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- NICE Guidance: Gambling: Identification, diagnosis and management
One of our priorities at Gambling Harm UK is to see gambling harm appropriately considered and prioritised within the health context. Consequently, as well as Gambling Harm UK's Medical Education efforts, Gambling Harm UK have been one of the earliest and most committed campaigners that wish to see NICE guidelines for gambling. In April 2020, a UK Parliament committee launched a call for evidence for gambling-harm with an inquiry: "Gambling can have significant adverse effects on people which can include addiction, mental health problems, financial loss, and in some cases crime or suicide. Excluding the National Lottery, gambling operators earned £11.3bn in 2018-19. All gambling in Britain is regulated by the Gambling Commission with the aim to “ensure gambling is fair and safe”. It is funded by licence fees from industry, which amounted to £19 million in the same period. Overall responsibility for the policy and regulatory framework lies the Department for Digital, Culture, Media & Sport (DCMS), which has an objective to ensure gambling is socially responsible. The industry is increasingly complex, with new risks emerging from online and mobile gambling and games that share features with gambling but are not regulated as such. The NAO’s report ‘Gambling regulation: problem gambling and protecting vulnerable people’ examines how well gambling regulation protects people from gambling-related harms and addresses new risks from social and technological developments. The report finds that there are an estimated 395,000 problem gamblers in Great Britain, with 1.8 million more gamblers at risk who may also be experiencing harm. The report finds that the Gambling Commission is improving its regulation but has more to do including taking a more strategic approach to influencing gambling operators to raise standards. The NAO concludes that even with improvements, the Commission’s ability to protect gamblers faces constraints in the regulatory framework, including inflexible funding and gaps in redress arrangements, and that the Commission is unlikely to be fully effective in addressing risks and harms to consumers within the current arrangements. This will be the first time the Committee has examined gambling regulation in recent years. The Committee will question officials from the Department for Digital, Culture, Media and Sport and the Gambling Commission, on how well the current regulatory framework protects gamblers. The Committee will also ask officials about how current restrictions imposed in response to the COVID-19 pandemic could affect those susceptible to the negative impacts of gambling. The Committee is inviting views from any interested parties on the issues raised by the NAO report – please submit your evidence by Wednesday 22 April." In May 2020, Gambling Harm UK's Kishan Patel responded to this call for evidence with a short synthesis of salient points which included the lack of guidelines on gambling-harm: "There are currently no NICE guidelines on gambling. As of 24th July 2018, gambling has been referred to NICE, but it has not yet been scheduled into the work programme." The timeline for NICE guidelines on gambling has now been updated which also signifies a significant watershed moment from inaction to action. 20 October 2021 - Scoping workshop 12 July 2021 - Stakeholder list updated 01 June 2021 - 15 June 2021 - Topic expert committee member recruitment 01 June 2021 - 15 June 2021 - Committee chair recruitment 16 November 2021 - 14 December 2021 - Committee member recruitment 16 November 2021 - 14 December 2021 - Draft scope consultation 07 February 2024 - Expected publication We would like to encourage individuals with lived experience to join us, to engage and support efforts towards a robust, appropriate, and impactful set of NICE guidelines. For more information, see here.
- BBC News: Online gambling: 'I stole £70,000 to feed my addiction'
Extract from the article Danielle's met other gamblers in recovery through a network called TalkGEN, which wants to improve education and understanding of gambling harm. It was set up in 2020 by Kishan Patel, a fifth year medical student. "Growing up I was massively affected by my dad's addiction," he says. "There were times when my family really struggled for money and there was a big cultural stigma in my community too, where people wouldn't want to talk to us because of it." Kishan's dad died eight years ago and he has seen the emotional and mental impact of gambling first hand. But he says it isn't thought of as a health concern in the same way as drugs or alcohol addiction is: "There are guidelines for health professionals around these issues, but gambling is neglected when it shouldn't be." He would like it to become something GPs consider asking vulnerable patients about, in the same way they might do with other addictions: "Just a simple question like, 'Do you gamble?' could help open up the conversation. It's a really serious health issue we need to be addressing."
- Gambling and health
Publicly the industry denied and continues to deny the significance of gambling harm on a population level. This refusal to accept the reality is compounded by the industry's lack of funding in public health research, despite the WHO commenting on the need to prioritise gambling-harm on agendas due to the magnitude of harm from gambling being comparable to the harm accrued by alcohol-use disorder or major depressive disorder. Harms in affected others challenge the industry in two ways. First, measures to raise awareness and prevent gambling harms in individuals who do not gamble will reduce the appeal of gambling and contribute to its social unacceptability. Second, the 'freedom to gamble' argument is confounded if individuals who do not gamble are harmed. The industry has largely refused to acknowledge the significance of harms in affected others, individuals who gamble and suffer low-risk harms, moderate-risk harms, and legacy harms due to previous gambling. This situation has not been helped by the chronic underfunding and lack of independence in research, education, and treatment. Summary “The gambling-related burden of harm appears to be of similar magnitude to harm attributed to major depressive disorder and alcohol misuse and dependence. It is substantially higher than harm attributed to drug dependence disorder.” WHO: The epidemiology and impact of gambling disorder and other gambling-related harm 2017 1 Gambling addiction was first formally recognised as a mental disorder by professionals in the US through the Diagnostic and Statistical Manual of Mental Disorders-III in 1980. Over the past two decades, gambling harm has emerged as a pressing public health issue globally. Domestic and international studies have reported statistical links between gambling harm in adults and suicide, mortality, and poor health. When faced with evidence of the links of gambling and harm to health, industry lobbyists have commonly steered away from admitting any responsibility; instead, they have promised research, reform, or reiterated commitments to safer gambling standards. Moreover, the industry has worked to associate itself with the NHS and other health organisations. Gambling harm may be experienced by individuals that gamble, affected others of people who gamble, and by communities. Research from Australia in 2016 reported a taxonomy of harms over eight domains: financial, relationship, emotional, health, cultural, work or study, criminal activity, life course and intergenerational harms. Responsible gambling mantras have largely replaced public health messaging in Great Britain. Meanwhile, ideas of risk-free gambling and safer gambling have been furthered. Current safer gambling ads seldom reflect the significance of gambling harm, especially on affected others, due to them being industry-supported. Similarly, specialist treatment options and awareness among health care workers remain challenges and are limited by such efforts being primarily managed with voluntary donations. Moreover, public health research in New Zealand and Australia have explored the significance of gambling harm on quality of life by reporting disability weights. These disability weights allow researchers and public health stakeholders to understand the significance of gambling harm on the individual and the population through comparison to other health states. Based on this research, a WHO report found an "urgent need to place gambling on national and international public health agendas", among other things. At the time of writing, little is known about the significance of harm in young people, individuals who previously gambled, and former affected others (legacy harm). Whereas gambling-harm has featured in Australia's Monash guidelines for healthcare professionals for over a decade, the UK's National Institute for Health and Care Excellence (NICE) is yet to begin reviewing the evidence on gambling harm. What is known? Taxonomy of gambling harm Gambling-harm can manifest both in individuals that gamble and individuals that are affected by other people’s gambling, as general, crisis, and legacy harms, across the domains of 2 Financial harm Relationship disruption, conflict or breakdown Emotional or Psychological Distress Decrements to Health Cultural Harm Reduced Performance at Work or Study Criminal Activity Lifecourse and Intergenerational Harms Prevalence of harms in Family Member's affected by gambling disorder (Affected Others) 3 93% reported that their loved one's disordered gambling impacted their financial security (64% stating that the impact was significant) 89% reported a reduction in available spending money and a 88% reduction in savings 23% reported losing a major asset such as a car, home, or business, and 12% had become bankrupt 82% reported that their loved one's disordered gambling impacted their work and/or education (37% stating that the impact was significant) 76% reported reduced performance at work or study due to tiredness or distraction 55% and 50% reported being late and absent, respectively 99% reported that their loved one's gambling compulsion had harmed their health (46% stating that the impact was significant, 38% moderate, 15% slight) 95% reported loss of sleep due to stress or worry 64% reported reduced physical activity, 30% increased alcohol use, 33% increased tobacco consumption, 56% eating too much, and 44% eating too little 29% reported neglecting their medical needs, 36% reported increased use of health services, and 21% reported requiring emergency treatment for health issues caused or exacerbated by their loved one's gambling 16% reported committing acts of self-harm, and 8% had attempted suicide 96% reported experiencing relationship harms (67% stating that the impact was significant) 89% and 82% reported greater tension and conflict, respectively 71% reported feeling excluded from others 68% reported threatening separation or ending the relationship 33% reported separating or ending the relationship with the family member who gambles and potentially related others Other harms 21% reported incidents of violence 21% reported feelings of shame within their religious or cultural community 7% reported engaging in petty theft or dishonesty as a consequence of their family member's gambling Other addictions Family members of individuals with gambling disorder reported elevated rates of problematic use of substances Alcohol: 34.6% Drugs: 21.2% Legal highs: 3.2% Prescription drugs: 5.0% Severity of gambling-harm on quality of life in Adults 4.5 Disability Weights (where 0 = perfect health and 1 = death) Schizophrenia: acute state: 0.76 Heroin and other opioid dependence: 0.64 Gambling disorder harm (PGSI 8 or more): 0.54 (NZ 18) Manic episode of Bipolar Disorder: 0.48 Gambling disorder harm (PGSI 8 or more): 0.44 (AUS 17) Migraine: 0.43 Moderate alcohol use disorder: 0.39 Moderate-risk harm gambling (PGSI 2-7): 0.37 (NZ 18) Affected others at gambling disorder harms: 0.36 (AUS 17) Affected others at moderate-risk harms: 0.33 (AUS 17) Stroke: long-term consequences, moderate plus cognition problems: 0.31 Moderate-risk harm gambling (PGSI 2-7): 0.29 (AUS 17) Mild alcohol use disorder: 0.26 Low-risk harm gambling (PGSI 1-2): 0.18 (NZ 18) Urinary incontinence: 0.15 Affected others at low-risk harms: 0.17 (AUS 17) Low-risk harm gambling (PGSI 1-2): 0.13 (AUS 17) Hearing loss: complete, with ringing: 0.09 Significance of gambling-harm on the population in Years of Life Lost due to Disability (YLD) New Zealand (Adult population: 3.6m) 6 Combined total of years lost with gambling-harm related quality of life effects in the New Zealand Adult population: 162, 000 years Anxiety and depressive disorders: 106, 000 years Harms from someone else's gambling in adults: 94, 700 years (prevalence: 13.6%) Alcohol – Hazardous drinking (>8 AUDIT): 87, 600 years Harms from own gambling in adults: 67, 200 years (prevalence: 7.3%) Diabetes: 26, 000 years Drug use disorders: 22, 400 years Stroke: 12, 900 years Eating disorders: 3, 980 years Victoria, Australia (Adult population 4.4m) 7 Major depressive disorder: 148, 000 years Alcohol use and dependence: 148, 000 years Combined total of years lost with gambling-harm related quality of life effects in the Victorian Adult population: 118, 000 years Harms from own gambling in adults: 102, 000 years (past-year prevalence: 12.5%) Diabetes Mellitus: 22, 700 years Harms from someone else's gambling in adults: 16, 300 years (past-year prevalence: 2.8%) Cannabis dependence: 5, 780 England 2013 (Adult population: 53.9m) Gambling harm in adults: 1.62m Dietary risks: 1.47m Tobacco smoke: 1.46m Harms from own gambling in adults: 0.90m (prevalence: 8.5%) Harms from someone else's gambling in adults: 0.77m (prevalence: 6.0%) Alcohol use: 0.55m Drug use: 0.27m Significance of gambling-harm on the population in Years of Life Lost due to Mortality (YLL) Research from the UK involving bank data from over 100, 000 customers found that high levels of gambling were associated with a 37% increase in mortality 8 The last Adult Psychiatry Morbidity Survey 2007 that considered gambling-harm reported that individuals with gambling disorder were more likely to have thoughts about suicide (19.2% vs 4.1%) and to have made a suicidal attempt in the past year (4.7% vs 0.6%) compared to individuals who do not suffer