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How FinTechs can help reduce harm from gambling By Sharon Collard Please note: This blog discusses harmful gambling and its impacts. In July 2023, a team from the Personal Finance Research Centre, FinTech West and the lived experience-led charity Gambling Harm UK delivered a workshop to consider how FinTech can help reduce harm from gambling. This was a great example of ‘grounded innovation’ in action: bringing FinTechs together with people who have lived experience of gambling harms to focus on real-life issues and how to solve them. It highlighted useful products and services that FinTech firms already offer as well as opportunities for further innovation. Most of all, it showed the invaluable contribution that experts-by-experience like Gambling Harm UK bring to the table. We are grateful to Higher Education Innovation Funding for funding the workshop. A key part of the workshop was Chris Gilham, Julie Martin and John Gilham from Gambling Harm UK sharing their own personal experiences, which illustrated the complex and messy nature of gambling problems and their serious long-term impacts. Chris told us about having been diagnosed with Adult ADHD just over eighteen months ago at almost 40 years of age, and how he has battled with his mental health since his mid-teens and using alcohol to cope. Then when he was 30 years old, having had no previous interest in gambling, he saw an advert and that day, he decided to try it. He explained that whilst gambling initially made him feel calmer, it wasn’t long before he was suffering from gambling harm. After almost five years of harm he finally found recovery following a two-day gambling binge, when he was planning to win and leave money to his family before ending his own life. Julie described the severe financial toll that her ex-husband’s gambling had on her and her children, meaning she had to work four jobs just to pay off loans he had taken out in her name, as well as the verbal, mental and sometimes physical abuse that she experienced. John (Chris’s dad) told us about his experiences as the parent of someone with a gambling addiction, how his life and that of his wife and family had been turned upside down and his role now supporting Chris in his recovery journey, including helping Chris keep tight control of his money. These real-life experiences really resonated with workshop participants – even if they had no experience of gambling harms. Our rich discussion touched on many issues including the links between ADHD and impulse behaviours such as gambling; the fact that there is no single reason for gambling problems; and the normalisation of gambling-like behaviours in online games that are so popular among children and young people, through features like microtransactions and loot boxes that are played to get an edge. John reminded us that 55,000 young people aged 11-16 in Britain are categorised as ‘problem’ gamblers – a term which stigmatises those suffering from this illness – with a further 85,000 young people estimated to be at risk of harm from gambling. How FinTechs can help reduce harms from gambling There is no perfect solution to help someone control their gambling. Blocks, self-exclusion schemes and other features can all be circumvented if gambling has become the most important activity in someone’s life and dominates their thinking, feelings, and behaviour. Nonetheless, the workshop highlighted a whole range of things that FinTechs are already doing as well as challenges still to be solved, such as joint accounts that give more control and protection. It also illustrated the invaluable contribution that experts-by-experience like Gambling Harm UK can bring to the table in terms of product ideation, design, and testing. Data-driven early intervention: Starling Bank described how it had a specialist team that proactively contacted loan customers to offer help where their underwriting team identified potential harm from gambling (or where they were in other potentially vulnerable situations), including links to external sources of support. It accepted that the message won’t always land well with customers but in its experience, there was more positive than negative feedback from customers. Saying the right things, in the right way is key, which Chris, Julie and Julie all confirmed was so important, means testing the language and training staff. Indicators of potentially harmful gambling might include applying for large loans late at night and multiple gambling transactions across several sites in a very short space of time. Enhanced friction and control features: At a time when it is quicker and easier than ever to set up a new bank account or take out a sizable loan, there is significant potential to give customers more control over their spending from the get-go. This might be a bank account where you have to opt-in to be able to gamble rather than opting out; or a non-gambling banking app with enhanced transaction monitoring. Through its personal financial management features, Moneyhub enables its users to set up spending flags across multiple accounts, making it easier for people to see what they are spending on different expenditure categories (such as gambling) where they may want to exercise more control and set spend limits. As Chris attested from his personal experience, tools to help people set up, and stick to, a budget can be an invaluable part of someone’s recovery from gambling addiction, ideally with a human element as well. Joint accounts: As an affected other, Julie highlighted the problems that resulted from having a joint account with her then-husband. He took her earnings and their savings from the joint account to gamble leaving her in dire financial straits, but Julie was unable to close the account without his permission. While joint accounts nowadays offer both parties easier visibility of the account data, for example via banking apps, in practice there may not be equal access or control if one partner is the victim of coercive control or financial abuse. Other research has highlighted the potential for a safer joint account using Open Banking payment initiation, but while the technology exists to build such a product, it is not yet available. Help to rebuild finances in recovery: John wanted to see financial services do more to support people with gambling problems to achieve sustainable recovery, by helping them rebuild their finances and their credit rating. Partly this is about raising awareness among FinTechs and other financial firms that gambling addiction is an impulse control disorder; and that people in recovery may be returning to a life they need help to cope with. In practical terms, it is about helping people build their finances so they can rebuild their lives, for example offering lower interest rates to people who have shown they can stick to a loan repayment schedule; allowing people to pay back debt over longer periods without penalising them; providing money management features such as ‘account sweeping’ to help repay debt or to start saving. Make gambling harms a normal thing to talk about: making it normal for us to talk about gambling harms and their potentially devastating impacts makes a lot of sense, given that millions of people in the UK are affected – not just the person who gambles but those around them as well. And taking the conversation to FinTechs and other financial services firms has the potential to stimulate even greater innovation for good. “Thank you so much for speaking to us in Bristol today. You really brought home how important it is for financial service providers to engage and to think bigger and better about how we can prevent and reduce harm and aid recovery. And for me most importantly, some immediately actionable insights which we can do something to address now in our own lending practices. Every step in the right direction, however, small, is very valuable in making change.” James Berry CEO, Great Western Credit Union. “Thank you for organising such a fascinating yet poignant discussion. Matthew Barr, John Dyer and I left energised planning how we at Moneyhub can do more to support those affected by gambling harm and how financial institutions can position themselves as a first line of defence to protect those who are vulnerable.” Jonathan Bell, Sales Director (Decisioning), Moneyhub. If you have been affected by any of the issues in this blog, you can contact the National Gambling Helpline which provides confidential advice, information and support by telephone and webchat free of charge. To find out more about the work of Gambling Harm UK, please contact John Gilham, CEO: john@gamharm.co.uk

As Gambling Harm UK we believe the voice of lived experience is important in helping to inform those changes required to reduce gambling harm. We have been approached by the Gambling Commission to ask if we could assist them in bringing this opportunity to the awareness of those who may fulfil the criteria to undertake this role. The Gambling Commission are looking for people aged 18+ living in the UK, who have personal experience of gambling related harm to join their Lived Experience Advisory Panel. They currently have 8 – 10 vacancies available for these roles now that some of their members 4 year terms are coming to an end. If you would like to find out more about the role then please use the link below: Info (gamblingcommission.gov.uk)

Our purpose as Gambling Harm UK(GHUK) is the relief of those who are in need as a result of a gambling addiction or gambling-related harm and their families through: a. Improving and providing education towards matters relating to gambling harm and addictions by using an evidence-based public health approach, with a focus on discussions on recovery of those suffering harm; b. Improving the health of those suffering from gambling harm by promoting addiction recovery, the mitigation of harm, and preventing harm in the first place through the development and dissemination of insights, advice and support; c. By engaging with and/or conducting evidence-based research that helps to further understand gambling harm and addictions’. Last week we looked to help make a difference by attending a workshop that Sharon Collard, Research Director at the University of Bristol ‘s Personal Finance Research Centre had invited us to. We met with her, Stuart Harrison Director of FinTech West and with a number of other FinTech organisations. These organisations had responded to the opportunity to meet members of GHUK to learn more about gambling harm, and to discuss and consider how FinTech can help reduce harm from gambling in the UK. Financial technology (better known as fintech) is used to describe new technology that seeks to improve and automate the delivery and use of financial services. ​​​At its core, fintech is utilised to help companies, business owners, and consumers better manage their financial operations, processes, and lives. We discussed a range of topics around both opportunities for prevention and for supporting sustainable recovery of those who may have been harmed. The interest shown by those present and their commitment to helping reduce gambling harm was refreshing. Hearing the positive conversations between the different organisations on ways they may be able to help was inspiring. Following the event, several positive messages were sent to us from those who had attended. Two examples of these are shown below: James Berry CEO at Great Western Credit Union “Thank you so much for speaking to us in Bristol today. You really brought home how important it is for financial service providers to engage and to think bigger and better about how we can prevent and reduce harm and aid recovery. And for me most importantly, some immediately actionable insights which we can do something to address now in our own lending practices. Every step in the right direction, however, small, is very valuable in making change.” Jonathan Bell Sales Director (Decisioning) – Moneyhub “Thank you for organising such a fascinating yet poignant discussion. Matthew Barr, John Dyer and I left energised planning how we at Moneyhub can do more to support those affected by gambling harm and how financial institutions can position themselves as a first line of defence to protect those who are vulnerable.” We will continue trying to make a difference at Gambling Harm UK by engaging with organisations and others to help increase their awareness of gambling harm so that they can support us in achieving our purpose. Improvements don't happen overnight. But one step at a time, hopefully by engaging with organisations such as FinTech things will start to improve, and if financial institutions can position themselves as Jonathan Bell says as a first line of defence to protect those who are vulnerable, then harm may be prevented and sustainable recovery achieved.

