthen my employer branding, I need to attract younger people, more engaged people, etc. What should I do? “. Because that's pretty much the only stuff that you've done, at least as a CTO, in raising awareness. And you don't have that much time or that much money or that much leverage on reducing the rest of your carbon footprint.

[23:35] Harriet
To be honest with you, the best ideas for how to make your organization more sustainable, they are going to come from people who are specialists who are working in these impact areas. And I think a lot of organizations miss a trick, because they have a couple of people who work on the sustainability of the organization, and they don't leverage that incredible hive-mind. What I would always suggest is, because there's two sides to this, the first of which is that, if organizations, particularly tech organizations who are so innovative, aren't leveraging, aren't using that innovation lens to get these better ideas from employees, and create networks of people within their organization who are making suggestions and making things better, then they're missing a trick. So that's number one. But that then spills over into your employer branding, as you said, because you have really beautiful, credible, stories, and lots of advocates within the organization who can kind of do your work for you. So, yes, you can have something that says, "Yes, this is what we do", as long as that plan is credible, and it is backed up, and there's a strategy behind it and it deals with your main impacts. And then actually what happens is, you know, you start to have points where if a potential employee starts to ask at interview stage ‘what actually do you do around sustainability’, you might have an advocate in the room. And one of the interviewers, someone in the room, might be able to just say, "Hey, you know, actually, we're doing this thing, I've suggested this thing, or I'm starting this initiative". And it starts to pay dividends. I think it's not just a communications thing here. It's about how you foster those networks of innovation within a company.

[25:23] Gaël
Yeah, for sure. So, you would be pretty open in communicating, that's a first step. And, and we can communicate about it without being at risk of being labeled, I don't know, "green-something"?

[25:41] Harriet
Just to add to that, the Conscious Advertising Network, there's a lot of culture change, behavior change that comes along with a lot of what we do. And for those that don't know, we've written these manifestos that give advertisers, CSR departments, etc., a plan for how to make their advertising more in line with human rights and solving climate change. So, you've got the guidance there, but we found the most effective kind of organizations within our membership group have actually created these cross-department working groups that are looking at how they implement these strategies. So yes, as an absolute first port of call, I think it's worth doing a sense check of some kind, of what you're doing, whether the strategy or the communications that are going externally do [actually] match up. Because it is so, so important that what's being said, and that what is being done are matching up, and that will make it so much easier to make really credible green claims, and to do this stuff well.

[26:47] Gaël
And so, Mathieu, would you put some pictures of these workshops, Climate Fresk whatever, etc., on the website, or on the sustainability strategy page, for instance?

[27:00] Mathieu
My first reaction to this [hypothetical] case would be that I don't quite see how a company could organize training and workshops without actually changing, and thinking about a CSR strategy, even if it's at the beginning. I'm sure that a startup that would organize all those training sessions, just like I had said, and some people would say, “We have to continue and to work together, and we have to do things about transportation, about our business model.” But I'm sure there would be other things to talk about, more than just the HR activities. And so yes, in my opinion, it's always good to talk about what you do. The idea is not to let the people think that this will save the planet, or that it is making you a green company. So, it's to talk at the level of what you are doing, and what are the values created? What is the lowering of the impacts on the environmental or social or societal issues? And so, my answer is yes. All will be in the words that you will use to talk about that.

[28:30] Gaël  
Context and order of magnitude basically, and a bit of humility, if I can read between the lines, okay. 

[28:39] Mathieu
Yeah, that's the key. Yes. 

[28:41] Gaël
Okay. That was rooted in reality for me, and I'm pretty sure, for a lot of the people listening. Before we jump onto the last part of this interview, and we talk a bit about ‘legals’, I'd like to grant you a treat, which is, do you want to share your worst case? Because we started with positive examples. And that's definitely what we should do. But if you've got to pick only one massive greenwashing advert or claim what would be your champion?