gambling-harm. 9 A study of 16-24 year olds living in Great Britain found that Men and Women who indicated gambling disorder harms were 9.0 and 4.9 times more likely to attempt suicide, after adjusting for anxiety, impulsivity, life satisfaction, and other factors 10 Standardised mortality ratios 11 Men and Women in Sweden, aged 20-49 year olds and diagnosed with GD, were 19.3 times more likely to suffer from suicide when compared to the general Swedish population of the same ages Men and Women in Sweden, aged 20-49 years old and diagnosed with GD, were 6.2 more likely to suffer from any mortality when compared to the general Swedish population of the same ages What the industry said? Michael Dugher, CEO of the Betting Gaming Council 12 "The UK's addiction rate stands at 0.5% of the adult population, which is low compared to the international standard. The rates have also remained 'broadly steady around or below one percent for the past 20 years." Dugher frames the topic of gambling harm on the segment of adults suffering the most severe harms due to gambling in the past 12 months while omitting the experiences of affected others, individuals who previously had gambled, and individuals experiencing subclinical levels of gambling harm. Moreover, there are significant concerns with measuring gambling harm using self-completion forms included in health surveys, and as such, the stated 0.5% is expected to be a significant underestimate. The industry rarely comments on affected others as it recognises that this is likely to be the most damaging to their public relations strategies. Instead, the industry benefits from the fallacious societal stigma that gambling addiction is the individual's fault; however, the same cannot be easily argued for loved ones, especially the children who suffer harm. Gambling Commission in a briefing paper for Local Authorities and local Public Health providers February 2018 13 “The numbers of those who experience harm as a result of gambling by others will be considerably greater than the number of people who harm themselves.” “These are not small numbers. They suggest a significant public health issue which has received remarkably little attention relative to other population level concerns.” The Gambling Commission makes clear why gambling harm should be considered as a public health issue. Identifying gambling as a significant public health issue is in direct contrast to how the Gambling Commission falls under the remit of the Department of Culture, Media and Sport (DCMS) instead of the Department of Health and Social Care. Michael Dugher, CEO of the Betting Gaming Council 14 “NHS Charities said it wouldn't be possible for betting co's to make a direct donation, but they were happy for us to donate all the profits from this special fun virtual Grand National to help the NHS at this difficult time. Most people agree there's nothing wrong with this...” Dugher states that NHS Charities were not accepting a direct donation from the gambling industry. This quote demonstrates the BGC’s interest in associating with the NHS for the 4.8m viewers who tuned in to watch this virtual horse race which raised £2.6m. 15 “You don’t have to bet. If you don’t want to have a bet, please make a donation direct to NHS Charities. But millions of people do enjoy an occasional flutter & do so responsibly & safely.” Dugher argues that millions of people enjoy an occasional flutter while ignoring the millions that suffer gambling harm and the individuals who gamble frequently and make up significant amounts of the industry’s profit. Betting and Gaming Council 16 “Suicide is a complex issue and the examination of any links to gambling or disordered gambling requires great care and sensitivity. We suggest that a collaborative and careful approach to understanding linkages is required. The aim of research should be to explore what is clearly a difficult subject and provide pragmatic solutions.” The BGC creates an aura of doubt around gambling-suicide, despite evidence from studies across the world reflecting that individuals with gambling-disorder are many times more likely to suffer from suicidal harm. “Through continued funding by our industry over more than 20 years, these charitable services are able to provide free of charge treatment, support & advice services for anyone affected by gambling.” The BGC boasts of their voluntary funding for treatment services for harms caused by their industry. Thus, the industry demonstrates that treatment services are available due to the industry's generosity while ignoring issues with treatment access, awareness, and chronic underfunding. Mark Etches, CEO of GambleAware 17 [Britain was] “in great danger of sleepwalking into a future public health storm over gambling-related harm”. Etches reflects on the numbers of 11–16 year olds with a gambling disorder and signifies concern for the future. Contrastingly earlier that year, evidence reported on by the World Health Organisation (WHO) reflected a worryingly significant ongoing neglected public health crisis with an “urgent need to place gambling on national and international public health agendas”. 1 References 1. Abbott M. The epidemiology and impact of gambling disorder and other gambling-related harm. Geneva: World Health Organization; 2017. Available from: https://www.who.int/docs/default-source/substance-use/the-epidemiology-and-impact-of-gambling-disorder-and-other-gambling-relate-harm.pdf?sfvrsn=5901c849_2 [Accessed: 25th March 2020] 2. Langham E, Thorne H, Browne M, Donaldson P, Rose J, Rockloff M. Understanding gambling related harm: A proposed definition, conceptual framework, and taxonomy of harms. BMC Public Health. 2016;16(1): 80. Available from: doi:10.1186/s12889-016-2747-0 3. Banks J, Andersson C, Best D, Edwards M, Waters J. Families Living with Problem Gambling: Impacts, Coping Strategies and Help-Seeking. 2018. Available from: https://about.gambleaware.org/ [Accessed: 13th March 2021] 4. Rawat V, Browne M, Bellringer M, Greer N, Kolandai-Matchett K, Rockloff M, et al. A tale of two countries: comparing disability weights for gambling problems in New Zealand and Australia. Quality of Life Research. 2018;27(9): 2361–2371. Available from: doi:10.1007/s11136-018-1882-8 5. Rawat V, Greer N, Langham E, Rockloff M, Hanley C. What is the harm? Applying a public health methodology to measure the impact of gambling problems and harm on quality of life. Journal of Gambling Issues. 2017;36(36). Available from: doi:10.4309/jgi.2017.36.2 6. Browne M, Bellringer M, Greer N, Kolandai-Matchett K, Rawat V, Langham E, et al. Measuring the Burden of Gambling Harm in New Zealand. Central Queensland University and Auckland University of Technology. 2017. 7. Browne M, Langham E, Rawat V, Greer N, Li E, Rose J. Assessing gambling-related harm in Victoria: a public health perspective. Victorian Responsible Gambling Foundation. 2016. 8. Muggleton N, Parpart P, Newall P, Leake D, Gathergood J, Stewart N. The association between gambling and financial, social and health outcomes in big financial data. Nature Human Behaviour. 2021;5(3): 319–326. Available from: doi:10.1038/s41562-020-01045-w [Accessed: 22nd March 2021] 9. Wardle H, Dymond S, John A, McManus S. Problem gambling and suicidal thoughts, suicide attempts and non-suicidal self-harm in England: evidence from the Adult Psychiatric Morbidity Survey 2007. Gambling Commission. 2019. 10. Wardle H, McManus S. Suicidality and gambling among young adults in Great Britain: results from a cross-sectional online survey. The Lancet Public Health. 2021;6(1): e39–e49. Available from: doi:10.1016/S2468-2667(20)30232-2 11. Karlsson A, Håkansson A. Gambling disorder, increased mortality, suicidality, and associated comorbidity: A longitudinal nationwide register study. Journal of Behavioral Addictions. 2018;7(4): 1091–1099. Available from: doi:10.1556/2006.7.2018.112 12. Michael Dugher. It’s important that the Gambling Review tackles betting by under-18s – but let’s deal in facts, not fiction. Available from: https://www.politicshome.com/members/article/michael-dugher-its-important-that-the-gambling-review-tackles-betting-by-under18s-but-lets-deal-in-facts-not-fiction [Accessed: 28th March 2021] 13. Gambling Commission. Gambling-related harm as a public health issue. 2018. Available from: https://www.gamblingcommission.gov.uk/PDF/Gambling-related-harm-as-a-public-health-issue.pdf [Accessed: 1st February 2021] 14. @MichaelDugher. ‘1. NHS Charities said it wouldn’t be possible for betting co’s to make a direct donation, but they were happy for us to donate all the profits from this special fun virtual Grand National to help the NHS at this difficult time. Most people agree there’s nothing wrong with this...’. [cited 2020 April 3.] Available from: https://twitter.com/MichaelDugher/status/1246177242939559944 [Accessed: 28th March 2021] 15. BBC Sport. Virtual Grand National raises £2.6m for NHS Charities Together. BBC Sport. 5 April 2020. Available from: https://www.bbc.co.uk/sport/horse-racing/52175385 [Accessed: 29th March 2021] 16. UK Parliament – Betting and Gaming Council. Betting and Gaming Council – Written evidence (GAM0068). 2019. Available from: https://committees.parliament.uk/writtenevidence/154/html/ [Accessed: 29th March 2021] 17. Davies R. 25,000 children in Britain are problem gamblers, report finds. The Guardian. 12 December 2017. Available from: https://www.theguardian.com/society/2017/dec/12/children-britain-problem-gamblers-report [Accessed: 29th March 2021]
- Gambling and addiction
The industry consistently emphasises that gambling addiction affects a small minority of individuals, benefitting from the fact that gold-standard prevalence surveys were stopped after 2010 due to funding cuts. The industry reflects on the estimates generated by data from self-completion forms included in health surveys or telephone surveys. On the other hand, more recent online studies have reported much higher gambling addiction rates, but the industry has dismissed these higher rates. Additionally, the industry fails to reflect that harmful gambling and gambling addiction should be viewed as a continuum. Moreover, more than half of the harm in individuals that gamble is expected to occur at the low-risk and moderate-risk harm levels. Summary The potential for addiction is influenced by intrinsic biological factors, extrinsic factors, and factors related to the addictive agent's ability to activate the brain's risk-reward areas. Like other addictions, dopamine has a crucial and well-documented role in developing and maintaining Gambling Disorder (GD). Gambling addiction is most prevalent among younger people. Other risk factors include a parent who suffered from a gambling disorder, poor mental health status, poor general health status, unemployment, and minority ethnic backgrounds. GD is a behavioural addiction characterised by compulsive involvement in gambling activities, despite severe adverse consequences. GD is defined in the Diagnostic and Statistical Manual of Mental Disorders as "persistent and recurrent problematic gambling behaviour leading to clinically significant impairment or distress". GD has been recently included in the disorder class of "substance-related and addictive disorders". It is essential to recognise that significant harms can occur in individuals who do not meet GD's clinical threshold as the diagnosis represents the most severe end of addiction and harm. According to research from Australia, gambling harm in individuals with GD makes up only 15% of the overall gambling harm suffered by those that gamble. Most of the harms on a population level are accrued by individuals who may be on the spectrum of addiction but not at GD's threshold. These findings are analogous to the scenario for alcohol harm, where harmful drinking in those without severe dependency is responsible for more significant amounts of harm. However, unlike alcohol harm, which is grouped into a single disorder on a continuum with mild, moderate, and severe sub-classifications, gambling-harm at mild and moderate levels are often treated with contempt. Industry lobbyists often comment on prevalence statistics of those suffering the most severe harms from their gambling. Through this narrative, the industry can hide behind the idea that gambling affects only a tiny minority of the overall population, neglecting that more than half of the gambling harm in individuals that gamble is attributable to low-risk harm and moderate-risk harm. Moreover, adult prevalence statistics following 2010 are primarily limited to self-completion forms in health surveys due to a funding cut instead of the gold-standard bespoke gambling prevalence surveys. What is known? Genetics of gambling disorder Twin studies investigating the genetics of pathological gambling have found that: 18 ‘heritability of pathological gambling is estimated to be 50–60%; pathological gambling and subclinical pathological gambling are a continuum of the same disorder; pathological gambling shares genetic vulnerability factors with antisocial behaviours, alcohol dependence and major depressive disorder; genetic factors underlie the association between exposure to traumatic life‐events and pathological gambling’ Risk factors for gambling disorder (Odds Ratio): 19, 20 Parents regularly gambled but did not have a problematic relationship with gambling: 1.58 Current cigarette smoker: 2.46 ‘Other’ ethnic minority groups: 2.86 Unmanaged hypertension: 3.10 Asian/Asian British: 3.55 Black/Black British: 3.80 Unemployed: 4.02 Bad/very bad general health status: 6.17 Parents regularly gambled and had a problematic relationship with gambling: 7.32 A low Warwick-Edinburgh Mental Wellbeing score: 7.65 Prevalence of gambling harm from own gambling in adults across the world (past 12 months) Great Britain British Gambling Prevalence Surveys 2007 and 2010 (Gold-standard) 19, 21 low-risk harm: 5.1 – 5.5%, moderate-risk harm: 1.4% - 1.8%, gambling disorder harm: 0.8% - 1.2% Self-completion forms included in health surveys 2012 – 2018 20, 22-24 low-risk harm: 2.5% - 3.9% moderate-risk harm: 0.8% - 1.1% gambling disorder harm: 0.5% - 0.9% Telephone surveys 2016 -2020 25 low-risk harm: 2.0% - 3.7% moderate-risk harm: 0.9% - 1.9% gambling disorder harm: 0.3% - 0.7% Online surveys 2019 – 2020 26 low-risk harm: 7.0% - 7.2% moderate-risk harm: 2.8% - 3.3% gambling disorder harm: 2.6% - 2.7% Isle of Man 27 Gambling Prevalence Survey 2017 