Following the success of Gambling Harm UK's - Real Patient Simulated Based Medical Education (RPSMBE) Upskilling Programme developed in 2022, we have now developed a second new training programme for medical students. This programme was delivered to year one medical students at Imperial College on the 5th June 2023. The feedback on the new programme was excellent and we will be now looking to offer this programme to medical schools along with our RPSMBE programme. The new programme has been designed to achieve two learning objectives for the students: · The first is to help them achieve an understanding of gambling harm as a public health issue. · The second is to increase their understanding from a clinician’s perspective. A short summary of the evaluation feedback from those students who attended these new workshops, along with testimonials from Doctors Donovan and Thakerar who we worked with to plan the new programme are shown below: Dr Molly Donovan: The workshop by Gambling Harm UK for Imperial medical students was really impactful. It broke down the complexities of gambling harm and provided unique insight through lived experience which set it apart from conventional teaching methods. Students gained both practical skills to identify and address gambling harm, and a wider awareness of the need for a multi-faceted, population level approach in tackling the harm from gambling. I strongly believe that all medical students should have the opportunity to attend a workshop like this. Thank you, John and Ben! Dr Viral Thakerar: The session delivered by John and Ben for our medical students was a powerful call to action. The blend of neuroscience, data on harms from gambling including on affected others, film clips, lived experience and discussing what clinicians and wider society should do, seemed to resonate with our students. There were plenty of thought-provoking questions and responses throughout the session. SUMMARY FEEDBACK FROM STUDENTS At the end of each of the one hour and fifty-minute session, students were asked: Would you prefer more, less, or the same amount of learning on gambling harm at the Under Graduate level? Responses by group were as follows: Group 1: 27 attendees (17 responses submitted via Menti) Less More The Same 0 3 14 Group 2: 24 attendees (13 responses submitted via Menti) Less More The Same 0 1 12 In response to the question: What is your key takeaway message? Students responded as follows: Group 1: Gambling is a learned behaviour Gambling is very common The process of gambling is just as rewarding as winning the bet The harms of gambling and the way the industry uses tactics and marketing to get people into gambling Affects more deeply than previously thought There is a strong psychological & biological basis behind gambling Gambling can affect anyone, and may not show immediate signs Gambling can affect every aspect of life That gambling is an impulse and that although it may be due to neural circuits developed in the brain and life stressors, there's a huge degree of responsibility on gambling companies Gambling is more widespread and more harmful than it seems. Significance of MECC (Make Every Contact Count). Also ask about gambling when relevant in patient history taking There is no deliberate choice involved in gambling and the process is as rewarding as the satisfaction of winning. Gambling harm can manifest in several forms That gambling is a hidden addiction which needs to be treated with good support and empathy The gambling industry heavily encourages gambling much more than I originally thought Loss-chasing, crime, disguising losses as wins, bright imagery to camouflage bad habit The effects gambling can have on all aspects of someone’s life Gambling harm can have varying extents between individuals. Gambling harm can include financial, social, cultural legal. It’s a behavioural addiction increased by the industry but helped by charity, NHS There are various different methods the gambling industry uses to get people to gamble more Not enough awareness on gambling as a public health issue Not enough updated legislation on gambling after phones Not enough research on gambling Gambling can occur due to an array of different factors, not solely down to the idea of making money quickly Group 2: Gambling is a serious disorder Gambling disorder can affect not just the person suffering but the people around them Gambling can affect others as well as the gambler Gambling isn’t always a matter of being irresponsible Gambling is a disorder - not the persons fault Gambling can affect you and those around you The process of gambling is almost the same in the brain as winning. It's an uncontrollable impulse disorder that can affect anyone Gambling is not the gamblers’ fault and is more than just a lack of willpower Gambling harm affects mental health greatly The harm caused to the individual and affected others Gambling can affect anyone and is a much more prevalent problem than I previously thought Gambling is a health condition Important to not look at people gambling with prejudice but instead be open to help them especially as clinicians There are many reasons why someone may gamble It is not normally mentioned in consultations and hence should be asked about whilst taking a social history. Be aware of the many aspects gambling can affect in someone’s life Gambling has many serious repercussions for the person gambling and their relationships with people around them Gambling may likely need intervention When asked - What did you like most about the session? Students gave the following responses: Group 1: Interactive Interactive, liked the videos shown and thought the content was very engaging. Engaging, interesting topic, like the way it was delivered with videos Personal anecdotes Personal experience of facilitators Used personal experiences to make the point. The cases and videos I liked that personal stories were shared which showed us that gambling affects normal people too. Liked the video and the gamblers story Enthusiasm of the talkers It was very informative and comprehensive Very informative and personal story The organisation Group 2: Informative Very interactive and videos were helpful and engaging. It was really informative, as I had never given gambling much consideration before. The videos It was very informative and interactive. Very multifaceted, with multiple causes and effects explored Talking about the techniques Gambling companies use. Very enlightening session and highlighted the issues of stigma Information given aside real-life stories When asked - What did you dislike most about the session? – Key themes were Would have valued more opportunity to speak with facilitators during the session A little long and may have benefited from being broken down into more than one session or done during earlier in the day. Wish a greater proportion of the time could have been allocated to personal lived experience stories Maybe more of a group type discussion rather than lecture style Leaving Nothing - Nil Facilitator ratings given by students: Group 1: 14 Excellent, 3 Good Group 2: 11 Excellent, 2 Good.