[29:20] Harriet
Hmm. Okay. Can I take two lenses on this? So, I think what we haven't talked about, and I'll just chuck this in here, is that, as well as the kind of greenwashing that organizations might do, intentionally or inadvertently, within the creative of their communications (I mean, my specialty is advertising so I'm going to talk from that angle), there is also the issue of when organizations don't think about climate and other forms of environmental misinformation in their media strategies. So, to give a bit background, advertising essentially funds our media, funds the CAT videos that we watch on the way to work, also funds our newspapers. And when we only think about the content, in this case, advertising, we're missing a trick. What we often see is we will have organizations with amazing environmental / CSR strategies. And we will see them inadvertently funding climate denial content or anti-science content, online, usually, or occasionally on television. And so, the worst things I've seen are brands such as, and I'm so sorry to name you guys, you know, but Lush and Ecosia, on things like ‘climate change is a hoax’ [published] online. And I think this is a risk that we haven't necessarily talked a lot about yet. And it's not greenwashing per se, but it's just a kind of institutional failure to think about, you know, this is what we call a disinformation economy. Because it's also that this kind of horrendous content [is] out there, that is being produced deliberately to confuse people, deliberately to mislead them as well. So as organizations, when we're thinking about how we tackle greenwashing, we should think about the wider context of myths and disinformation as well. And then just in terms of advertisements, the recent ASA ruling in the UK around HSBC, it's a real warning shot for high carbon organizations, and organizations that invest really strongly in the fossil fuel economy. [Such a] case was essentially HSBC spotlighting its sustainability credentials and what it invests in, whilst simultaneously investing hugely in fossil fuel projects, and the ASA (Advertising Standards Authority, UK) specifically called them out for that. And I think that it is just everything that is wrong with that worst kind of greenwashing where a brand essentially launders its reputation by spotlighting something whilst having this incredibly, profound impact on the world, on the planet we live in and on the people that live on it. So those are the two for me.

[32,28] Gaël
So Mathieu, you've got the right to share your two favorites as well. And the HSBC case is very interesting; I've seen it as well. And I really wonder how we will develop in France as well, because we do have the same issue with banks and actually, I guess, very honestly with teams in banks that are 100% sure that they are doing everything they could to save the planet, and a few folks next door or in the next building [are]doing the absolute opposite. And they don't talk to each other. It's a big organization. So, they stand on their feet, both of them, they're pretty sure of themselves, and that creates a lot of confusion in the public. But anyway, that was me commenting on it. But Mathieu, what are your two favorites?

[33,16] Mathieu
Yeah, my two favorites would be, one advertisement from Adidas in France, regarding the new Stan Smith [trainer] that was supposed to ‘50% recycled’. So, the claim itself was not really clear. The consumer could not know the exact proportion of the shoe that is made from recycled materials, whether plastic or other materials. But the main issue regarding this ad, and you can find this logo in Adidas stores, is it's a logo, with the shape of the earth, saying 'end plastic waste'. Meaning, with Adidas, in buying those shoes, we will end plastic waste. So, it's a very big problem because those shoes are recyclable at the end of life. So, this is totally misleading the public. So that's the first one, because it's a huge brand and known all over the world. And the second one is from Volotea, an air travel company. Their slogan was (it was a kind of a concour [competition] - I don't know how you say that in English). And the ad was saying "I would love to connect with nature, please fly me directly to Lyon, Vienna, Milan, etc.", and you could pick your destination.

[34,50] Mathieu 
Even if you were living in Paris, you could take an airplane to go to Lyon. And it was about reconnecting with nature - take a plane to do that?! And so, to me it's a very good example of the non-understanding of all our issues. Firstly, taking a plane is a problem, it is very impactful. But talking about nature, about reconnecting with nature by taking a plane, this is something that it says to me, "wow, you don't understand at all what we are facing today".

[35,31] Gaël
Two very clear examples, and I will of course put all the links to these different examples and rulings in the show notes, as usual, with all the other references that you shared.