7.0% low-risk harm 1.5% moderate-risk harm 0.8% gambling disorder harm Northern Ireland 28 Gambling Prevalence Survey 2010 8.2% low-risk harm 5.9% moderate-risk harm 2.6% gambling disorder harm 28 Gambling Prevalence Survey 2016 6.7% low-risk harm 4.9% moderate-risk harm 2.3% gambling disorder harm Scandinavia 29 Denmark Gambling Prevalence Survey 2016 3.6% low-risk harm 1.2% moderate-risk harm 0.4% gambling disorder harm Finland Gambling Prevalence Survey 2015 8.7% low-risk harm 2.8% moderate-risk harm 0.5% gambling disorder harm Norway Gambling Prevalence Survey 2015 7.7% low-risk harm 2.3% moderate-risk harm 0.9% gambling disorder harm Sweden Gambling Prevalence Survey 2015 4.2% low-risk harm 1.3% moderate-risk harm 0.4% gambling disorder harm 30 Italy Problem Gambling Survey 2018 4.1% low-risk harm 2.8% moderate-risk harm 3.0% gambling disorder harm 31 Victoria, Australia Gambling Prevalence Study 2014 8.9% low-risk harm 2.8% moderate-risk harm 0.8% gambling disorder harm 7 Gambling Prevalence Study 2019 6.7% low-risk harm 2.4% moderate-risk harm 0.7% gambling disorder harm 32 New Zealand Meta-analysis of survey results 2010 - 2016: 3.1% low-risk harm 1.5% moderate-risk harm 0.5% gambling disorder harm 33 Health Survey 2012: 2.0% low-risk harm 1.0% moderate-risk harm 0.2% gambling disorder harm 34 National Gambling Study 2012: 5.0% low-risk harm 1.8% moderate-risk harm 0.7% gambling disorder harm 35 What the industry said? Betting and Gaming Council 16 “Rates of problem gambling in Great Britain are stable and low by international standards and we are committed to doing more to ensure safer gambling” The BGC omits consideration for the vast majority of individuals who suffer gambling-harm and instead focuses on the smaller population who suffer the most severe forms of harm. Moreover, the BGC states that gambling disorder harm rates are stable despite the absence of a gold-standard prevalence study since 2010 due to a funding cut. Michael Dugher, CEO of the Betting Gaming Council 36 “I recognise the concerns people have when around 0.6 per cent of those who bet are classed as ’problem gamblers’.” Dugher demonstrates a lack of understanding of gambling harm by stating that 0.6% of those who bet suffer from a gambling disorder. Contrastingly, the most recent gold-standard study in 2010 reflected that approximately 1.6% of individuals that gambled in the past year suffer from the most severe form of addiction. After excluding individuals who exclusively play on the lottery and those who do not gamble regularly, this rate would be far higher. Moreover, the harms suffered by non-adults are entirely omitted. Notably, the gambling disorder harm rate is much higher in 11-16 year olds where 5.1% of individuals who gambled in the past year or 1.9% of the overall population affected by gambling disorder. “Of those problem gamblers, a smaller but still significant number are ‘disordered’ or addicted gamblers.” Dugher also demonstrates a confused understanding of addiction, as the most severe form of harm is at the gambling disorder level. As ever and despite the evidence, the industry refuses to embed an understanding of addiction and gambling-harm as being on a continuum and thus ignore the harms suffered by individuals who gamble and experience low-risk harms and moderate-risk harms. “That might be a tiny fraction – and we shouldn’t forget of course that millions of people gamble safely – but the effect of addiction on these individuals and their families can be devastating.” Here the CEO of the BGC, quite unusually, recognises that family members can suffer devastating harms but omits the statistic that between 6% to 7% of adults have reported suffering affected other harms in Great Britain. Michael Dugher, CEO of the Betting Gaming Council 37 “For millions of people, it is a carefree leisure activity, and they do so perfectly safely and perfectly responsibly.” Dugher uses the term “millions of people” to describe the number of individuals who gamble with no significant consequences while neglecting that millions of people suffer significant harm from gambling. “But we recognise, as do the Government, as do campaigners and others that there is a small group of people who can have a problem with this, and in some cases it can be very, very severe.” Dugher suggests that there is only a small group of people who suffer harm from gambling. Furthermore, Dugher and colleagues often implies that campaigners wanting reform are prohibitionists and have an issue with gambling as a leisure activity, despite evidence from lived experience campaigners showing that this claim is not valid. 38 “What we're saying is you've got to get the regulation right because what we don't want is to drive customers away from safer gambling on the regulated high standard sites to the illegal black market offshore companies.” Paradoxically, Dugher highlights the concern of black market offshore companies while failing to recognise that before 2014, a large number of remote operators were not regulated, and the vast majority of companies continue to base offshore to avoid the UK’s corporation tax. Moreover, remote operators are global by nature and thus have customers in the black market in other countries. Brigid Simmonds, Chair of the Betting and Gaming Council 39 “Just as we intervene with our customers so banks should as well:” Simmonds deflects responsibility for safer gambling to banks, such that just like operators, banks should intervene to prevent gambling-harm. However, operator interventions are often limited to safer gambling messages as operators seldom close accounts that are profit-making for the industry. “We take our responsibility to our customers incredibly seriously and we are determined to raise standards and improve safer gambling,” Simmonds then repeats vague commitments to raising standards and improving safer gambling. Brigid Simmonds, Chair of the Betting and Gaming Council 40 … "we have worked together on BetRegret"… Simmonds comments on her role in developing the “BetRegret” campaign, which has been widely criticised for furthering stigma by placing responsibility on customers, potentially increasing self-blame, and for being drowned out by the sheer volume of contradictory betting advertisements. Michael Dugher, CEO of the Betting Gaming Council 41 “Place you bets now please… #RouletteBoy” "I thought you liked casinos, young Matt?" Dugher uses social media to mock someone who is now abstinent; in doing so, he demonstrates his contempt for those who have suffered gambling-harm, the legacy effects of those harms, and the chronic nature of addiction. References 7. Browne M, Langham E, Rawat V, Greer N, Li E, Rose J. Assessing gambling-related harm in Victoria: a public health perspective. Victorian Responsible Gambling Foundation. 2016. 16. UK Parliament – Betting and Gaming Council. Betting and Gaming Council – Written evidence (GAM0068). 2019. Available from: https://committees.parliament.uk/writtenevidence/154/html/ [Accessed: 29th March 2021] 17. Davies R. 25,000 children in Britain are problem gamblers, report finds. The Guardian. 12 December 2017. Available from: https://www.theguardian.com/society/2017/dec/12/children-britain-problem-gamblers-report [Accessed: 29th March 2021] 18. Lobo DSS, Kennedy JL. Genetic aspects of pathological gambling: a complex disorder with shared genetic vulnerabilities. Addiction. 2009;104(9): 1454–1465. Available from: doi:10.1111/j.1360-0443.2009.02671.x 19. Wardle H, Moody A, Spence S, Orford J, Volberg R, Jotangia D, et al. British Gambling Prevalence Survey 2010. The Gambling Commission. 2011. 20. Seabury C, Wardle H. Gambling behaviour in England & Scotland Headline findings from the Health Survey for England 2012 and Scottish Health Survey 2012. NatCen. 2014. 21. Wardle H, Sproston K, Orford J, Erens B, Griffiths M, Constantine R, et al. British Gambling Prevalence Survey 2007. NatCen. 2007 22. Gambling Commission. Participation in gambling and rates of problem gambling - England 2016 - Statistical report. Gambling Commission. 2016. 23. Barnfield-Tubb J, Francis C. Gambling participation in 2019: behaviour, awareness and attitudes. 2020. Available from: https://www.gamblingcommission.gov.uk/PDF/survey-data/Gambling-participation-in-2019-behaviour-awareness-and-attitudes.pdf [Accessed: 29th March 2020] 24. Conolly A, Fuller E, Jones H, Maplethorpe N, Sondaal A, Wardle H. Gambling behaviour in Great Britain in 2015: Evidence from England, Scotland and Wales. NatCen. 2017. 25. Gunstone B, Gosschalk K, Joyner O, Diaconu A, Sheikh M. The impact of the COVID-19 lockdown on gambling behaviour, harms and demand for treatment and support. Gambling Research Exchange Ontario. 2020. 26. Gambling Commission. Gambling behaviour in 2020: Findings from the quarterly telephone survey. Gambling Commission; 2021. Available from: https://beta.gamblingcommission.gov.uk/statistics-and-research/publication/year-to-december-2020 [Accessed: 30th March 2021] 27. Butler N, Quigg Z, Bates R, Sayle M, Ewart H. Isle of Man Gambling Survey 2017: Prevalence, methods, attitudes. Public Health Institute, Liverpool John Moores University. 2018. 28. Dunne S, Flynn C, Sholdis J. 2016 Northern Ireland Gambling Prevalence Survey. Northern Ireland Statistics and Research Agency. 2017. 29. Pallesen S. PREVALENCE OF GAMBLING PROBLEMS IN THE NORDIC COUNTRIES. [Presentation] University of Bergen. 30th May 2017. 30. Folkhälsomyndigheten. Published Material. Available from: www.folkhalsomyndigheten.se/publicerat-material [Accessed: 10th January 2021] 31. Stradbrooke S. Italy gambling survey casts doubt on effectiveness of advert ban. CalvinAyre.com. 19 October 2018. Available from: https://calvinayre.com/2018/10/19/business/italy-gambling-survey-advertising-effectiveness/ [Accessed: 28th February 2021] 32. Victorian Responsible Gambling Foundation. FACT SHEET 3: PROBLEM GAMBLING SEVERITY INDEX (PGSI) Victorian Population Gambling and Health Study (2018-2019). 2020. Available from: https://responsiblegambling.vic.gov.au/resources/publications/fact-sheet-3-problem-gambling-severity-index-pgsi-762/ [Accessed: 30th March 2021] 33. Ministry of Health New Zealand. Health and Lifestyle Survey – Monitoring gambling harm and knowledge. Available from: https://www.health.govt.nz/our-work/mental-health-and-addiction/addiction/gambling/gambling-research-and-evaluation/key-information-sources-gambling-harm-and-service-utilisation/health-and-lifestyle-survey-monitoring-gambling-harm-and-knowledge [Accessed: 28th February 2021] 34. Rossen F. Gambling And Problem Gambling: Results Of The 2011/12 New Zealand Health Survey Final Report. Ministry of Health New Zealand. 2015. 35. Bellringer M. New Zealand 2012 National Gambling Study: Gambling Harm And Problem Gambling. Ministry of Health New Zealand. Report number: 2, 2014. 36. Dugher M. We Need Big Changes And A Race To The Top On Standards In Gambling. Available from: https://bettingandgamingcouncil.com/news/michael-dugher [Accessed: 29th March 2021] 37. Hirst I. Government must tackle rates of gambling addiction which is a ‘crisis waiting to happen’, according to MP. Dewsbury Reporter. 7 January 2021. Available from: https://www.dewsburyreporter.co.uk/news/opinion/government-must-tackle-rates-gambling-addiction-which-crisis-waiting-happen-according-mp-3087969 [Accessed: 30th March 2021] 38. Gambling Harm UK. Lived Experience Community Respond to Remote Customer Interaction Call for Evidence. Available from: https://www.gamblingharm.com/post/lived-experience-community-respond-to-remote-customer-interaction-call-for-evidence [Accessed: 31st March 2021] 39. Hancock A. Betting industry body hits out at role of banks and tech in addiction. Financial Times. 3 February 2020. Available from: https://www.ft.com/content/4cc7cfa2-4692-11ea-aeb3-955839e06441 [Accessed: 30th March 2021] 40. @BrigidSimmonds. ‘Many congratulations Zoe, we have worked together on BetRegret & your knowledge & expertise in advertising, marketing & how charities can work with other partners & industry will be vital to your new role @GambleAware’. [cited 14 January 2021] Available from: https://twitter.com/BrigidSimmonds/status/1349755154640347137 [Accessed: 30th March 2021] ] 41. Boycott-Owen M. Gambling industry chief accused of mocking recovering addict on Twitter. The Telegraph. 5 February 2021. Available from: https://www.telegraph.co.uk/news/2021/02/05/gambling-industry-chief-accused-mocking-recovering-addict-twitter/ [Accessed: 30th March 2021]
- Gambling in children and young people