Well, 25 years have passed, and in all that time, whether I knew it or not, I was living as an affected other through gambling harm and my husband's mental illness, which brought on his coercive and controlling behaviour. What is my life like now? It's not perfect. I am and will always be an affected other, but with help from the gambling harm community and teaching myself to look after me a lot more, I feel better and know there is a happy future ahead. I still miss my family life and having my husband, a partner, as, at times, it can be lonely dealing with everything by myself. Occasionally it is challenging, but you grow, and your resilience grows. I now have a fantastic job with Gambling Harm UK. It has been such an insightful few years. Sadly, this must change soon, but I've enjoyed every second of being able to give back, bring awareness, and teach others about what I've been through and how it feels to be me. I have hopefully helped both affected others and recovering gamblers to see their lives differently and to have hope for their futures and ultimately know that we can get through this. There is a way out and a light at the end of the tunnel. My work with Gambling Harm UK has been a key part of my journey to a new future. Over the last year my work has mainly been within schools. A project we have worked very hard on has now brought gambling harm awareness and the potential dangers of gambling to around 8000 young people aged 14 to 24, which is so important to me. One thing I strongly believe in is prevention, which is so much better than a cure. So the more young people we can talk to, the more we can bring awareness to, the better it is. The white paper “High Stakes” gambling reform for the digital age, was recently issued by the government. It was so anticipated and long waited that, unfortunately, I think for many of us, it was an anti-climax. Still, the gambling harm community must be proud of the work that everybody has done to lobby parliament and government about the people we have lost and the many living with gambling harm today. These people have gone through so much due to gambling harm that although the white paper did not make the changes we wanted, it brought inroads to where we wish to be. I've always thought we shouldn't rely purely on government and legislation change to make a difference. I think the real change will come from our voices, those with lived experience of what gambling harm means. People will begin to hear what we're saying, understand the real potential impact of this harm and realise that this addiction is a medical disorder which impacts people’s wellbeing both physically and mentally. Hopefully, this will enable those who can gamble safely within their financial limits to carry on doing so. And for those who are at potential risk of harm to be able to seek help faster than they ever did before and then potentially save themselves, their partners, and their families the upset and the sadness that can come from the gambling harm. The other work Gambling Harm UK has done, which I was privileged enough to be part of, was taking our Charity's real patient simulated-based medical education programme to Anglia Ruskin University School of Medicine and having a day with year three medical students going on to be GPs. I found this a fantastic and very emotional day. Getting feedback from these 23/24-year-old young people who are already on a long and challenging route towards their goals for their future that our stories were so helpful and would enable them to become better healthcare professionals was so amazing to hear. They all said they did not know how gambling harm could affect people so badly. So, our work with these students will make such a difference in the future to every person who walks into their GP surgeries and talks about the symptoms that they're having. These future new young GPs will now consider when they meet patients “is gambling harm occurring in their lives?”, and if so, they can get them the help they need and the support they're crying out for so much quicker because the stigma of gambling harm stops people from speaking out all too often. I am very proud of my new voluntary position with Healthwatch Essex which has resulted out of the work Gambling Harm UK is doing with them. I'm now an ambassador for their mental health and trauma programmes, which means I get to sit in and talk to others like me, with professionals from the NHS, and various people from county councils. We discuss the issues with the support network for people with mental health issues. We talk about trauma and how it affects people in their daily lives, and what support is needed and required for these people. I will attend events this year where we bring everybody together. Again, awareness is brought to the needs of many people in many different situations. So, I'm trying to say that being an affected other doesn't mean your life has to continue to be negative. If you work and try hard enough, you can turn things around and make it positive. I think that is probably the best thing I've done so far. That's what I've managed to do more than anything in these last 18 months. I felt safe and secure with the people that I've worked with. I've been happy that my children finally have the support and the network they need around them to survive what they have been through, the trauma and the pain they have seen. I am happier that I have learnt to understand myself a bit more. I am kinder to myself now; that is such a significant learning curve I needed to discover. What must you do now to help yourself as an affected other? It is essential to talk and share your feelings and questions. There are many charities and organisations online that you can get in contact with (see below for details). I found that exercise also helped me. A five-mile walk with my music playlist for company was always so helpful in clearing my mind. I am also an avid swimmer, so 50 lengths a few times a week meant an hour where I couldn't think about anything and enjoyed an empty mind. Have you thought about Mindfulness? An opportunity to release yourself from daily life. A few moments of inner peace and relaxation, breathing and allowing your stress or anxiety to leave you. It's a technique that's not easy to master but so well worth it when you can catch that five minutes of peace. Remember, you are so important. As an affected other, I am sure you will have your life consumed with others, their recovery, their worries, and their anxieties. But it would be best if you looked after yourself too. Never undervalue your worth, as you are priceless. Please find below our link to Life Changing Fund Raising opportunity, I would be very grateful if you would be so kind as to donate anything you can afford to help us to continue our work. https://www.gofundme.com/f/dzyc74-a-lifechanging-opportunity Other support organisations: https://gamfam.org.uk/ https://www.betknowmoreuk.org/ https://www.gamblingwithlives.org/ https://www.gamlearn.org.uk/

How have I been since November of 2021, when sadly, my husband took his own life in a gambling-related suicide? To be honest, I thought I'd already reached my lowest point. It was at this point I realised I hadn't. It was such an awful time for the children, me, my family, and my friends. It felt like I was living in a dream, a nightmare, a film. It has taken me months, if not longer, to come to terms with what happened, and when I say come to terms, it doesn't mean I still understand it. It doesn't mean I'm over it. It means I know a little more and understand why we lost him. I was working in a dementia care home on the evening my husband died. I was driving home when I received a call from my son to say his father was shouting and banging on the door. I remember the sick feeling in the pit of my stomach, how scared I felt, and how much panic. I called the police and knew I'd get help but never realised his intentions or plans that night. I would have done anything to save him. I would have done anything to stop what happened, and the guilt I felt for months afterwards was awful. I now understand there was nothing more I could have done. He was at a point and a place where he had lost all control of reality. I'm so sorry that he didn't accept the help offered over the previous months. Again I had to seek help and counselling for myself and my children. At that point, I was working very hard in my 12-hour shift job with the care home and also part-time for Gambling Harm UK. I was fortunate to have the community around me, like-minded people who understood a bit more about gambling harm. Who helped me through my very darkest days. I think working kept me busy and my mind active. It was at night though I didn't sleep. I would lay awake just thinking about what I could have done to change the outcome. What could I do now to help my children? Where was my life going to go? Due to COVID, we had to wait a long time for the coroners inquiry. Hence, it was nearly the year's anniversary of my ex-husband's death. I relived the night again in court, which was a challenging and emotional experience. A year after his death, I began working full-time with Gambling Harm UK. Getting involved with awareness workshops, talking to others in the gambling harm community, and being brave enough to share my story with others. Collaborating with charities like Gambling with Lives has been great, taking us to Parliament to talk to MPs. Trying to make them listen and understand that the regulations' white paper needs to be published. I've even been on the radio now and had a few interviews, and although I get nervous, I'm proud I can bring awareness and talk about gambling harm and how it's affected my life. As I talk about my life and experiences, I hope to help remove the stigma of gambling harm by being honest and open about my emotions. I don't want anybody else to go through what I have been through. I don't want anybody else to feel the sadness, hurt and stress I have felt over the years. I hope by opening up. I can normalise discussing gambling harm and being an affected other, like the normalisation of gambling adverts on television, radio and in sports. We need to ensure that the Government, authorities, and gambling industry start to listen and, most importantly, assist charities to help reduce gambling harm to a much lower level than it is today. I think my mental health is the