[35,44] Gaël 
And now I'd like to share an experience that some of you have already had. If you're based in France, or if you're not based in France, but you use a VPN with a French IP address, you just land on the Google homepage, and there you will see a statement, a link, to what we [Google] do when it comes to sustainability, and a link to the sustainability strategy page. If you do the very same exercise with a US IP address, or actually from quite a lot of other parts in the world, you will see a very different claim, with exactly the same font being used, and exactly the same place in the homepage, which is stating "carbon neutral since 2007". And of course, the reason is that recent laws in France prevent such claims without a strong backing. And I found it a beautiful example of what is coming for many companies with the new regulations and the legal environment, that they will be facing more and more. So, Harriet, Mathieu, maybe, could you highlight the main developments? Where does it [new greenwashing regulations] happen? Is it mostly in Europe, in the US, in Asia, or some other places in the world as well, and what are the main regulations that companies should be aware of right now, either existing or forthcoming?

[37,17] Harriet
So I'm not a legal expert, I'll start by saying that. But I think to understand this space, you do have to understand a little bit of the legal background. So, forgive me, the legal experts out there, I am a comms person trying to explain it simply. So, what we've got is this rapidly changing landscape. The EU has released essentially a roadmap, a directive that's showing the direction of travel. And this kind of direction of travel is essentially one that means that there's going to be stronger and more precise kinds of regulations around greenwashing. And the way that they [the EU] have done it means that they've set a direction of travel, which is concentrating on things like vague and misleading terms. You talked about the 'carbon neutral' one there, which I would absolutely challenge anyone to define what carbon neutral really means and tell me what methodology there is for getting there. And of course, those kinds of vague terms, that's exactly what they're designed to do and that's exactly why they're misleading and confusing. So, those kinds of terms will not be allowed. Individual countries will need to adapt this direction of travel to their countries and to their own legal systems.

[38,58] Harriet
So obviously we will have different interpretations and different enforcement across Europe. But organizations do really need to be looking at this space and listening to the communications that are coming out from the EU. And we're all waiting for them to firm up. In the UK, what we are seeing is actually the ASA and the CMA [Competition & Markets Authority, UK] are starting to actually define where they're going, through using these kinds of landmark rulings. There have been several recently that are setting a precedent for where we think they're going. And I used the HSBC example before, of organizations signaling that they are cracking down on organizations who are spotlighting particular green things issues whilst ignoring the rest of the product lifecycle or the usage lifecycle, for example. And there was a recent ruling around Shell, which I think everyone in my climate social circle was very happy to see, where again, they're signaling that this kind of greenwashing from fossil fuel companies just isn't going to be allowed. They're talking about much stronger fines and much stronger enforcement around that. So, it is a really big business risk for organizations.

[40,03] Harriet
But what we know today is that it's going to look different across different markets. The US, with the political developments in the US, where the Republicans have majority control of the House, I don't think we're seeing an appetite for leadership there, frankly. We've got many organizations that work in the mis- and dis-information space, and who are being asked to provide huge amounts of documents to the US political system. So, I still see Europe as leading in this space, with close markets such as the UK keeping a very keen eye on what's happening and probably copying and using some of that. And I see markets like the [United] States being laggards.

[40,54] Gaël
Mathieu, would you like to comment on this one?

[40,57] Mathieu
My question now, regarding this hardening of the regulatory framework in France, in Europe and abroad, is, it's a good thing to have new rules and hard law tackling climate change. But the issue is what resources will be available to enforce the law, both financial and human resources. And for instance, in France, the neutrality claim is now strictly framed, but I can still see those claims in packaging, for bottled water, for example. And I don't know whether the directorate in charge of protecting the consumers are willing to fight against that, and to make the law be applied. So that's a question for me. At the European level, they are talking about having claims and labels to be checked by an independent and accredited verifier, and I don't know how this will be done. You have a very big number of companies that are communicating about their engagements, etc., and does that mean that every single claim will have to be checked by an independent party, and which one, and how much will this cost? So that's a very important sign that is sent by the European Union, that greenwashing is not an option, and that it's a drawback to the fight against climate change and against transition. So, it's important to fight it. But I'm waiting to see the final text and how it will be applied and followed by all the authorities.