Evidence from Great Britain reflects that gambling is one of the more popular activities among 11–16 year olds. However, the industry comment that most of this gambling is done legally through private betting, significant numbers of young people enter licensed gambling venues illegally. Brain imaging studies have shown that brain development continues until the age of 25. The brain area related to decision-making and addictive behaviour is among the last to develop. Thus, it is not surprising that gambling harms, similar to other harmful behaviours, are most common in 16–24 year olds. As well as being vulnerable to harms from their gambling with potentially devastating life-long effects, young people are especially susceptible to harms from a family member’s gambling, which has not been considered in research until recently. The Gambling Act 2005 sets out three licensing objectives 42 “preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime ensuring that gambling is conducted in a fair and open way protecting children and other vulnerable persons from being harmed or exploited by gambling” Summary The third licensing objective in the Gambling Act 2005 specifically singles out children as a vulnerable group who should be protected from being harmed or exploited by gambling. Gambling-harms in young people are of particular significance; young people are more vulnerable to harm, and these harms can have a significant impact, both now and in the future. Moreover, as well as experiencing harm from their gambling, young people can also be susceptible to harm from an immediate family member's gambling through parental neglect or from other stresses, as detailed in the appendix. There is consistent and robust evidence from imaging studies that brain development continues through adolescence and does not complete until the age of 25 or later. Furthermore, the prefrontal cortex, an area of the brain tied to addictive behaviours due to its role in regulating reward regions of the brain and its involvement in higher-order executive function, is among the last to develop. Moreover, similar to other addictive products, such as alcohol and recreational drugs, the age of onset for first gambling is significantly associated with gambling disorder in later life. In Great Britain, the legal age for gambling varies by product. Some gambling products have no age-restrictions, others restricted for individuals 16 years and older, with traditional gambling products having the legal age of 18. Remarkably, loot boxes, although the most popular wagering activity among under 16s, are not yet considered a form of gambling and therefore unregulated. On top of games of chance where children can lose money, popular video games such as Grand Theft Auto 5 feature simulated gambling where players can gamble for virtual currencies. Despite all this, young people have profoundly limited access to appropriate treatment, help, or support. Notably, contrasting with the widespread recognition for substance-use harm, gambling-harm does not feature in competency-based curriculums for specialists in child and adolescent psychiatry (CAMHS). What is known? Legal definitions of youth and age of maturity 43 The age of majority is 18 years in all EU Member States except for Scotland, where children are considered to have full legal capacity from the age of 16 years. In EU Member States, the term ‘youth’ is the only term used to describe an age group that goes beyond 18 years. It is often used when States want to include young adults as well, sometimes up to the age of 30 years. The UN’s definition on the term ‘youth’ includes all persons between the ages of 15 and 24 years; UNESCO uses a wider and more flexible definition depending on the context. In the EU Strategy for Youth, the term ‘youth’ refers to teenagers and young adults aged between 13 and 30 years. EUROSTAT statistics consider the youth population to be aged between 15 and 29 years. Brain development during adolescence and youth 44 Brain maturation occurs during adolescence due to a surge in the synthesis of sex hormones. Types of studies that have provided evidence that structural and functional brain development is an active stage of maturation until at least the age of 25 neuromorphological, neurochemical, neurophysiological, neurobehavioral, neuropharmacological, and brain imaging studies Legal age of gambling by product 45 No age limit Private or Non-Commercial Betting Equal chance gaming Prize gaming at entertainment centre or travelling fair Category D gaming machines Games of chance in video-games (not considered gambling) 16 years old National lottery tickets and scratchcards in shops (18 from October 2021) National lottery tickets and scratchcards online (18 from April 2021) 18 years old Casino, betting shops or licensed premises Category A, B1, B2, B3, B3A, B4 and C gaming machines Football pool Gambling among secondary school students (11-16 year olds) >1 million 11-16 year olds gambled in the past-year 46 In 2018, gambling (14%) was more popular as a past-week activity among 11-16 year olds than alcohol use (13%), tobacco use (4%), and drug-taking (2%) 47 In 2019, gambling (11%) was less prevalent as a past-week activity among 11-16 year olds than alcohol use (16%), but more common than tobacco cigarettes (6%), e-cigarettes (7%), and drug-taking (5%) 46 In 2019, the most prevalent past-week gambling activity (excluding video game gambling) among 11-16 year olds was placing a private bet for money (e.g. with friends) at 5%, followed by: 46 Fruit or slot machines (e.g. at an arcade, pub or club): 4% National Lottery scratchcards which you bought in a shop: 3% Playing cards for money with friends: 3 Personally placing a bet at a betting shop: 3% Lotto (the main National Lottery draw): 2% National Lottery instant win games on the internet: 2% Any other National Lottery games (e.g. EuroMillions): 2% Other Lotteries: 2% Bingo at a bingo club: 2% Bingo at somewhere other than a bingo club: 2% Personally visiting a betting shop to play gaming machines: 2% Playing other gambling machines: 2% Personally visiting a casino to play casino games: 2% Gambling websites/apps where you can win real money: 2% Any other gambling: 3% The most popular form of games of chance with money are in video games Ever-played 46 Used in-game items to open loot boxes/crates/packs to get other in-game items within the game you were playing 11-16 year olds: 28% Paid money to open loot boxes/crates/packs to get other in-game items within the game you were playing 11-16 year olds: 23% Bet with in-game items on website outside of the game or privately (e.g. with friends)11-16 year olds: 3% Past-year 48 Paid money to open loot boxes 10-16 year olds: 20% Past-week 49 Paid money to open loot boxes 11-14 year olds: 27% 18+ year olds: 16% Investigations into under age gambling The Gambling Commission ran a test at the Royal Ascot in 2014, where all 20 bookmarkers served a 16-year old without asking for proof of age, and consequently received a written warning. In 2019, this test was repeated, with 7 out of 17 failing to ask for ID. 50,51 Gambling-harm among children and young people In 11-16 year old school students 46,52 Meta-analysis of prevalence in 2018 – 2020 46,47,52 By frequency Past week gambling: 9% - 14% Past year gambling: 36% - 39% By harm level Low-risk and moderate-risk harm gambling: 2.2% - 2.7% Gambling disorder harm gambling: 1.7% - 1.9 Other gambling: 32% - 33% DSM-IV-MR J harms: 46 Found yourself thinking about gambling or planning to gamble often: 1.7% Gambled to escape from problems or when you were feeling bad sometimes or often: 2.0% Felt bad or fed up when trying to cut down on gambling sometimes or often: 1.2% Needed to gamble with more and more money to get the amount of excitement you want sometimes or often: 1.9% Spent much more than you planned to on gambling sometimes or often: 1.6% Taken money without permission to spend on gambling (any one or more of the following: dinner money or fare money, money from family, money from things you’ve sold, money from outside the family, or somewhere else) Any one or more of the above: 3.8% Gambling led to risk relationships (any one or more of the following: arguments with family/friends or others, missing school): Any one or more of the above: 2.5% Gambling ever led to telling lies to family/friends or others once or twice or sometimes or often: 2.1% After losing money by gambling, have you returned another day to try to win back the money you lost more than half the time or every time: 1.6% Other harms 52 Lost sleep at night because you went to bed late because you were gambling rarely or sometimes or often or all the time: 2.5% often or all the time: 1.1% Lost sleep at night because you were worried about own gambling rarely or sometimes or often or all the time: 1.7% often or all the time: 0.3% Stopped you from buying things you wanted rarely or sometimes or often or all the time: 4.3% often or all the time: 1.3% Made it hard for you to concentrate at school rarely or sometimes or often or all the time: 3.8% often or all the time: 1.4% Made it hard for you to put effort into your homework or personal study rarely or sometimes or often or all the time: 3.4% often or all the time: 1.4% Made you not feel comfortable around your friends rarely or sometimes or often or all the time: 2.7% often or all the time: 0.9% In 11-16 year olds school students (statistics of harmed by an immediate family member(s) gambling) 52 Felt bad because of gambling among family members: 5.5% 46 Lost sleep at night because of worrying about a family member’s gambling rarely or sometimes or often or all the time: 4.9% often or all the time: 1.3% Not had enough food (food at home or money on school canteen card/account) rarely or sometimes or often or all the time: 1.8% often or all the time: 1.1% Stopped you from belonging to clubs or doing activities you like doing rarely or sometimes or often or all the time: 1.3% often or all the time: 1.0% Stopped you from going on trips (e.g. family holidays or school outings rarely or sometimes or often or all the time: 1.8% often or all the time: 0.9% Parent’s or guardians have less time to spend with you rarely or sometimes or often or all the time: 1.6% often or all the time: 1.0% More arguments or tension at home rarely or sometimes or often or all the time: 2.1% often or all the time: 1.2% Has made you feel sad rarely or sometimes or often or all the time: 2.4% often or all the time: 0.6% Has made you feel worried rarely or sometimes or often or all the time: 2.9% often or all the time: 0.7% In 18-24 year old university students 53 47% of students gambled in the past 12 months 8% of which suffer low-risk harm 8% of which suffer moderate-risk harms 8% of which suffer gambling disorder harms Overall, 11% of students suffer significant harm from their gambling, and 4% of students suffer the most severe level of harm from their gambling What the industry said? Matthew Hill, Director of the Gambling Commission 50 “This was a pretty poor result. Preventing under 18s from gambling is one of the most basic obligations every bookmaker has, on or off the course. The industry must do better or operators are likely to find themselves facing formal sanctions.” Hill warns operators of the possibility of sanctions for failing to protect children from gambling as all twenty operators tested allowed a 16 year old to gamble at the Royal Ascot 2014. Richard Watson, Executive Director of the Gambling Commission 51 “Every single gambling business must protect children from gambling but the on course bookmakers results have remained unacceptable. Despite various educational attempts to raise standards, by ourselves and the trade bodies, the on-course sector has historically performed poorly in both underage gambling test purchase exercises and Think 21 testing. Pass rates have failed to meet the standards expected and the sector has consistently performed to levels below those we see in other gambling and age restricted products. By way of example, over the past four years, the on-course sector has a pass rate of around 35% for Think 21 testing.” Watson reports that on-course bookmakers fail to meet the standards expected in preventing underage gambling following an investigation where 7 out of 17 operators allowed a 16 year old to gamble at the Royal Ascot 2019. Michael Dugher, CEO of the Betting Gaming Council 12 “We have already done a lot and we are ready to go even further to prevent underage gambling” Dugher refuses to accept responsibility for industry failings in meeting one of the three licensing objectives. Instead, he uses a vague statement and commitment to defend the prevalence of underage gambling. Michael Dugher, CEO of the Betting Gaming Council 12 "far from trying to entice children to gamble, regulated members of the BGC have a zero tolerance approach to betting by under-18s," and that they welcome the raising of the age limit from 16 to 18 for lottery products. Dugher suggests that regulated members of the BGC have a zero-tolerance approach to underage gambling, despite prevalence statistics and undercover investigations by the Gambling Commission reflecting the contrary. Michael Dugher, CEO of the Betting Gaming Council 36 "I'm also pleased to see that new age-verification and ID checks have resulted in literally hundreds of thousands of accounts being closed recently, where the customer was unable or unwilling to meet the new strict criteria" Dugher reports feeling pleased that the Gambling Commission set rules that mandate operators to verify customers age and identity before allowing them to gamble. Tim Miller, Executive Director of the Gambling Commission 54 “There's no doubt that today's figures on children and gambling should make people sit up and listen, he said. But while discussions about children gambling might conjure up images of kids sneaking into bookies or sitting alone on their iPad gambling on an online casino, our latest research paints a more complex picture. The most common activities that children gamble on are not licensed casinos, bingo providers or bookies. Instead we found children preferred to gamble in informal environments, out of sight of regulation - private bets between friends or playing cards with their mates for money.” Miller states that gambling figures for young people are worrying but argues that underage gambling is not happening mainly in betting shops or online. Although non-regulated forms of activity such as video game gambling and private betting may be more common among 11-16 year olds, staggering numbers of this population are able to enter licensed betting premises and gamble. Marc Etches, CEO of GambleAware 17 "Computer gaming with gambling presents real future challenges to the current regulatory framework. We've been saying for some time we have concern about the normalisation of gambling for young people..." Etches points to the regulatory gap in recognising games of chance in computer gaming as part of gambling. Michael Dugher, CEO of the Betting Gaming Council 55 “tackling betting by under 18s is a top priority. BGC members have a zero tolerance approach to underage betting - unlike the illegal, online black market - but are determined to do more to protect young people.” Dugher acknowledges that betting by under 18s is an issue and that it is a top priority. He also states that BGC members have a zero-tolerance approach to underage betting despite consistent statistics of 11-16 year olds entering licensed betting premises such as casinos and betting shops in the past week. References 12. Michael Dugher. It’s important that the Gambling Review tackles betting by under-18s – but let’s deal in facts, not fiction. Available from: https://www.politicshome.com/members/article/michael-dugher-its-important-that-the-gambling-review-tackles-betting-by-under18s-but-lets-deal-in-facts-not-fiction [Accessed: 28th March 2021] 17. Davies R. 25,000 children in Britain are problem gamblers, report finds. The Guardian. 