main thing or the most challenging thing about the last 15 months. How I've managed to keep going some days, I don't know. I've struggled so much that it has been hard to carry on. I am fortunate to have talked to professionals who immensely helped. I feel privileged and grateful to have worked with and known some fantastic colleagues who have helped me. It has been an uphill battle, a daily one, fighting myself, fighting my thoughts, and trying to adjust to what being an affected other means to me today and in the long term. As I've said before, I know things will get better. I see them getting better. What doesn't change is what happened. Always in my mind and heart, but I've got to learn to live with that. Use my positivity and work to ensure that my life and my children's lives move forward in a healthy, happy, positive way. In the next and final part of my story, I will share some more about how working for Gambling Harm UK has enabled me to start to re-build my life and give me some proud moments in what has often being challenging days. I will also share some of things I am doing on my journey to re-build my life. If you or anyone else you know is suffering from gambling harm, then please consider accessing the services that are available. Over recent years services have started to improve and more are available today to help those like me, the affected other. GamFam is a support service I use myself. They offer support through GRA5P – The GamFam Recovery and Support Programme. GRA5P is a structured 5-stage self-help peer support programme, which was designed to support those affected by someone else’s gambling. More recently and out of increasing demand they have also now developed a programme to support those in recovery too. I wish I could have accessed their service when I first needed help back all those years ago. You can find more details about all what they do at www.gamfam.org.uk Services for affected others are also available through GamAnon www.gamanon.org.uk and Gamcare at www.gamcare.org.uk

Trigger warning: This article contains images of gambling ads that may be distressing or triggering to some individuals. If you may be adversely affected by viewing gambling ads, please proceed with caution or refrain from reading this article. Gambling-harm has been increasingly recognised as a public health issue globally, with the WHO reporting that the amount of years of healthy life lost from gambling-harm is on a similar level to the healthy life lost from alcohol misuse disorder or major depressive disorder. One key tenant of UK regulations on the gambling industry includes the protection of children. Notably, children are at-risk of suffering severe harms from their own gambling and from another’s gambling such as a parent’s. It is important to highlight that gambling harm in young people is not a rare occurrence, in fact, the Gambling Commission (GC) reported in 2020 that among 11-16 year olds in England and Scotland, 4.6% have experienced gambling harm from their own gambling and 5.5% were harmed from a family members’ gambling in the past year. There is a growing evidence-base that demonstrates how gambling products and industry practices maximise yields by manipulating cognitive biases and by framing gambling as a widely popular low-risk or no-risk source of entertainment; with such messaging engineered and delivered through a £1.5 billion annual advertising spend. Game design and related advertisements are recognised as being likely to contribute to appeal of gambling and therefore gambling consumption in younger people. As such, following the introduction of the Gambling Act in 2007, the Advertising Standards Agency (ASA) set rules and advice for gambling ads which must adhere to the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) and the law. In 2017, the GC and the ASA were among the signatories of a letter that ordered 450 online gambling operators to remove games such as “Jack and the Beanstalk” and “Pirate Princess” as ads for these games were deemed to be likely to appeal particularly to people under the age of 18 and were freely accessible. Five years later, in April 2022, The Committee for Advertising Practice (CAP) announced new rules set to come into force on 1st October 2022 that replaces “particular appeal” with a “strong appeal test”. Within the guidance, there are themes to help guide operators towards compliant gambling ads so that they are not of particular and more recently strong appeal to children, and these include: Use of licensed characters must be responsible, Cartoon animals, fairy tales and colourful, exaggerated graphics are likely to appeal Names may also appeal particularly to children In our study, a selected sample of fifteen slot-game advertisement images, that were freely available online on platforms belonging to ten of the most popular gambling platforms, were explored in relation to the ASA CAP Code which sought to prevent advertising that is of a particular appeal to children and young people. Our survey results composed of ninety participants who engaged with our charity’s social media and website, show that the majority of participants found each of the images as having a particular appeal to children and young people and so in breach of ASA guidance. In conclusion, whilst the survey was limited in scope and the participants were non-representative of the national population, its results indicate that the gambling games in this survey have a particular appeal to children. Indeed, across eleven of the fifteen ads in our survey, a majority of respondents identified at least two of the three ASA’s themes as being causative towards particular appeal to children and young people. While Gambling Harm UK welcomes the strengthening of ASA guidelines which took place in October of 2022, the guidance based on a ‘strong appeal’ rather than a ‘particular appeal’ does not appear to have yielded a marked reduction in the availability of games selected in our survey. Note: While Big Bad Wolf was no longer available on 888Casino on 25/02/23, it was found on Unibet’s website. Similarly, while Frozen Gems was no longer available on Bet365 on 25/02/23, it was found on Genting Casino’s website. Gambling Harm UK urges the ASA to investigate the games included in our survey. Further, due to the significant nature of gambling harm and the vulnerability of children and young people, the ASA should take a more active role in examining gambling products for breaches of its guidelines. The ASA should also consider whether current guidance is sufficient in protecting against normalisation and trivialisation of risk. Full report:

I know that my story as an affected other is one of the more severe ones, but it is a true story and an example of how gambling addiction, an illness, and an impulse control disorder can devastate lives. And what is the root cause of this? In my view, it is an industry where making money is seen as more important than people's and families lives. Will that change? Well, not likely unless those responsible for causing gambling harm are personally held accountable. However, if more people start to share their stories as affected others, and more data is collected, we might help bring the needed changes. This first part of my story details my life as an affected other until November 2021. In the following two parts which I will post over the coming months, I will share what I have learned about gambling harm, things I wish I had known and could have looked out for, and what I would do today if faced with the same situation. Then in the final part, I will talk about starting the journey to rebuild my life and the work I do as the Project Officer for Gambling Harm UK. As I said, I hope that by sharing my story, others will feel able to share theirs. I hope it will start to remove the stigma around this illness that leads many not to seek the help they need. The gambling industry has normalised gambling. I hope together we can normaIise talking about gambling harm. If we don't, others will suffer from gambling harm, behind closed doors at home, in their workplace, and at school. Their mental and physical health will be harmed, just like mine. I believe where I am now was my destiny, not a destiny I would have chosen, but one where now I can and must try to make a difference. I need to start my story by saying this is a never-ending story. What I went through has changed my life forever. That's not saying things can't or won't get better, but being an affected other will always be there. For most of my married life, I have suffered gambling harm due to my then husbands gambling disorder (an impulse control disorder as I know it now). My harm manifested from medium to severe over the last 15 years, and I can probably describe them best in three stages. I came from a family who never gambled, so my husband's enjoyment of the lottery and football bets did not flag any alarms initially. During a period of financial difficulty, when the children were six and ten, he worked two jobs, but money still wasn't coming in. He worked day and night, so he was out of the house most of the time. I was proud of his efforts. It was only when a bank payment of a loan of 10,000 pounds for a car went missing and wasn't paid to the bank as promised that my life started to crumble. I was left answering the bank manager's questions and so confused and scared, apologising for the missing payment. At this point, I found out he had been spending nights gambling away all his earnings in casinos. He became angry when he had to start to admit his actions. If I could use five words to explain my feelings, I would use shame, shock, fear, panic, and anger. How could my husband be irresponsible, stupid, and selfish to do this to us? Over the coming months, our debts grew higher, as did my stress and anxiety. My husband became less willing to talk. I had to juggle five credit cards to live, sometimes having hardly any food left in the cupboards with two children. I hid it all from my friends and family as his gambling intensified. Despite everything, including living with his anger, my love for him and my lack of understanding of his addiction made me feel I could save him. However, he threatened me and wouldn't let me go anywhere or do anything alone. He told me he would kill me if I tried to take the kids and leave. My fear grew, and after a particularly nasty evening and my