[42,55] Gaël
Quick comment on this, because A), you're right, you need to have some resources to check and the willingness to check. I mean, I've discovered very recently that less than 10% of the French companies that are now legally required by law to disclose their carbon emissions have been fined, because the Ministry of Economy is still in 'educational mode'. I'm sure that a lot of the other French taxpayers will enjoy knowing that they can be in 'educational mode' because most of the time they're not with us. But that's me being maybe too populist. So sorry about that. But I was really upset when I saw that. The second stuff [B] is like if you don't provide resources, I mean, this controlling body, if you've got 20 civil servants to deal with a million claims per year, obviously that's also a very efficient way for nothing to happen. But do you also have some ideas about the level of the fine? Because GDPR, for instance, really changed the game because for the very first time we were talking about real money. Not real money for Facebook or Google, because 4% is still small potatoes for them, but for a lot of big tech companies, getting a huge fine, which is a percentage of your revenues, that's something very serious. That's a very tangible risk. Do you know something about the potential fines on green-washing?

[44,25] Mathieu
We had examples from the recent past. In Italy, for example, Eni was fined €5 million because of misleading claims. And in the Netherlands last year, H&M and Decathlon had to pay €400,000 and €500,000 (respectively) to NGOs, to avoid being sued by the authority in charge of protecting consumers. So that can be huge amounts. And that's another interesting point regarding the regulation, that NGOs will be more and more entitled to sue big companies.

[45,13] Gaël
Yes, that's a very positive message, at least for the B2C sector and the B2B company which has some kind of public visibility because then the B2B sector is not really the one that the NGO will go after because they also need some publicity to keep the ball rolling. But still, that is a very positive signal indeed. Okay, so I learned a lot during this episode, and actually I learned very tangible stuff that I think I will apply with some of my clients and partners. So thanks a lot for that. Maybe one final question to both of you, Harriet and Mathieu. You shared a lot of resources and we will put them in the show notes (I've already mentioned that). But do you want to add one or two podcasts, books, articles, thought-leaders that you believe people should follow when it comes to greenwashing? And I would say on a more positive note, responsible communication?

[46,17] Harriet
Sure. This is such a rapidly developing area for anyone that is on the Greenwashing front. ACT is hosted within an organization called Media Bounty. It's an ethical ad organization. We are doing a series of thought leadership pieces about navigating Greenwash. So go to Media Bounty's website and there's an event coming up in London on the 29th this month. As well for anyone that's based there. I do think that it is really worth following the rulings of some of these bodies. So going to the ASA's websites and looking at rulings around greenwash. I think looking at organizations, if you're kind of working in advertising and comms and you want to look at ways of doing things well, there's a community of people called Clean Creatives sorry, Creatives for Climate, who have a network. And it's a network of practitioners who are sharing good practice, sharing bad practice, and looking at how they can support each other. So I think if you're working in this space and you want to be connected to a community, I would definitely go to Creators for Climate and have a look at what's on there.

[47,40] Mathieu
I would like to point out a really good newsletter dedicated to the fight against greenwashing. The name is 'The Crisps' and it's a newsletter made by Lavinia Muth and Tanita Hecking. And these are two women working in the marketing and communication sector, especially in the apparel industry, and they are sending one newsletter per month and two per month if you buy the pro-format of the newsletter. And that's really good 'crispy' content, very good content regarding Greenwashing,

[48,24] Gaël
Thanks Mathieu and Harriett for joining Green IO and sharing all those new references on top of the others (references). I hope that you will keep on carrying the torch of responsible communication as high as possible. And I do hope that Green IO will help you in carrying it a bit higher after the release of the episode. Thanks a lot.

[48,44] Harriet
Oh, thanks so much Gael. And thanks for everyone for listening. It's been great.

[48,48] Mathieu
Thank you. Bye.

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