12 December 2017. Available from: https://www.theguardian.com/society/2017/dec/12/children-britain-problem-gamblers-report [Accessed: 29th March 2021] 36. Dugher M. We Need Big Changes And A Race To The Top On Standards In Gambling. Available from: https://bettingandgamingcouncil.com/news/michael-dugher [Accessed: 29th March 2021] 42. Gambling Commission. Part 5: Principles to be applied by licensing authorities. Available from: https://www.gamblingcommission.gov.uk/for-licensing-authorities/GLA/Part-5-Principles-to-be-applied-by-licensing-authorities.aspx [Accessed: 30th March 2021] 43. European Union Agency for Fundamental Rights. Age of majority. Available from: https://fra.europa.eu/en/publication/2017/mapping-minimum-age-requirements/age-majority [Accessed: 22nd March 2021] 44. Arain M, Haque M, Johal L, Mathur P, Nel W, Rais A, et al. Maturation of the adolescent brain. Neuropsychiatric Disease and Treatment. 2013;449–461. Available from: doi:10.2147/NDT.S39776 45. Great Britain. Gambling Act 2005: Elizabeth II. Chapter 19. London: The Stationery Office; 2001. 46. The Gambling Commission. Young People and Gambling Survey 2019. The Gambling Commission. 2019. 47. Gambling Commission. Young People & Gambling 2018. Gambling Commission. 2018. 48. Parent Zone. The Rip-Off Games: How the new business model of online gaming exploits children. Parent Zone. 2019. 49. Royal Society for Public Health. Skins in the Game. Royal Society for Public Health. 2019. 50. Gambling Commission. Twenty bookmakers at Ascot allowed 16-year-old to bet: operators warned they must improve underage gambling controls. Gambling Commission. 2 July 2014. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/News/twenty-bookmakers-at-ascot-allowed-16-year-old-to-bet-operators-warned-they-must-improve-underage-gambling-controls [Accessed: 23rd March 2021] 51. Gambling Commission. On course bookies face licence reviews. Gambling Commission. 30 July 2019. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/news/2019/On-course-bookies-face-licence-reviews.aspx [Accessed: 23rd March 2021] 52. Gambling Commission. Young People and Gambling. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/Statistics-and-research/Levels-of-participation-and-problem-gambling/Young-persons-survey.aspx [Accessed: 28th February 2021] 53. Young Gamers and Gamblers Education Trust. How gaming & gambling affect student life. Young Gamers and Gamblers Education Trust. 2019. 54. BBC News. Number of child gamblers quadruples in just two years. BBC News. 21 November 2018. Available from: https://www.bbc.co.uk/news/business-46286945 [Accessed: 29th March 2021] 55. Betting and Gaming Council. BGC Chief Executive @MichaelDugher says tackling betting by under 18s is a top priority. BGC members have a zero tolerance approach to underage betting - unlike the illegal, online black market - but are determined to do more to protect young people. Available from: https://www.facebook.com/BettingAndGamingCouncil/photos/a.105106001278691/330551518734137/?type=3 [Accessed: 29th March 2021]
- Gambling and advertising
The industry maintains that advertising has no effect on consumption but instead helps operators differentiate product offerings and for customers to identify which brands are regulated and therefore can be trusted. Evidence from the Gambling Commission reflects the contrary. Younger adults, in particular, were more likely to be affected by advertising to spend money on gambling when they were not otherwise planning to. Worryingly, this phenomenon has been reported even among 11-16 year olds. The industry is keen to prevent meaningful reform on gambling advertising nationally and internationally because of its importance in driving gambling in the short-term and the long-term through a normalisation effect. The importance of advertising to the industry is highlighted by their lobbying against change and their expenditure. Summary Over the past decade, gambling advertising has grown exponentially. In the present day, gambling advertising is ubiquitous, with a distinct presence across various mediums, including online advertising, social media, affiliates, television, radio, newspapers, sponsorships, and physical ads in stores. The widespread nature of gambling advertising has meant inevitable exposure to vulnerable groups, such as young people and individuals with special educational needs and disabilities. Moreover, the volume of ads has led to a normalisation effect, such that young people are growing up in an era where gambling is seen as a normal part of everyday life. This phenomenon is particularly noticeable in sport. Advertising is vital to the gambling industry for one encompassing reason: increasing consumption and increasing yields. Increased gambling can be broken down into activity among new customers and returning customers. The importance of advertising to the industry is demonstrated by the sheer size of investments made and its fierce opposition to meaningful regulation in Great Britain and abroad. Like the tobacco industry, the gambling industry maintains the notion that advertising does not affect consumption but merely helps promote safer gambling by directing customers to regulated brands and helps customers differentiate offerings between brands. However, the industry would not spend as much on advertisements if it did not increase customers' gambling losses and increase industry profits. Online advertising is particularly significant for the gambling industry as it benefits from targeting and the accessibility of online gambling, where ads facilitate a more direct link to the product. According to the Advertising Standards Authority, there are several themes to the concerns around gambling advertising and these are: Links to problem gambling Children's exposure Online media Societal expectations Aggressive advertising Misleading advertising Some of the industry has recognised that there are significant issues with advertising, including the sheer volume of ads, their presence in sports, and ads' ability to reach young people in sports and online. However, despite these well-grounded concerns, little meaningful action has been taken. Instead, industry efforts have been self-heralded as successes demonstrating the industry's ability to self-regulate. Recent industry measures, which have been criticised for include the 'whistle-to-whistle’ advertising ban and the use of safer gambling messages during the pandemic, are discussed in more detail in the voluntary bans chapter. What is known? Advertising spend by the UK Gambling Industry According to the Advertising Association, the UK’s gambling industry advertising spend grew from £0.17bn to £0.24bn between 2010 and 2013 (after adjusting for inflation) at an increase of 40% or a year on year increase of 13.3% 56 2010 = £0.15bn (0.95% of total spend) TV: £0.07bn Press: £0.04bn Internet: £0.01bn 2011 = £0.17bn (1.07% of total spend) TV: £0.08bn Press: £0.04bn Internet: £0.03bn 2012 = £0.21bn (1.27% of total spend) TV: £0.12bn Press: £0.05bn Internet: £0.03bn 2013 = £0.24bn (1.36% of total spend) TV: £0.14bn Press: £0.05bn Internet: £0.02bn According to Regulus Partners, the UK’s gambling industry advertising spend grew from £1.07bn to £1.56bn between 2014 and 2017 (after adjusting for inflation) at an increase of 46% or a year on year increase of 15.3% 57 Prior to 2014, remote operators were not required to have a GB gambling license (discussed in more detail in chapter 9: gambling operators as multinational corporations) 2014 = £1.00bn (5.4% of total spend) 58 Internet: £0.72bn (9.9% of all online advertising spend) Online Marketing: £0.40bn Affiliates: £0.28bn Social Media: £0.04bn TV: £0.16bn (3.2% of all TV advertising spend) Sponsorship: £0.03bn Other Offline: £0.09bn 2017 = £1.56bn (7.0% of total spend) 59 Internet: £1.20bn (10.4% of all online advertising spend) Online Marketing: £0.75bn Affiliates: £0.30bn (54.3% of all affiliate advertising spend) 60 Social Media: £0.15bn (5.9% of all social media spend) TV: £0.23bn (4.6% of all TV advertising spend) Sponsorship: £0.06bn Other Offline: £0.07bn Gambling advertising exposure In young people 11-24 year olds in the past month 61 85% reported seeing gambling advertising on TV (including national lottery adverts) 70% noticed gambling adverts in betting shops on the high street, window displays as well as promotions on shop floors and near tills 66% reported seeing gambling promotions on their social media channels 11-16 year olds exposed at all in the past year (exposed at least once a week) 46 70% were exposed to gambling advertising or sponsorship at all in the past year 59% (33%) were exposed to ads on TV 52% (24%) were exposed to ads linked to sports events 50% (24%) were exposed to social media websites 45% (20%) were exposed to other websites (excluding social media) 43% (21%) were exposed to sponsorships on TV or radio 40% (18%) were exposed to sponsorships in sports venues 37% (13%) were exposed to ads on posters/billboards 31% (11%) were exposed to ads in newspapers 12% follow gambling companies on social media platforms like Facebook, YouTube and Instagram 11% had ever received direct marketing from gambling companies about gambling Mails: 4% Messages via Youtube: 3% Texts: 3% Messages via Instagram: 3% Messages on Facebook: 2% Messages via Snapchat: 2% Messages via Twitter: 2% Messages on another social media website: 1% In adults (16+ year olds) exposed at all in the past year (exposed at least once a week) 87% of adults (16+) has seen or heard gambling advertisements or sponsorships in the past year 23 79% (50%) were exposed to ads on TV 72% (45%) were exposed to gambling sponsorships on TV or radio 65% (33%) were exposed to gambling sponsorships on sports merchandise 64% (33%) were exposed to gambling sponsorships in sports venue 63% (31%) were exposed to gambling advertisements online (non-social media sites) 62% (23%) were exposed to gambling advertisements on posters/billboards 61% 27%) were exposed to gambling associations with sporting competitions 58% (31%) were exposed to gambling advertisements on social media 51% (23%) were exposed to gambling advertisements in newspapers 45% (18%) were exposed to gambling advertisements on the radio Online affiliates ODDSbible, an emerging affiliate brand that is part of the LADbible Group, boasts over 1m followers in under 1 year of operation, with 79% of these followers being between 18 and 34 years old and 96% being male 62 Significance of targeting and data analytics 63 A case-study of Sky Bet and companies used by Sky Bet and an individual with Gambling Disorder (Flutter Entertainment) What data? TransUnion: a large credit scoring agency that owns CallCredit, Signal, and Iovation CallCredit 34 page breakdown of financial history including information on: bank accounts, loan defaults, debts, mortgages and monthly payments Iovation A spreadsheet containing 19, 000 fields of data including device identification numbers network information about Signal A document containing personal characteristics including: history of playing slots favourite sports to bet on Interpretation of data by Sky Bet “win back” customer worth about $1, 500 if he started gambling again customer would be receptive to gambling promotions that featured Las Vegas Actions by Sky Bet sent emails to customer promoting a chance to win more than $40,000 by playing slot Effects of gambling advertising Spent money on gambling after seeing a gambling ad or marketing when they were otherwise not planning to 11-16 year olds: 5% (1 in 20) 46 16+ year olds who gamble online: 44% (1 in 2) 23 By age 18-24: 61% 25-34: 56% 35-44: 49% 45-54: 45% 55-64: 31% 65+: 26% By type Free bets and bonuses: 29% TV: 20% Online: 16% Social Media: 16% Newspaper: 11% Billboards: 9% What the industry said? William Hill PLC Annual Report and Accounts 2015 64 "[Gambling has] increased over time, with the National Lottery and TV advertising making gambling more socially acceptable as a leisure activity while mobile devices are making the product more accessible" William Hill recognises the role of advertising over the long-term in normalising gambling and the growing role of mobile devices in increasing accessibility of gambling products. Stephen van Rooyen, CEO of Sky in the UK and Ireland 65 "Yet again, the gambling industry are ignoring the fact they spend five times more on online marketing than they do on TV," van Rooyen said. "By cutting TV ads, they'll simply spend more online, bombarding people's smartphones, tablets and social media feeds with even more gambling ads." Van Rooyen recognises that the industry is keen to avoid meaningful change with online advertising as this is the most effective form of advertising. GVC Holdings PLC Annual Report 2019 66 “The Group also unilaterally ended all UK football shirt sponsorship and perimeter board advertising and has encouraged others in the industry to follow suit.” GVC Holdings recognises an issue with football sponsorships and takes steps to address it, leaving space for other operators to take their place. Betting and Gaming Council 16 "The fact that only companies licensed by the Gambling Commission may advertise in the UK provides an important means for customers to identify legal from illegal operators. It is also provides a means for companies to inform gambling consumers about the products that they enjoy." Like the Tobacco Industry in the past, the Betting and Gaming Council publicly denies or omits the role of advertising in increasing gambling-harm. In this statement, the BGC paraphrases Philip Morris, who in 1987 said that advertising ‘may influence the choice of one brand over another’. 