daughter's fear, she contacted a family friend. The call resulted in his arrest for harassment for leaving threatening messages on my phone. We separated, and a restraining order was placed, so he couldn't contact us. I told the police about his gambling issues, but they did nothing to help him. I got domestic abuse support, and my family then had to be told what had happened. It drove a heart-breaking wedge between us all. Everyone was so confused as to whom he had become. It was so easy for all of them to say he was gone. You're free of this horrible life, be happy now. But what about me? What about my love, relationship, loss of a man I married, or feelings? We were separated for six months. I contacted Gamcare after researching on the internet, looking for help. I got some telephone counselling to help me. Also, a visit to the GP got me antidepressants and six more counselling sessions. That was all the support I got back in 2012. Things have improved today, but I was left alone and vulnerable with two young children. My family and friends were disjointed from me. Nobody understood. I began to allow him back into my life. I thought I was doing the best for the children. I loved him so much and believed he had changed. He came home, and after a few months, my family did accept it. I felt torn and guilty between my husband's and my parent's feelings, pulled every which way. We had a good five years, he stayed coercive and controlling, but I had become stronger too. My research and my group work with GamFam taught me about the disease that is gambling. I understood why he couldn't stop and the impact of dopamine running through his brain that had developed a craving which he couldn't control. I tried to learn to look after myself a bit more as well. But the stress was always in the background, the fear of his relapse in the pit of my stomach. Five years on, I started seeing signs again, too much time on his laptop or phone, irritability, and being secretive. I was damned if I accused him, and I was damned if I didn't. Only when a vast amount of savings went missing did my heart sink, and the fear came back with force. The shame intensified the second time around. I felt like an idiot, and I was angry and hurt. Why did he not love us enough to stop? Lockdown came, and his gambling became a 12-hour-a-day problem. His anger and threats returned; sadly, he physically assaulted me this time. My mental health was at rock bottom. I had days I didn't want to be alive anymore, but I kept going for the children. He was finally arrested and did time on remand. His mental health was a mess. He wouldn't get help. His coercive behaviour still got to me through our daughter. Although young adults now, both children have struggled with their father's behaviour and required professional support. Then the night of the 10th of November 2021, he came to our family home, demanding to be let in, shouting for me. I wouldn't answer, so in front of myself and our 16-year-old son, he poured petrol over his head and set himself on fire. He died on the operating table in the early hours of the next day. That night will never leave us. The guilt I felt for a long time was awful—the pain of losing my husband and the father of my children. Even in a crowded room, the loneliness still gets to me today. Life moves on, good days and bad, but I try to be positive both in my life and my work with Gambling Harm UK. Every day is new, and I'm working hard to make them better for all the people who have suffered from any degree of gambling harm, Affected Others, or are in Recovery, and of course myself. If you are suffering from gambling harm yourself, or know of someone else who is, and you or they require any help or support, please use the organisation links below. If you want to hear more of my story and where I was as a person back in 2020, you can listen to a Podcast interview I gave back then, to "All Bets Are Off". The link to this is available below. https://podcasts.apple.com/gb/podcast/s2-ep10-affected-others-the-story-of- julie/id1511740988?i=1000497258947 Support organisations: https://www.gamcare.org.uk/get-support/talk-to-us-now/ GamCare: National Helpline https://gamfam.org.uk/ GamFam: Recovery and Affected Other Support https://www.gamblersanonymous.org.uk/ Gambling Anonymous: Support for Gambling https://www.nhs.uk/live-well/addiction-support/gambling-addiction/ NHS Treatment services

Are you able to help us make a potentially life-changing or even life-saving impact on someone else’s life? At Gambling Harm UK, we are working to increase awareness of gambling harm. We recognise some people can gamble without harm, but for those where gambling leads to harm, the impact can be devastating to their lives. Both to the person who gambles and to their families and friends around them. Data indicates that at least 10% of the population is affected directly or indirectly by gambling harm. For us to continue to deliver our programme of work, we require funding to meet our costs. Like any charity, we depend on people’s goodwill and support. Our work includes the following: · Educating young people, students, healthcare, and other professionals. · Raising awareness in corporate organisations. · Gambling harm research efforts. We aim to be independent, and raising funds via donations is an essential part of being able to do this. As CEO, I have decided to launch our “Life-changing Opportunity” appeal. We aim to raise £125,000 to cover the charity’s costs from 1st August 2023 to 30th July 2024. Our donation link can be accessed at https://www.gofundme.com/f/dzyc74-a-lifechanging-opportunity Funds raised will be spent on our educational awareness raising and research activities. Examples of our work over the last twelve months include delivering awareness sessions to almost 5000 young people, and developing and delivering the first-of-its-kind medical students upskilling programme focused on gambling disorder achieved with the support of the Anglia Ruskin University School of Medicine. I appreciate times are financially challenging, and some people who may want to donate will be unable to. We understand that. If you are in that situation but would still like to help, you can share our appeal with others. If you receive this appeal and are suffering gambling harm, please contact the national gambling helpline on 0808 8020 133.

Organisations are continually faced with numerous challenges and issues and must decide where they prioritise their resources to be successful and sustainable. In these circumstances should gambling harm be a business priority or not? As Gambling Harm UK, we believe the answer to this should be yes. We hope the following may help you make the correct decision for your organisation. Is gambling harm in the workplace really a significant issue? Yes, gambling harm in the workplace is a significant issue that can have negative impacts on both employees and employers. Here are some reasons why: Prevalence: Gambling harm is a common problem, with an estimated 10% of the UK population directly or indirectly experiencing gambling harm. This means that in a workplace with 100 employees, there could be 10 employees struggling with gambling harm. Cost: Gambling harm can be costly for both employees and employers. Employees who experience gambling harm may experience financial difficulties, such as debt and bankruptcy, which can impact their work performance and lead to absenteeism or even job loss. Employers may also face costs related to reduced productivity, absenteeism, and increased health care costs. Legal risks: Employers have a legal obligation to provide a safe workplace for their employees. Failure to address gambling harm in the workplace could result in legal liability, particularly if an employee's gambling harm leads to accidents or injuries on the job. Impact on mental health: As mentioned earlier, gambling harm can have negative impacts on an individual's mental health, including depression, anxiety, and other mental health disorders. This can lead to decreased productivity, increased absenteeism, and higher healthcare costs. Social responsibility: Employers have a responsibility to promote social responsibility and contribute to the well-being of their communities. Addressing gambling harm in the workplace can help prevent negative social outcomes, such as crime and family breakdowns, that can result from gambling harm. Is improving mental health a priority for your organisation? If so, you should also care about gambling harm. Gambling harm can have a significant impact on an individual's mental health, as well as their physical health, relationships, and overall well-being. Studies have shown that those suffering gambling harm are strongly associated with depression, anxiety, and other mental health disorders. Gambling harm can also lead to feelings of shame, guilt, and hopelessness, which can exacerbate existing mental health conditions or lead to the development of new ones. Overall, addressing gambling harm in the workplace is an important part of promoting a mentally healthy workplace and supporting the overall well-being of your employees. Are there possible legal risks for an employer by not addressing gambling harm in the workplace? 1. Health and Safety at Work Act (HSWA): The HSWA places a legal duty on employers to ensure the health, safety, and welfare of their employees. Failure to address gambling harm in the workplace might be seen as a breach of this duty and if so, could result in legal action being taken against the employer. 2. Equality Act 2010: The Equality Act 2010 requires employers to take steps to prevent discrimination and harassment in the workplace. If an employer fails to address gambling harm and this leads to an employee experiencing discrimination or harassment, the employer might be held liable. 