Ambit Energy, the $1.2 billion energy services company, pays close attention to the regulatory climate because the nature of the company’s product—electricity and natural gas—is highly regulated. It should come as no surprise, then, that the company is also aware of FTC concerns about the portrayal of lifestyle imagery in recruiting materials for direct selling companies.
Ambit recently made a company-wide decision to remove all lifestyle imagery from its marketing materials. vice president of field development and support, Darrell Starkweather says, “We are proud of our leadership, the service we offer and the income opportunity we have available for those who want to participate. Lifestyle imagery may imply a certain level of success that not everyone aspires to. So, we removed the assumptions.”
The possibility of achieving a lavish lifestyle has been central to the marketing materials of many companies for decades. When asked whether the removal of such materials affected Ambit’s recruiting numbers, Starkweather said, “Not at all.” He went on to say, “We have only seen an upside. Removing lifestyle imagery actually makes the opportunity more doable. The prospect can create their own goals.”
Executives must fully embrace this fundamental change in order for the sales force to follow suit. Starkweather believes it starts at the top and must be woven into all materials. “‘Do not exaggerate the opportunity’ is at the core of our training and culture. It is taught from day one by corporate leaders and field leaders. It’s incorporated in their contracts, the tools they use to recruit and in ongoing trainings as they develop.”
In October of 2016, FTC Chairwoman Edith Ramirez delivered the keynote speech at the DSA Business and Policy Conference held in Washington, D.C. and clearly set forth the agency’s expectations concerning the use of lavish lifestyle photography in recruiting materials. Ramirez said, “A legitimate multi-level marketer must accurately represent its business opportunity and what a participant is likely to earn…It is time that MLM income representations matched the income reality of the majority of MLM participants.”
Ramirez includes “implied” lifestyle and income in her description of “deceptive” claims. She said, “These lifestyle claims, whether made through statements or images, are deceptive when made to a general audience because participants are unlikely to achieve them.”