67 Philip Bowcock CEO of William Hill, Annual Report 2018 68 "This issue is one I have been speaking about for some time. I was on the record in 2016 saying I had concerns about the level of gambling advertising, for example, at 4 pm on a Sunday afternoon. The tone of the adverts, the number of them and the potential impact on young people have all been raised as concerns." Unusually for the industry, Bowcock recognises issues with advertising including the tone of the content, the volume, and the potential for impact on young people. Philip Bowcock CEO of William Hill, Annual Report 2018 68 "Most of our advertising is during live sport and it's then that we find young people are most likely to see gambling advertisements. The average under-18 audience of a Premier League match on Sky Sports is 96,000. Major events like the World Cup attract hundreds of thousands more young viewers. That is far too many young people seeing a product that isn’t appropriate for them." Hypocritically, Bowcock highlights an issue with advertising during live sports, while William Hill is the Scottish Cup's official sponsors. Moreover, William Hill also sponsored England and the FA Cup in 2014, through the FIFA World Cup in 2014, and secured the boxer Anthony Joshua as a brand ambassador in 2018. Bet365 69 "The business said it spent more in marketing as it tried to entice betters with offers linked to the 2018 World Cup, which was part of this period." Bet365 look to benefit from the exposure of events like the World Cup. Mr Green Annual Report 2017 70 "Digital communication gives us useful data for us to analyse which messages and channels are effective. In this way, we are constantly expanding our knowledge about what is relevant to the customer." Mr Green, a subsidiary of William Hill, recognise that digital targeted advertising can benefit from data analytics. William Hill PLC Annual Report and Accounts 2015 64 "Historically, affiliates drove a lot of traffic to our sites. Now, as we have increasingly focused on our core, regulated markets, TV advertising, search engine optimisation and PPC [pay-per-click] account are much more important. These channels accounted for [circa] 73% of our marketing spend and all drive a lower cost per acquisition." William Hill recognises the increasingly important role of digital advertising in lowering costs and increasing ad effectiveness to shareholders. Ladbrokes PLC Annual Report 2015 71 "We have helped to run a high impact TV and advertising campaign to educate people about the risks of gambling and how to stay in control. We are fully aligned with the GB Gambling Commission's objectives to ensure that gambling is crime free, fair and open and children and vulnerable people are protected and indeed commit to these objectives across the whole of our business wherever we operate" Ladbrokes reports their role in educating people about gambling-risks and their commitment to being fully aligned with the Gambling Commission’s objectives. Despite this commitment, Ladbrokes failed multiple customers between November 2014 and October 2017 and was fined £5.9m in 2019. Michael Dugher, CEO of Betting Gaming Council 72 “We welcome the Committee’s understanding of the role of advertising and the lack of real evidence of any link between gambling advertising and problem gambling.” Like the tobacco industry in the past, Dugher’s statement reflects the idea that advertising does not affect consumption. Moreover, Dugher fails to recognise evidence from the Gambling Commission that reflects approximately 1 in 20 11-16 years old go on to gamble when they were not otherwise planning to because of gambling advertising. Stewart Kenny - Founder of Paddy Power "That is dangerous, because it is promoted by well-known people, it's a constant barrage of advertising they see it before, during and after the match… It's become normal for children to think gambling and soccer are the same thing." Stewart Kenny, the Paddy Power founder who resigned in 2016 over what he saw as the failure to tackle problem gambling, says advertising is "normalising" gambling for children, and that it has become "nearly part of the game" when watching football. References 16. UK Parliament – Betting and Gaming Council. Betting and Gaming Council – Written evidence (GAM0068). 2019. Available from: https://committees.parliament.uk/writtenevidence/154/html/ [Accessed: 29th March 2021] 23. Barnfield-Tubb J, Francis C. Gambling participation in 2019: behaviour, awareness and attitudes. 2020. Available from: https://www.gamblingcommission.gov.uk/PDF/survey-data/Gambling-participation-in-2019-behaviour-awareness-and-attitudes.pdf [Accessed: 29th March 2020] 46. The Gambling Commission. Young People and Gambling Survey 2019. The Gambling Commission. 2019. 56. Community of Advertising Practice. CAP and BCAP Gambling Review: An assessment of the regulatory implications of new and emerging evidence for the UK Advertising Codes. Community of Advertising Practice. 57. REGULUS PARTNERS. Industry Advertising spend 2014-2017. Available from: https://www.begambleaware.org/media/1853/2018-11-24-rp-ga-gb-marketing-spend-infographic-final.pdf [Accessed: 28th February 2021] 58. IAB UK. UK advertising spend passes £20bn as growth hits five-year high. Available from: https://www.iabuk.com/press-release/uk-advertising-spend-passes-ps20bn-growth-hits-five-year-high [Accessed: 28th February 2021] 59. IAB UK. Full Year 2017 Digital Adspend Results. IAB UK. 2017. 60. IAB UK. IAB / PwC Affiliate Marketing Study 2017. Available from: https://www.iabuk.com/adspend/iab-pwc-affiliate-marketing-study-2017 [Accessed: 28th February 2021] 61. Ipsos Moir. Terms & Conditions. 2021. Available from: http://www.ipsos-mori.com/terms [Accessed: 31st March 2021] 62. LADbible Group. ODDSbible. Available from: https://ladbiblegroup.com/OurBrands/oddsbible/ [Accessed: 21st March 2021] 63. Satariano A. What Sky Bet, The Gambling App, Knows About You. The New York Times. 24 March 2021. Available from: https://www.nytimes.com/2021/03/24/technology/gambling-apps-tracking-sky-bet.html [Accessed: 28th March 2021] 64. William Hill. THE SCALE TO DELIVER OUTSTANDING CUSTOMER EXPERIENCES. 2015. Available from: http://files.williamhillplc.com/media/3612/williamhill_ar15.pdf [Accessed: 31st March 2021] 65. BBC Sport. Gambling chiefs confirm ‘whistle-to-whistle’ television sport advertising ban. BBC Sport. 13 December 2018. Available from: https://www.bbc.co.uk/sport/46550118 [Accessed: 29th March 2021] 66. GCV Holdings. FOR THE GOOD OF ENTERTAINMENT. 2019. Available from: https://www.annualreports.com/HostedData/AnnualReports/PDF/LSE_GVC_2019.pdf [Accessed 31st March 2021] 67. Bates C, Rowell A. Tobacco Explained: The truth about the tobacco industry …in its own words. World Health Organization. Available from: https://www.who.int/tobacco/media/en/TobaccoExplained.pdf [Accessed: 31st March 2021] 68. William Hill. Towards a digitally led, internationally diverse business. 2018. Available from: https://www.williamhillplc.com/media/12906/williamhill_ar18-01032019.pdf [Accessed 31st March 2021] 69. Andrews J. Bet365 chief exec takes home £58million pay rise as Britain’s top earning boss. Mirror Online. 18 December 2019. Available from: https://www.mirror.co.uk/money/denise-coates-handed-astonishing-320m-21119736 [Accessed: 29th March 2021] 70. MrGreen & Co AB. Annual Report. 2017. Available from: https://mb.cision.com/Main/8953/2473501/806461.pdf [Accessed 31st March 2021] 71. Ladbrokes. BUILDING A BETTER LADBROKES. 2015. Available from: http://ar2015.ladbrokesplc.html.investis.com/media/downloads/pdf/strategic-report-and-divisions/Ladbrokes_2_Strategic_Report_AW_160309.pdf [Accessed 31st March 2021] 72. Betting & Gaming Council. BGC statement on House of Lords Committee Report. Available from: https://bettingandgamingcouncil.com/news/bgc-statement-house-of-lords-committee [Accessed: 29th March 2021]
- Gambling research, education, and treatment
Donations to gambling-harm research, education, and treatment efforts are made voluntarily. RET funding targets are currently based on an arbitrary percentage of net losses, and minimum funding targets have been consistently missed. Some operators have maintained their status as voluntary contributors in reducing and preventing gambling harm by donating as little as £5 across a year. Therefore, unsurprisingly, UK RET funding is also drastically lower than countries, including Canada, New Zealand, and Australia, that hold a public health approach to preventing gambling harm. Chronic underfunding and a lack of independence from the industry have meant that steps to tackle and prevent gambling harm have been woefully limited. Firstly, there is a lack of understanding of the significance of gambling harms on the population's health. Additionally, there is an absence of dedicated studies, education, and treatment efforts to prevent and tackle disproportionate gambling harm in ethnic minority communities. At the time of writing, gambling-harm is also poorly recognised in health and social care, with gambling absent from guidelines and curriculums for health care professionals. Lastly, current safer gambling initiatives place the onus on the customer and are widely criticised as thin-veiled attempts to advertise brands. Summary Investment into gambling-harm research, education, and treatment (RET) is currently made voluntarily. At present, minimum funding targets are not set on need and are based on an arbitrary percentage of net losses. However, due to donations' voluntary nature, the minimum funding targets have been missed for the past two consecutive years. Meanwhile, operators have maintained their status as voluntary contributors to RET efforts by donating as little as £5 across a period of 12 months. RET funding in the UK is significantly lower than in other countries where a public health approach to gambling harm has been enacted. Notably, RET funding shortfalls reflect a disparity between the industry’s purported commitments to reducing gambling harm and their lack of actions in delivering meaningful change. Moreover, some of the more substantially funded RET initiatives have been criticised for industry ties and a lack of independent and critical evaluations evidencing their effectiveness. The UK is relatively far behind in terms of research into gambling-related harms relative to some other countries. Research evaluating the significance of harm to health on the UK population through measurements of disability-adjusted life years, and studies measuring the costs of impact, are desperately needed as part of a public-health approach. Despite being the primary funding source of research, the industry has created an atmosphere of doubt and regularly calls for more research. For over a decade now, research has consistently reflected that individuals from ethnic minority backgrounds are several times more likely to be affected by gambling harm. However, dedicated studies to explore this phenomenon further have been limited and largely absent. Furthermore, treatment statistics reflect that individuals from ethnic minority backgrounds are far less likely to receive specialist help and support. Similarly, despite significant evidence of the effect of gambling-harm on health, gambling is yet to feature in medical education curriculums for medical students, speciality curriculums for Psychiatry and General Practice, or NICE guidelines for health care practitioners. Instead, gambling-harm specialist services reach a fraction of the harmed population, which is relatively far fewer than the results achieved by substance use treatment services. Gambling education was recently introduced into the PSHE statutory guidance; however, the framework does not apply to independent schools and is only statutory for years 10 and 11. Additionally, gambling features as one of the learning objectives in "internet safety and harms" contrastingly, "drugs, alcohol, and tobacco" are covered as a separate topic with their distinct learning objectives. Safer gambling initiatives and awareness campaigns organised or funded by the industry place the onus for safe gambling on the consumer. Such campaigns are in stark contrast to the evidence, which reflects a significant genetic component to addiction. Thus, responsible gambling messages have been widely criticised as being thinly veiled advertisements. What is known? Research, Education, and Treatment spending and investment Research, Education, and Treatment (RET) spending in Great Britain is comparable to that of some states in the US, and is relatively a fraction of what is spent in Canada, Australia, and New Zealand GambleAware (the charity responsible for managing and distributing RET efforts and funding in Great Britain) asks all those who profit from the gambling industry in Great Britain to donate a minimum of 0.1% of their annual Gross Gambling Yield (GGY) directly to GambleAware 2017 - 2018: 0.07% (£9.5m/£14.4bn) 73 2018 - 2019: 0.07% (£9.6m/£14.3bn) 74 2019 - 2020: 0.07% (£10.1m/£14.2bn) 75 A review by the Gambling Commission in 2018, which drew on input from GambleAware and the Advisory Board for Safer Gambling (RSGB), reported that hypothetical RET scenarios could cost between £21.5m to £67.0m 76 The Gambling Commission compared RET spending in Great Britain with other countries in 2018 76 Specialist treatment services Source of referrals into treatment services Gambling 77 Self, family, and friends: 92% Health services and social care: 3% Criminal justice: 1% Substance misuse services: 0% Other: 3% Alcohol only 78 Self, family, and friends: 66% Health services and social care: 22% Criminal justice: 6% Substance misuse services: 3% Other: 4% Non-opiate and alcohol 78 Self, family, and friends: 64% Health services and social care: 17% Criminal justice: 10% Substance misuse services: 3% Other: 6% Non-opiate only 78 Self, family, and friends: 66% Health services and social care: 15% Criminal justice: 10 Substance misuse services: 2% Other: 7% Opiate only 78 Self, family, and friends: 56% Health services and social care: 9% Criminal justice: 25% Substance misuse services: 7% Other: 3% Percentage of populations reached by National Gambling Treatment Services 77 0.02% of individuals who gamble and suffer low-risk harm 0.03% of affected others completed treatment 0.30% of individuals who gamble and suffer moderate-risk harm 1.00% of individuals who gamble and suffer gambling disorder harm in Great Britain completed treatment Disproportionately affected population groups 79 Observed = % of population receiving treatment in 2019/20, Expected = % of population affected by gambling disorder harms from the last British Gambling Prevalence Study) Age 16-24 year olds: Observed: 11% & Expected: 30% 25-34 year olds: Observed: 42% & Expected: 26% Ethnicity White: Observed: 89% & Expected: 66% Asian or Asian British: Observed: 5% & Expected: 19% Black or Black British: Observed: 3% & Expected: 9% Other: Observed: 3% & Expected: 7% Research Research gaps in the literature Population health measures of loss of healthy life have never been conducted in the GB population (discussed in more detail in chapter 1: gambling and health) Prevalence of affected other harms were not measured at all prior to 2019 Great Britain has only had one cost of impact studies, and this has been limited to some of the direct costs to the government. Cost of impact studies for gambling disorder gambling in Sweden and Czech Republic have reported that costs are approximately twice the amount of tax revenue generated 80, 81 The last gold-standard prevalence