3. Employment contracts: Employment contracts may include clauses relating to gambling, such as prohibiting gambling in the workplace or during working hours. Failure to enforce these clauses might lead to legal action being taken against the employer. Is there any evidence relating to the risks of gambling harm in the workplace? Research data is still limited but the following links provide some information: 1. According to the Office for Health Improvement and Disparities Jan 2023 report, gambling was linked to a loss of concentration on work, (source: https://www.gov.uk/government/publications/gambling-related-harms-evidence-review/gambling-related-harms-evidence-review-summary) 2. According to a Gamcare publication, gambling and debt can be a distraction for people at work. These distractions can have a range of negative consequences for people while at work, especially when working somewhere like a building site where concentration is key to avoiding accidents. (source: https://www.gamcare.org.uk/news-and-blog/blog/problem-gambling-at-work/) 3. Cube HR highlight both health and safety risks but wider employer risks. (source: https://cubehr.co.uk/blog/gambling-at-work/) If I give attention to gambling harm in the workplace could my business be seen as anti-gambling? Addressing gambling harm in the workplace does not mean that your business is anti-gambling. Rather, it shows that your business is committed to promoting a safe and supportive workplace environment that prioritises the well-being of employees. Gambling is an accepted form of entertainment, and it is not necessarily problematic for everyone. However, gambling harm can have negative impacts on individuals and their families, and it is important to address this issue in the workplace to provide support and resources to those who may be affected. Overall, addressing gambling harm in the workplace is an important part of promoting a safe and supportive workplace culture, and it does not mean that your business is anti-gambling. Will it be expensive for an organisation to implement measures to address gambling harm? The cost of implementing measures to address gambling harm will vary depending on the size of the organisation, the nature of their operations, and the specific measures being implemented. However, it is important to note that the cost of not addressing gambling harm could potentially be greater in terms of reputational damage, legal liabilities, and lost productivity. Overall, while there will be some costs associated with implementing measures to address gambling harm, they do not have to be significant, and the potential benefits can outweigh these costs in the long run. Ultimately, it is up to each organisation to weigh up the potential costs and benefits and determine the most appropriate course of action for their circumstances. What are the first steps I could take as an employer to help respond to gambling harm? As an employer there are several steps you could take to help respond to gambling harm among your employees: 1. Provide education to employees: Offer educational resources to your employees, such as brochures, posters, or training sessions on gambling harm and how to recognise and address it. 2. Implement a workplace policy: Develop a workplace policy that addresses gambling harm, including guidelines for addressing employees who may be experiencing gambling-related problems and information on available resources for support and treatment. 3. Offer employee assistance programs (EAPs): Consider offering an employee assistance program that provides confidential counselling and support to employees who may be experiencing gambling harm or other personal issues. 4. Create a supportive work environment: Foster a supportive work environment that encourages employees to seek help and support when needed. This can include promoting a culture of openness and understanding, providing access to resources, and offering flexible scheduling options to accommodate treatment or support. Will our business brand be positively impacted by addressing gambling harm in the workplace? Addressing gambling harm in the workplace can have several positive impacts on your business's brand, including: 1. Increased reputation as a responsible and caring employer: By taking proactive steps to address gambling harm in the workplace, your business can demonstrate a commitment to the well-being of its employees and the wider community. 2. Enhanced corporate social responsibility (CSR): Addressing gambling harm can be seen as a part of your business's broader CSR strategy, highlighting your commitment to ethical and responsible business practices. 3. Improved employee morale and retention: By promoting a safer and healthier workplace environment, your business can increase employee satisfaction and reduce staff turnover, improving your reputation as an employer of choice. 4. Positive media coverage: Addressing gambling harm in the workplace can attract positive media attention, providing an opportunity to showcase your business's commitment to social responsibility and ethical practices. 5. Increased customer loyalty: Consumers are increasingly seeking out brands that align with their values and demonstrate a commitment to social responsibility. Addressing gambling harm can demonstrate your business's commitment to responsible behaviour, potentially enhancing customer loyalty. Finally: Gambling harm can affect anybody. It is an illness and like any illness those suffering from it need help and support. As the hidden addiction, you may not know staff within your organisation who are suffering. With an increased risk of suicide being associated with gambling harm, if your organisation can help, please do. The NHS is expanding the number of national treatment centres to respond to the demand for support. 24-hour support, 7 days per week is available via the National Gambling Helpline (0808 8020 133) or, access support via the NHS Live Well website link. https://www.nhs.uk/live-well/addiction-support/gambling-addiction/ There are several support charities who can also help you, Gambling Harm UK is one.

Gambling harm is a growing public health concern affecting individuals, families, and communities across the world. Given their current and future potential roles within healthcare teams, it's essential for medical students to be well-informed about, know how to identify, and be confident in providing treatment and support to patients who may be suffering from gambling harm. This is why our charity recently hosted a medical education course on gambling harm for third-year medical students, which used a simulation-based format with individuals with lived experience acting as real patients. The course was designed to provide medical students with an immersive and interactive learning experience that would help them better understand the complexities of gambling harm and the impact it has on individuals, families, and communities. By using a simulation-based format, the course aimed to create a realistic and engaging learning environment that would help medical students to develop their skills and knowledge in a practical and hands-on way. The course was designed by a team of experts on gambling harm and medical education, who provided an overview of the latest research in gambling harm. This was followed by a series of interactive simulations, in which individuals with lived experience acted as real patients and shared their personal stories and experiences with the medical students. The medical students were first tasked with empathetically and sensitively gathering a history from a patient presenting with a symptom that may seemingly be unrelated to gambling harm. This was then followed by a more thorough assessment of other gambling harms as well as an evaluation of the risks to the patient and others. Lastly, the student doctors worked together to provide support and resources to the patients. Through these simulations, the medical students were able to see first-hand the impact that gambling harm can have on an individual's life and the importance of asking direct questions to promote early identification. Our lived experience delivery was particularly impactful for the medical students, as it provided an authentic perspective on the challenges and complexities of gambling harm. Individuals with lived experience shared their stories and provided insight into what it's like to live with gambling harm either from their own gambling or from another person's gambling, and the impact that it has had on their lives. This helped the medical students to understand the importance of empathy and compassion when working with patients who may be struggling with gambling harm and its stigmas. The simulation-based format of the medical education course was a great success, with the medical students expressing that they found the experience to be incredibly valuable and impactful. They reported increased confidence to identify and treat patients who may be suffering from gambling harm and appreciated the opportunity to put their knowledge and skills into practice in a safe and controlled environment. In conclusion, our charity's medical education course on gambling harm was an important step in preparing medical students to tackle this growing public health concern. By using a simulation-based format with individuals with lived experience, the course provided a hands-on and immersive learning experience that helped the medical students to develop their skills, knowledge and attitudes in a practical and impactful way. We believe that this type of education is crucial for healthcare professionals, and we will continue to advocate for its importance in undergraduate education. What did you like most about the sessions today? "Having real family members affected by gambling made the session much more helpful as I could understand exactly what to do and not to do in a consultation" "Before the session, I was not aware of the [gravity] of the effect gambling has and the severity that it has on QOL. + How many people it affects + How it is not just gambling. But also the emotional/behavioural changes" "The structure of both sessions and how it was split into smaller groups which allowed us not only to learn more effectively but also improve our communication skills on sensitive topics." What did you dislike most about the sessions today? "N/A (10/10 session) I would recommend to other med schools" "There was nothing I would change" "I wouldn't mind if the session was longer." Figure 1. Column chart showing student perceptions on helpfulness of sessions towards gambling harm competencies where 1 = not at all helpful and 5 = very helpful. The mean is plotted with 95% confidence intervals. Figure 2. Column chart showing student perceptions on helpfulness of the lived experience delivery of the sessions where 1 = not at all helpful and 5 = very helpful. The mean is plotted with 95% confidence intervals. Figure 3. A donut chart showing proportions of student preferences for quantity of gambling harm education at the undergraduate level. Abstract report Footnote: "Three years ago, I was a 4th Year Medical Student at Imperial College London realising that: I had experienced gambling harm all my life Gambling harm is one of the most significant modifiable risk factors for health That the issue is extraordinarily neglected relative to other similar issues It bothered me that I had never encountered gambling harm teaching in my medical education and that this would be the norm across undergraduate teaching domestically and internationally. (Now that I'm practising medicine as an FY1 doctor, I come across gambling harm regularly but often only because I have asked.) Therefore, in October 2019, I started my efforts to change this. Since then, we’ve created resources with medical education providers with a vast reach, namely, Geeky Medics and Osmosis – Medical Education. We’ve now gone a step further in making a decisive impact in gambling harm medical education through a successful course designed and delivered by individuals with lived experience course to medical students directly. We're extremely pleased with the feedback that we have received and the impact that this course will have on the students, their loved ones, and patients. We look forward to and strive to see gambling harm being considered and tackled alongside alcohol misuse, tobacco use, and drug misuse in medical education and healthcare practice." Dr Kishan Patel Chair of the Board of Trustees at Gambling Harm UK

