The campaign ran in 2004, and used a number of tragedies to highlight its big idea; that: "Reading HUMO Magazine is so good, reading it can distract you from everything." The first ad I saw was this one depicting two pilots reading HUMO, unaware that they are flying directly into the Twin Towers.
Design-wise, it's not even that clever. The blue sky (which is historically accurate from 9/11) uses its light colors as negative space to contrast the towers grey. The towers are framed by the view from the cockpit, and the pilots are obviously distracted looking at the HUMO. It's actually pretty boring to look at, but the intent is clearly to shock and show how distracting HUMO can supposedly be.
The next ad in the campaign uses the same shock approach, but this time uses the JFK assassination. The presidential bodyguard, who is supposed to prevent the President from being hurt is distracted by his HUMO.
Legally speaking, these ads have done nothing wrong; they're not breaking an copyright laws, they're not damaging anyone's reputation per say, and they're not obscene. They're just in awful taste.
So the issue isn't legal, it's ethical. To show how these ads are unethical, I'll use the American Marketing Association's list of Ethical Norms and Values to judge them. According to Altstiel & Grow, the AMA lists 3 Ethical Norms: "Do no harm", "Foster trust in the marketing system", and "Embrace ethical values"; as well as 6 Ethical values: Honesty, Responsibility, Fairness, Respect, Transparency, and Citizenship.
These ads violate one of the norms right off the bat: “Do no harm.” These ads are clearly exploiting horrible tragedies for their own benefit, and are clearly doing harm to those affected by those tragedies. They are also not embracing ethical values because they are obviously not respecting the dead and those affected.
All in all, these ads just feel wrong. Any campaign that uses tragedies to sell a product is clearly going for shock value and is without a doubt offensive. There has to be a better way to sell HUMO magazine.
HUMO is a Belgian magazine, written in Dutch, why they want to use American tragedies or print ads in English is beyond me. I can understand trying to reach a wider audience, but this is not that way. I would recommend focusing their advertisements on their existing market, to strengthen their base, and use things from Belgian history to sell a Belgian magazine.
Citations:
Altstiel, T. & Grow, J. (2013). Advertising Creative: Strategy, Copy and Design (3rd Edition). Los Angeles: Sage.
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