study was conducted in 2010 The only dedicated quantitative study of gambling-harm in ethnic minority communities was published in 2020 using secondary data following a consistent picture of disproportionate harms in ethnic minority communities across prevalence studies since 2007 82, 83 Out of 116 registered clinical studies, only one is in the UK 84 Funding gaps The Adult Psychiatry Morbidity Survey (APMS) 2014 omitted gambling despite finding a significant relationship between gambling and suicidal harm in 2007 Gambling Commission spending on prevalence studies research 86–94 2009/10: < £446,000 2010/11: < £368,000 2011/12: £192,000 2012/13: £51,000 2013/14: £169,000 2014/15: £275,000 2015/16: £652,389 2016/17: £651,634 2017/18: £778,357 2018/19: £795,143 Issues with education PSHE Curriculum (updated September 2020 to include gambling) 94 Internet safety and harms the similarities and differences between the online world and the physical world, including: the impact of unhealthy or obsessive comparison with others online (including through setting unrealistic expectations for body image), how people may curate a specific image of their life online, over-reliance on online relationships including social media, the risks related to online gambling including the accumulation of debt, how advertising and information is targeted at them and how to be a discerning consumer of information online. how to identify harmful behaviours online (including bullying, abuse or harassment) and how to report, or find support, if they have been affected by those behaviours. Drugs, alcohol and tobacco the facts about legal and illegal drugs and their associated risks, including the link between drug use, and the associated risks, including the link to serious mental health conditions. the law relating to the supply and possession of illegal substances. the physical and psychological risks associated with alcohol consumption and what constitutes low risk alcohol consumption in adulthood. the physical and psychological consequences of addiction, including alcohol dependency. awareness of the dangers of drugs which are prescribed but still present serious health risks. the facts about the harms from smoking tobacco (particularly the link to lung cancer), the benefits of quitting and how to access support to do so. What the industry said? Betting and Gaming Council 36 “Importantly, the largest BGC members are committing an additional £100 million to research, education and treatment (RET) over the next four years.” The BGC announced a voluntary commitment to increase RET funding following calls for a statutory levy that would mean independence between the industry and prevention and treatment efforts. At the end of the four years, funding will increase ten-fold, demonstrated the industry’s ability to fund RET despite it chronically underfunding it for several years. This voluntary commitment also signals the industry’s acceptance that existing RET measures are insufficient. Initially, the funds were to be allocated to Action Against Gambling Harms. However, with little notice, the BGC revoked this and instead changed the recipient to GambleAware. Researchers have stressed their concerns to decision-makers and highlighted the need for a levy that funds prevention and treatment while being free from real or perceived industry influence. The researchers also reflected that the unilateral decision-making in funding allocations is one way of the industry exerting influence. 95 Peter Jackson, CEO of Flutter Entertainment PLC 96 “GambleAware has a long track record in commissioning treatment services and working with providers for the benefit of problem gamblers. Through the provision of this unprecedented level of financial support, we aim to achieve a step-change in the treatment and counselling available to those experiencing gambling-related harm. Through the provision of this unprecedented level of financial support, we aim to achieve a step-change in the treatment and counselling available to those experiencing gambling-related harm.” Jackson focusses on the need for a step-change in treatment services, implying that most of the incoming funds for RET will be spend on treatment. Worryingly, public health monitoring of gambling-harm is still limited to counting the numbers of individuals affected in the past-year. To allow gambling-harm to be considered in the context of other issues and for efforts to tackle gambling-harm to be monitored appropriately, there is a desperate need for research that evaluates the significance of harms instead of simply the numbers affected. Nigel Huddleston, Minister for Sport, Tourism and Heritage 97 “We have been clear that the gambling industry has a responsibility to protect people from gambling-related harm and support those who have been affected. I welcome the Betting and Gaming Council now outlining how it will deliver on leading operators’ pledges to bolster research, education and treatment. We will monitor closely the progress of these new measures and continue to encourage the wider industry to step up” Huddleston reports on the industry's need to keep up with the Gambling Commission’s licensing objectives and reflects trust that the industry will now tackle and prevent gambling-harm voluntarily. Betting and Gaming Council 16 “The vast majority of gambling activity in Great Britain is carried out in a fair and transparent fashion”…”most people who gamble in this country do so with companies licensed by the regulator.” The BGC take the minority view as only about a third of the population agree that gambling is carried out in a fair and transparent fashion. Ian Proctor, Chairman of Flutter UK & Ireland 98 “We believe the way forward is taking a risk-based approach founded on evidence. This means not considering affordability in isolation, but in the context of many other data points including frequency of bets and deposits, personal circumstances, time, products used and, crucially, changes in usual patterns of behaviour for each customer. When all these inputs are considered together, we can take an impactful approach to player protection.” Proctor identifies the need to be evidence-led and for affordability to be judged alongside other data points, implying that such basic measures are not utilised already in player protection. Responsible Gambling Fund 99 “RGF said the funding partnership with the Great Foundation was unworkable thanks to increasing interference from gambling industry stakeholders pressuring the Great Foundation as to how to spend the money. A spokesman for the RGF said the gambling industry “has much stronger interest in funding treatment than it does in funding research”. The RGF reported that the industry had a substantial interest to interfere and disrupt RET efforts. Martin Lycka, Senior VP of US Regulatory Affairs & Responsible Gambling at Entain Group 100 “Our approach, Advanced Responsibility and Care (ARC), will combine the best academic research and life experience with industry-leading data science and AI to create what we believe is the first pro and personalised approach to player protection. And we'll be trialling this in the UK this summer.” Lycka associates the ARC with academic research and other technologies to suggest that emerging player protections efforts will be more meaningful. References 73. GambleAware. Annual Review 2016/17. 2017. Available from: https://about.gambleaware.org/media/1628/gambleaware-annual-review-2016-17.pdf [Accessed: 9th November 2019] 74. BeGambleAware. 2018/19 supporters. Available from: https://www.begambleaware.org/201819-supporters [Accessed: 30th March 2021] 75. BeGambleAware. 2019/20 supporters. Available from: https://www.begambleaware.org/201920-supporters [Accessed: 30th March 2021] 76. Gambling Commission. Reviewing the research, education and treatment (RET) arrangements. Gambling Commission; 2018. Available from: https://www.gamblingcommission.gov.uk/PDF/Review-of-RET-arrangements-February-2018.pdf [Accessed 31st March 2021] 77. GambleAware. Annual Statistics from the National Gambling Treatment Service (Great Britain). GambleAware. 2020. 78. Public Health England. Adult substance misuse treatment statistics 2019 to 2020: report. GOV.UK; 2020. 79. Gambling Harm UK. Treatment Statistics from 2018-2020 in context. Available from: https://www.gamblingharm.com/post/treatment-statistics-in-context [Accessed: 31st March 2021] 80. Hofmarcher T, Romild U, Spångberg J, Persson U, Håkansson A. The societal costs of problem gambling in Sweden. BMC Public Health. 2020;20(1): 1921. Available from: doi:10.1186/s12889-020-10008-9 81. Winkler P, Bejdová M, Csémy L, Weissová A. Social Costs of Gambling in the Czech Republic 2012. Journal of Gambling Studies. 2017;33(4): 1293–1310. Available from: doi:10.1007/s10899-016-9660-4 82. Gunstone B, Gosschalk K. Gambling among adults from Black, Asian and Minority Ethnic communities: a secondary data analysis of the Gambling Treatment and Support study. GambleAware; 2019. 83. Gambling Harm UK. Gambling in BAME & Risk Factors. Available from: https://www.gamblingharm.com/post/gambling-in-bame-and-other-risk-factors [Accessed: 31st March 2021] 84. ClinicalTrials.gov. Search of: Gambling - List Results - ClinicalTrials.gov. Available from: https://clinicaltrials.gov/ct2/results?recrs=&cond=Gambling&term=&cntry=&state=&city=&dist= [Accessed: 31st March 2021] 85. Gambling Commission. Annual report and accounts 2009/10: keeping gambling fair and safe for all. 2010. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/247697/0199.pdf [Accessed: 25th March 2020] 86. Gambling Commission. Annual report and accounts 2010/11: keeping gambling fair and safe for all. 2011. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/247408/1115.pdf [Accessed: 25th March 2020] 87. Gambling Commission. Annual report and accounts 2011/12: keeping gambling fair and safe for all. 2012. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/247021/0253.pdf [Accessed: 25th March 2020] 88. Gambling Commission. Annual report and accounts 2012/13: keeping gambling fair and safe for all. 2013. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/246662/0344.pdf [Accessed: 25th March 2020] 89. Gambling Commission. Annual report and accounts 2013/14: keeping gambling fair and safe for all. 2014. Available from: https://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2013-14.pdf [Accessed: 25th March 2020] 90. Gambling Commission. Annual report and accounts 2014/15: keeping gambling fair and safe for all. 2015. Available from: http://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2014-15.pdf [Accessed: 25th March 2020] 91. Gambling Commission. Annual report and accounts 2015/16: keeping gambling fair and safe for all. 2016. Available from: http://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2015-16.pdf [Accessed: 25th March 2020] 92. Gambling Commission. Annual report and accounts 2016/17: keeping gambling fair and safe for all. 2017. Available from: https://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2016-2017.pdf [Accessed: 25th March 2020] 93. Gambling Commission. Annual report and accounts 2017/18: keeping gambling fair and safe for all. 2018. Available from: https://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2017-2018.pdf [Accessed: 25th March 2020] 94. Department for Education. Relationships Education, Relationships and Sex Education and Health Education. Department for Education. 2019. 95. Wardle H, Banks J, Bebbington P, Blank L, Bowden Jones Obe H, Bramley S, et al. Open letter from UK based academic scientists to the secretaries of state for digital, culture, media and sport and for health and social care regarding the need for independent funding for the prevention and treatment of gambling harms. [Online] The BMJ. BMJ Publishing Group; 2020. Available from: doi:10.1136/bmj.m2613 96. Betting & Gaming Council. Support for the Treatment of Gambling Harm. Available from: https://bettingandgamingcouncil.com/commitments/safer-gambling-increasing-support-for-the-treatment-of-gambling-harm [Accessed: 29th March 2021] 97. Betting & Gaming Council. COMMITMENT 2: Increasing support for the treatment of gambling harm. Available from: https://bettingandgamingcouncil.com/safer-gambling-initiatives/research-education-treatment [Accessed: 29th March 2021] 98. Proctor I. Flutter: Gambling industry is listening, and responding, to addiction concerns. CityAM. 12 February 2021. Available from: https://www.cityam.com/flutter-gambling-industry-is-listening-and-responding-to-addiction-concerns/ [Accessed: 29th March 2021] 99. Mason T. Gambling charities solve dispute by merging. Civil Society News. 15 December 2011. Available from: https://www.civilsociety.co.uk/news/gambling-charities-solve-dispute-by-merging.html [Accessed: 29th March 2021] 100. Lycka M. Martin Lycka: The age of responsible gambling. SBC Americas. 11 March 2021. Available from: https://sbcamericas.com/2021/03/11/martin-lycka-the-age-of-responsible-gambling/ [Accessed: 30th March 2021]
- Design of gambling products