Introduction The Betting and Gaming Council (BGC) was formed in 2019 as a merger of three different ‘industry associations’; the Remote Gambling Association (RGA), the Association of British Bookmakers (ABB) and the National Casino Forum (NCF).[i] These associations represented various sectors of the UK’s gambling industry whose interests had not always been aligned.[ii] With the formation of the BGC, however, the industry has created a unified body to advocate on its behalf.[iii] This advocacy, however, is not the aspect of the organisation that it stresses to the press or the public. Instead, the BGC, since its creation, has styled itself as a ‘standards body’ first and foremost, as CEO Michael Dugher is quoted in bold on their website ‘Our number one priority remains to raise standards and drive big changes’.[1] And whilst the BGC has championed several initiatives to promote safer gambling, their effectiveness has been questioned; the Guardian’s Rob Davies refers to much of the work as ‘cosmetic rather than profound’.[1] The BGC’s role as representatives and advocates of the industry is not immediately apparent and is always couched in the language of promoting industry standards; below Dughers’ quote (and in a much smaller font), the BGC’s stated mission is: “To champion the betting and gaming industry and set world class standards to ensure an enjoyable, fair and safe betting and gaming experience for all our customers.”[1] And its purpose: “To provide a forum to facilitate collaboration, sharing of best practice, drive and champion standards, and create a single voice for the industry.”[1] Despite this downplaying of its role as an industry-founded and industry-funded organisation, the BGC, like its forebears, is first and foremost a lobbying group for the gambling industry. Below we examine how and why the BGC was formed, the influence and connections it exerts, to what extent its claims of industry self-regulation can be taken seriously and finally, we will look at some of its strategies and tactics. FOBTs, the industry’s lost battle and the formation of the BGC Before their maximum bet was reduced by law from £100 to £2 in 2019, ‘fixed-odds betting terminals’ (FOBTs) were out of control. They represented over £1 billion lost a year by people who gambled, a disproportionate proportion of their players were ‘problem gamblers’ (13.6%, rising to over a quarter when including those at ‘moderate risk’), and they were primarily responsible for overcrowding high streets with betting shops.[2] By 2017, these problems, combined with the heart-rending stories of victims, coalesced into a media storm, with FOBTs dubbed the ‘crack cocaine of gambling.’[3]Unsurprisingly, the same year, the government launched a ‘consultation on a range of options on cutting maximum stakes.’[4] With each machine bringing in more than £50,000 a year and generating a total of £1.2 billion in income, the industry launched a defensive action. [3] This action would be spearheaded by the Association of British Bookmakers (ABB) and its CEO Malcolm George. Much of their effort was unsophisticated, with Malcolm George often railing against a ‘media panic’ induced by ‘those with their own commercial interests at heart’.[5] George was not entirely incorrect; the industry was divided on FOBTs, with some organisations backing reform and the ABB’s counterpart, the Remote Gambling Association, ‘content to stay out of the matter’. [3] Such heavy-handed attacks, however, did the ABB no favours. As with much lobbying, however, the primary battle was not in the press but in parliament. Here the ABB acted with much more sophistication and in a manner still emulated by its successor, the BGC: Firstly, the ABB commissioned KPMG (an accounting firm) to write a report on the impact of cutting FOBT’s maximum stake to £2; the report found that this would cost the industry a staggering £639 million and cause 15-21,000 job losses. It was, however, deeply misleading as the ABB had dictated the parameters of KPMG’s report in such a way to ensure a beneficial outcome. As KPMG notes, the report was ‘performed to meet specific terms of reference’, with certain estimates’ agreed with the industry’ and ‘should not be regarded as suitable to be used or relied on by any other person or for any other purpose’.[6] Despite this, the report was circulated among MPs and Civil Servants; it was used in ‘Treasury modelling’ and even cited by the Chancellor of the Exchequer, Philip Hammond.[3] Secondly, it would seem that the industry’s allies in parliament attempted to delay or axe the incoming £2 stake limit proposed by then Sports Minister Tracy Crouch. As Crouch would report, Philip Davies lobbied the Culture Secretary Jeremy Wright against the policy; after that, the Treasury and chancellor Philip Hammond (who cited the erroneous report) took over. Crouch then resigned in protest, triggering outroar and a rebellion which forced the Treasury to backtrack. Crouch has stated that without her resignation, she does not believe the policy would have gone ahead, given the Treasury’s and Hammonds’s ‘scepticism’, no doubt influenced by the misleading KGMP report and lobbying by pro-industry MPs.[3] With these late dramatics, the ABB had been defeated, and the industry’s reputation damaged. It was clear to gambling firms that if they wanted to weather public outrage and growing calls for reform, they would need a modern and sophisticated organisation to “champion” their interests. Thus, in 2018 the Betting and Gaming Council was formed. The BGC: buying influence At its formation, the BGC was already a formidable beast. It appointed a veteran lobbyist Brigid Simmonds as chairman. More importantly, it hired Michael Dugher, a former Shadow Secretary and Labour MP as chief executive and Kevin Schofield, a veteran journalist and former editor of PoliticsHome, to run the organisation’s communication strategy.[3] All the contacts and experience in this core team have undoubtedly been useful to the BGC in various ways, some of which we trace below. With the appointment of Kevin Schofield, the BGC had hired an experienced journalist and a man fully capable of running the organisation’s communications strategy. Perhaps it was this canny understanding of communications that caused PoliticsHome (a news source read by MPs and political advisors) to go from publishing articles broadly sympathetic to gambling reform to publishing no less than eleven articles written by the BGC or its staff in the eighteen months since they hired Schofield.[3] Or perhaps Schofield retains friends and influence at PoliticsHome, for which he was an editor for five years. Similarly, since his appointment, niche BGC reports have received favourable coverage by Schofield’s former colleagues in both the Sun and the Sun on Sunday.[3] Somewhat more challenging to map is the influence of former shadow minister Michael Dugher. Dugher is a man with numerous contacts from his time at the forefront of political activity; he has undoubtedly helped the BGC meet with and influence officials, ministers and MPs. The nature of such lobbying means that we can only speculate on the extent of his work. What we can note, however, is the apparent influence and reach of the BGC, whose staff met with DCMS officials seven times between October and December of 2020 (the period immediately before the Government’s Gambling Act Review was announced).[3] Perhaps the most well-publicised (alleged) exertion of Dugher’s influence was the hiring of former Labour Deputy Leader Tom Watson by Flutter Entertainment. Of course, Flutter is not the BGC, and there is no evidence that Dugher directly or indirectly influenced that decision. What is known is that Dugher and Watson are close friends, and despite Watson’s former vocally anti-gambling stance, he took a job for the industry, lending it both his expertise and reputation. Further, Watson has taken to using a favourite phrase of Dughers (and not many others) to describe activists in favour of gambling reform, that is, to call them ‘prohibitionists’ (despite the rarity of calls for an outright ban).[3] It is not just former MP’s the BGC has ties with (nor is the Dugher-Watson connection the height of the industry’s incestuous dealings). In November 2020, the BGC began paying current Conservative MP Laurence Robertson £2,000 monthly for 10 hours work advising ‘on sports and safer gambling’ (an hourly rate of £200).[3] Similarly, Philip Davies (the MP who lobbied to delay FOTB reform) got paid £50,000 for 124 hours of work advising Entain chief executive Kenny Alexander.[3] Alongside this, Davies has several former staff employed in the industry. Two of Entains senior officials previously worked in his office (head of safer gambling and external affairs Sophie Dean and chief of corporate affairs Grainne Hurst); the BGC also employs his former aide Camilla Toogood as its ‘government relations manager’.[3] Whilst there is nothing technically wrong with hiring a host of Davies acolytes, it shows how the BGC and, indeed, the industry maintains a deep connection with those politicians it deems friendly to their cause. The BGC: self-regulation? Unlike the old Association of British Bookmakers or the Remote Gambling Association, the BGC’s purpose as a pro-industry lobbying group is not immediately apparent to the casual observer. In a rather successful PR stunt, the industry dropped the standard ‘association’ moniker in its creation of the BGC and has focused on messaging concerning the groups role as a ‘standards body’. The BGC stresses this role at every opportunity and indeed, the organisation has championed several voluntary initiatives aimed at the protection of consumers. This has led many commentators to attribute a genuine concern for those affected by gambling harm. However, such exercises by the industry are best viewed as thinly veiled publicity stunts, primarily tokenistic and driven by the desire for self-preservation, which attempts to mask the actions of an industry desperately trying to fend off outside regulation. Take, for example, two instances of BGC “championed” reform. Firstly, the much-publicised whistle-to-whistle ban on gambling advertisements during live sporting broadcasts. The ban, agreed on in 2018, was labelled a ‘huge success’ in the BGC’s annual review and has been held up as something of a crowning achievement for the organisation and as proof that effective self-regulation is possible.[7] Indeed, the BGC claimed that the initiative had reduced the number of gambling ads seen by 4-17-year-olds by a staggering 97%.[8] The reality is substantially different; over the first year of the ban, gambling ads across all TV channels fell by about 11.3%.[9] Whilst this might seem substantial, two factors undermine the BGCs narrative. Firstly, despite a ban on tv advertisements during broadcasts, the broadcasts themselves contained numerous gambling logos and advertisements; 9 of 20 premier league clubs and 17 of 24 championship clubs had shirt sponsorships, to say nothing of the numerous advertisements on pitch-side boards.[10] Secondly, the ban only served to accelerate the move to online advertising, which the industry was already in the process of making. Indeed, the 97% reduction in gambling ads seen by children boasted by the BGC is achieved through not only excluding all media except broadcast tv but also by examining only the number of tv ads seen over the span of televised football matches, not the overall number of televisions ads seen at other times.[3] In short, the ban is unlikely to have reduced gambling harm due to the omnipresent nature of gambling ads both online and through sponsorships during broadcast; similarly, it was almost certainly harmless to the industry, which already had a large amount of exposure through those sponsorships and online marketing. The main purpose for the ban seems to have been the positive news coverage it generated for the industry. Secondly, and of more minor importance, is the BGCs supposed support for gambling reforms. Notably, when the Gambling Commission introduced a ban on gambling on credit - a ban on gambling on debt (and thus likely creating more debt) - Dugher claimed the BGC had always ‘fully and publicly’ supported the ban.[3] Despite this, the Commission's own report indicated that ‘none of the remote gambling operators who responded supported the ban’.[3] The BGCs backers had opposed the reform, and the BGC had only thrown its weight in once it was already decided; rather than championing reform, the organisation appears to have attempted to gain credit for a reform its backers opposed. What these examples illustrate and what must be kept in mind is that the BGC is, first and foremost, a pro-industry body; its responsibility is not to those affected by gambling harms but to the various gambling companies that make up its membership. As such, the regulatory initiatives it has championed have been aggrandised and have only been incidentally helpful in reducing gambling harm (if they have at all). The BGC commits to such initiatives with the dual aims of improving the industry’s public image and of fending off government intervention – the alternative is that profit-driven private enterprises are funding an organisation whose goal is to reduce their profits through self-regulation. The BGC: bogus fear of a black market One of the BGC’s primary methods of pushing back against the prospect of greater regulation is to raise concerns over growth in the gambling ‘black market’ (unlicensed gambling operations). The argument being that much like the American prohibition, a draconian crackdown on the industry could lead to an explosion of an unregulated (and more dangerous) form of gambling. Whilst the prospect of growth in the black market should perhaps not be dismissed outright, the industry’s predictions are certainly exaggerated and cynically leveraged; as Paddy Power co-founder Stewart Kenny has noted, industry heads always ‘used the threat of the black market’ and ‘always knew it was a bit of a bogus argument’.[3] Despite Mr Kenny’s admission and others like it, the BGC has focused much of its efforts on framing its opposition to regulation as civic-minded warnings. Whilst the ABB of old might have railed against the prospect of regulation (and the APPG on Betting and Gaming certainly has), the BGC’s well-oiled PR machine has taken a conciliatory tone, offering notional support to ‘the Gambling Review’ whilst raising the spectre of the black market if regulation is taken too far, warning that it may lead to ‘regulated industry being smaller and the illegal black market growing substantially’.[11] Dugher and the BGC then call for the government not to limit regulation or roll back its gambling review but rather to ‘take an evidence-based approach’.[11] Whilst this may seem an uncontroversial and eminently reasonable approach, one must recall the KGMP report on FOBTs that was declared unfit for outside use by its authors yet still found its way into Treasury modelling, onto the desks of civil servants, MPs and even the Chancellor’s. The industry can and has created ‘evidence’ which suits their financial interests; the BGC’s network of influence means that often this evidence makes its way to decision-makers even when it is woefully inaccurate and unusable. It is unsurprising then that in 2019 the industry commissioned PwC to write a report on the size of the UK black market.[3] The report estimated that 200,000 Britons wagered 1.4 billion on black market operators every year; this eye-catching figure was dutifully spread around the press (with Schofield’s old colleagues in the Murdoch Press doing much of the heavy lifting).[3] The report was deeply flawed and had failed to distinguish between real website visits and ones generated by bots; it drew widespread criticism and a surprisingly strong statement from the usually reticent Gambling Commission, with executive Niel McArthur calling the report ‘exaggerated’ and ‘not consistent with the intelligence picture’.[3] Furthermore, it should be noted whilst the report was completed in August of 2019, the BGC, a self-described ‘standards body’, did not choose to publish it until 2020, just as the Gambling Review was initiated. Not deterred by this criticism, the BGC quickly published a follow-up alleging that wagers on black market sites had doubled during the pandemic and now equalled around 2% of those placed on legitimate sites.[3] As Davies notes with some scepticism, during the same period, wagers on legitimate sites increased by a comparatively modest 13%; the PwC report would suggest that during lockdown, people were drawn not towards the licenced operators whose adverts they saw daily but towards much riskier black market sites.[3] To refer back again to Paddy power co-founder Stewart Kenny this seems incredibly unlikely as most people are ‘not going to lend [their] credit card details to black market operators’.[3] [i] An industry association is founded and funded by businesses operating in the sector. Its purpose is to promote the interests of the businesses it represents. [ii] Most notably on the issue of FOBTs [iii] Since the absorption of the Senet Group in 2020, the BGC now represents approximately 90% of the UK's licensed operators. [1] Betting & Gaming Council. Our Purpose [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/about-us/our-purpose [2] Channel 4. Gambling act was a ‘mistake’ confesses senior Labour politician [Internet]. [cited 2023 Jan 6]. Available from: https://www.channel4.com/press/news/gambling-act-was-mistake-confesses-senior-labour-politician [3] Davies R. Jackpot: How Gambling Conquered Britain. London: Guardian Faber; 2022. [4] GOV.UK. Government to take action on Fixed Odds Betting Terminals [Internet]. [cited 2023 Jan 6]. Available from: https://www.gov.uk/government/news/government-to-take-action-on-fixed-odds-betting-terminals [5] Financial Times. Why criticism of FOBTs needs to be played down [Internet]. [cited 2023 Jan 6]. Available from: https://www.ft.com/content/3304187a-7ff1-11e6-8e50-8ec15fb462f4 [6] Davies R. Government’s FOBT decision influenced by ‘discredited’ report. The Guardian [Internet]. 2018 Nov 12 [cited 2023 Jan 6]; Available from: https://www.theguardian.com/uk-news/2018/nov/12/government-fobt-decision-discredited-report [7] Betting & Gaming Council. ‘Whistle to whistle’ ban a huge success [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/annual-review/responsible-advertising-2 [8] Betting & Gaming Council. ‘Whistle to whistle’ ban success [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/news/whistle-to-whistle-ban-dramatically-reduces-number-of-betting-adverts-seen-by-children [9] Patel K. Gambling and voluntary bans [Internet]. 2021 [cited 2023 Jan 6]. Available from: https://www.gamblingharm.com/post/gambling-and-voluntary-bans [10] Association P. Number of clubs sponsored by betting firms is ‘disturbing’, say campaigners. The Guardian [Internet]. 2018 Jul 30 [cited 2023 Jan 6]; Available from: https://www.theguardian.com/football/2018/jul/30/campaigners-concerned-championship-efl-clubs-sponsored-betting [11] Betting & Gaming Council. New research reveals shocking size of Black Market gambling across… [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/news/new-research-reveals