Online gambling has surged over the past decade. With reduced costs and increased accessibility, online gambling is highly profitable to the industry and is unsettlingly addictive for players. Most online games facilitate cognitive biases through the illusion of control and often contain characteristics that particularly appeal to younger customers. The industry has repeatedly resisted reform and suggested that product design has little influence on harm but somewhat down to the individual, despite clear evidence suggesting otherwise. Summary The Gambling Industry has grown over the past decade, primarily due to the upsurge of online gambling. Online gambling products are subject to: reduced costs, increased accessibility, improved advertisement effectiveness, increased vulnerability to cognitive biases, and increased potential for neurostimulation. Electronic gaming machines and online casino products have been repeatedly associated with unsettlingly high gambling addiction levels among players. These products have structural characteristics that affect human decision-making and behaviours, and therefore addiction potential, such as: free bet offers, high event frequencies, random ratio reinforcement schedules, near misses, losses appearing as wins, multiline betting, and exaggerated audible and visual reinforcements 101 In the UK, fixed-odd betting terminals (FOBTs), a type of electronic gaming machine, quickly proliferated in clusters before drawing attention and campaigns for change due to their addictive potential. Recently, the maximum individual stake allowed for FOBTs was reduced from £100 to £2. However, this change took several years to be enacted with resistance from the government, primarily due to the sector's concerns regarding job losses. The estimated job losses resulting from reducing the maximum stake were greatly overstated, as, before the regulation change, physical betting shops were already in decline due to the ongoing increase in online operations. Though similar in style and addictiveness to FOBT's, operators and legislation have not attempted to alter the wagering limits of online fixed-odds betting. Early evidence on live in-play sport-betting and cash-out features are also hypothesised to contain structural characteristics that facilitate cognitive biases through illusions of control to consumers. Gambling products are also designed to maximise appeal among possible customers. Notably, a significant number of online slot games are expected to appeal to younger customers who have some familiarity with particular names, characters, animations, or other graphics. Furthermore, these products often contain animated characters, which are expected to disproportionately attract younger customers and propagate cognitive biases around the level of risk involved. The same issues are also expected to be suffered in fantasy-team styled products, which essentially involve adapting popular sport fan games into gambling games. One example of this, the Football Index, which contains structural characteristics that lead towards cognitive biases and appeal to young people, worryingly has been allowed to operate with a license under a fraudulent business model. Newly introduced changes to online slot games include rules on the speed of play and near misses; and are due to be implemented in November 2021. Characteristically and despite clear evidence, the industry has previously denied any association of gambling-harm and the type of gambling product. Characteristically, the industry has instead sought to deflect blame on to the individuals who suffer harm until changes are mandated by regulation. What is known? Gross gambling yield of remote betting, bingo, and casino 102 2013: £0.9bn 2014: £1.1bn 2015: £2.2bn (remote operators required to register for a GB license) 2016: £4.2bn 2017: £4.8bn 2018: £5.3bn 2019: £5.7bn Football Index (Great Britain Gambling Commission license: 09/09/15 – 11/03/21) 103 09th September 2015: License approved 2nd October 2015: Launched January 2018: 100k users July 2018: Shirt sponsor for Bristol Rovers announced 104 June 2019: Shirt sponsor for Nottingham Forest announced 105 Late 2019: 500k users January 2020: Gambling Commission warned “an exceptionally dangerous pyramid scheme under the guise of a ‘football stock market’” 106 August 2020: Shirt sponsor for QPR 107 11th March 2021: Administration and license suspended Appeal to children A non-exhaustive list of examples of gambling products that utilise cartoon animals, fairy tales, colourful exaggerated graphics, and names, that may appeal particularly to children and young people Adventure Trail Age of the Gods Age of Dragons Aquaman Batman The Riddle Riches Berry Berry Bonanza Captain’s Treasure Djinn of Storms Dragon Champions Dragon Spark Dynamite Digger Fluffy Favourites Halloween Fortune Hansel and Gretel Jack and the Beanstalk Justice League Kings Court Lara Croft Temples and Tombs Loco the Monkey Mad Max Fury Road Monopoly Norse Book of Dwarves Norse Gods and Giants Piggy Payout Pirate Princess Prince of Olympus Rainbow Rewa Rainbow Riches Reacttoonz 2 Red Riding Hood Rick and Morty Sahara Riches Cash Collect Sinbad Spartacus Super Colossal Reel Terminator The Goonies The Mask of Zorro The Nutcracker Transformers Voyage of Adventure War of Gods Proportion of individuals who gambled in the past year with gambling disorder per type of activity Great Britain 19,21,108,109 Table continued... Sweden 110 Timeline of Fixed Odds Betting Terminals 111 2001 - Fixed Odds Betting Terminals (FOBTs) introduced 2005 - approximately 20,000 FOBTs 112 2007 - approximately 30,000 FOBTs 112 2016 - The APPG on FOBTs recommends a reduction to £2 spin 2017 - Treasury ignores Gambling Commission advice that FOBTs are high-risk 2018 - DCMS recommends £2 maximum 2019 – 32,810 FOBTs 102 2019 - the maximum bet on FOBTs was changed from £100 to £2 What the industry said? Neil Goulden, Chair of the Association of British Bookmakers 113 "There is very clear evidence that problem gambling is about the individual and not any specific gambling product or products. “Altering stakes and prizes is not an effective form of player protection, nor does it balance the constant regulatory dilemma of allowing the vast majority of our eight million customers to enjoy their leisure time as they see fit, whilst protecting the small minority who do develop problems with their gambling. “At the same time, the ABB recognises the need for effective consumer protection and we will be introducing a ‘Code of Responsible Gambling in LBOs’, which will build on current best practice and give consumers the self-help tools they need to avoid excessive or irresponsible gambling. “In doing so, the ABB is putting consumer and player protection at the core of responsible gambling in the UK.” Goulden purports evidence that is distinctly against a consistent global evidence base which has repeatedly demonstrated that some gambling products are more addictive and harmful than others. Notably, Goulden shifts the responsibility from the industry who benefits from addiction to the individual who suffers from it. Michael Dugher, Member of Parliament for Barnsley East 114 “More gamblers have problems with scratchcards and slot machines than FOBTs. The review must be widened. And they have to stop beating up on high street betting shops.” While still an MP and three years before taking the CEO role for the industry lobbying group the BGC, Michael Dugher opposed a government crackdown on FOBTs, citing a couple of different reasons. First, Dugher states that individuals with gambling disorder played the national lottery more than FOBTs. Although the national lottery is vastly more popular as a product, this sentence is worryingly misleading as FOBTs have significantly higher addiction rates than the national lottery. Secondly, Dugher said such action would harm jobs in high street betting shops. Both excuses fail to tackle the issue of gambling harm caused by FOBTs. Such statements are designed to derail the conversation by deflecting other issues while providing zero solutions. Betting and Gaming Council 72 “The BGC are already working with the Gambling Commission on new affordability checks and a new code of conduct for game design, including slowing spin speeds on games and removing some in game features.” The BGC in working with the Gambling Commission, admit that they have responsibility and control over harmful gambling. In this statement, the BGC also acknowledges the need for reform in affordability checks and the structural characteristics of products such as game features and speed of play. The Gambling Commission 115 “Proposals around the design of slots games are just the first step in keeping players safe. Slots is an area which has seen technological innovation in terms of product design and we expect operators to continually show an equal, and indeed greater, commitment to innovate in terms of consumer protection. Regulatory intervention needs to keep pace with this and the proposals in this consultation form part of a comprehensive package of work we are taking forward to make online gambling safer” Gambling Commission suggests that efforts on online slot game design are just a first step in keeping players safe. Research since 2010 has reflected that online slot games have among the highest rates of addiction by activity, suggesting a significant delay between evidence and action. Brigid Simmonds, Chair of the Betting and Gaming Council 116 "I am pleased with our members' hard work and continued commitment to delivering substantial progress on the three safer gambling challenges set by the Gambling Commission on high value customers, advertising and game design. The progress reported today including restricting under 25's from qualifying for high value customer accounts; strengthened advertising rules and games with slower speeds and the removal of some functionality comes despite difficult operating circumstances during the COVID-19 crisis. These measures, along with our recently announced 10 pledge action plan for COVID-19 safer gambling and our 22 industry safer gambling commitments will significantly transform and improve the environment for our customers and the wider public. We agree with the Gambling Commission that there is still more work to do and we will rise to the ongoing challenge." Following pressure from campaigners and the Gambling Commission, Simmonds acknowledges significant issues with industry practices surrounding high-value customers, advertising, and game design. Simmonds then vaguely comments on the industry's progress and commitments and again acknowledges the need to transform industry practices. References 19. Wardle H, Moody A, Spence S, Orford J, Volberg R, Jotangia D, et al. British Gambling Prevalence Survey 2010. The Gambling Commission. 2011. 20. Seabury C, Wardle H. Gambling behaviour in England & Scotland Headline findings from the Health Survey for England 2012 and Scottish Health Survey 2012. NatCen. 2014. 21. Wardle H, Sproston K, Orford J, Erens B, Griffiths M, Constantine R, et al. British Gambling Prevalence Survey 2007. NatCen. 2007 72. Betting & Gaming Council. BGC statement on House of Lords Committee Report. Available from: https://bettingandgamingcouncil.com/news/bgc-statement-house-of-lords-committee [Accessed: 29th March 2021] 101. Yücel M, Carter A, Harrigan K, van Holst RJ, Livingstone C. Hooked on gambling: a problem of human or machine design?. The Lancet Psychiatry. 2018;20–21. Available from: doi:10.1016/S2215-0366(17)30467-4 102. Gambling Commission. Industry statistics. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/Statistics-and-research/Statistics/Industry-statistics.aspx [Accessed: 31st March 2020] 103. Gambling Commission. BetIndex Limited - Licence summary. Available from: https://beta.gamblingcommission.gov.uk/public-register/business/detail/43061 [Accessed: 31st March 2021] 104. Streeter J. Football INDEX unveiled as main sponsor of Bristol Rovers FC. SBC News. 23 July 2018. Available from: https://sbcnews.co.uk/marketing/2018/07/23/football-index-unveiled-as-main-sponsor-of-bristol-rovers/ [Accessed: 31st March 2021] 105. Nottingham Forest Football Club. Football Index announced as official shirt partner. Nottingham Forest. 7 June 2019. Available from: https://www.nottinghamforest.co.uk/news/2019/june/Football-Index-announced-as-official-shirt-partner/ [Accessed: 31st March 2021] 106. Wood G. Football Index: Gambling Commission was warned about firm in January 2020. The Guardian. 18 March 2021. Available from: https://www.theguardian.com/football/2021/mar/18/football-index-gambling-commission-warned-january-2020 [Accessed: 31st March 2021] 107. Morrissey P. Football Index confirmed as new shirt sponsors. QPR. 20 August 2020. Available from: https://www.qpr.co.uk/news/club-news/football-index-confirmed-as-new-shirt-sponsors/ [Accessed: 31st March 2021] 108. Sproston K, Erens B, Orford J. Gambling Behaviour in Britain: Results from the British Gambling Prevalence Survey. 2000. Available from: https://www.researchgate.net/publication/264875487_Gambling_Behaviour_in_Britain_Results_from_the_British_Gambling_Prevalence_Survey [Accessed 31st March 2021] 109. Conolly A, Davies B, Fuller E, Heinze N, Wardle H. Gambling behaviour in Great Britain in 2016: Evidence from England, Scotland and Wales. NatCen; 2018. 110. Folkhälsomyndigheten. Swelogs 2015 and 2018. Available from: https://www.folkhalsomyndigheten.se/livsvillkor-levnadsvanor/andts/vad-vi-gor-inom-andts/spel/swelogs-befolkningsstudie/swelogs-prevalensstudie-2015/ [Accessed 31st March 2021] 111. Woodhouse J. r Fairer Gambling. Message for our supporters. Available from: https://fairergambling.org/ [Accessed 31st March 2021] 12. Woodhouse J. Fixed odds betting terminals. House of Commons Library; 2019. Available from: http://researchbriefings.files.parliament.uk/documents/SN06946/SN06946.pdf [Accessed: 25th March 2021] 113. Association of British Bookmakers. Gaming machines policy ‘must be evidence-based’. Politics Home. 10 April 2013. Available from: https://www.politicshome.com/members/article/gaming-machines-policy-must-be-evidencebased [Accessed: 30th March 2021] 114. Hawkes S. Theresa May blasted for ‘beating up’ on bookies and told to widen gambling review to include scratchcards and National Lottery. The Sun. 28 December 2016. Available from: https://www.thesun.co.uk/news/2491836/theresa-may-blasted-for-beating-up-on-bookies-and-told-widen-gambling-review-to-include-scratchcards-and-national-lottery/ [Accessed: 29th March 2021] 115. Gambling Commission. Online games design. Available from: http://www.gamblingcommission.gov.uk/news-action-and-statistics/Consultations/online-games-design [Accessed: 30th March 2021] 116. Gambling Commission. Gambling Commission and industry collaboration makes progress on safer gambling. Gambling Commission. 01 April 2020. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/news/2020/Gambling-Commission-and-industry-collaboration-makes-progress-on-safer-gambling.aspx [Accessed: 30th March 2021]
- Gambling and the way it is conducted
Public opinion of gambling has deteriorated significantly over the past decade; there are well-grounded concerns regarding industry exploitation of individuals on the addictive spectrum. Estimates suggest that half of the online industry's profits are generated from harmful gambling, where players are more likely to gamble, lose more money, and gamble at unsociable hours. The Gambling Commission has increasingly fined operators for regulatory failings, yet operators continue to profit substantially from failures and harmful gambling. Summary Over the past decade, public opinion of gambling and the way it's conducted in Great Britain has consistently and significantly deteriorated. There are well-grounded concerns of the regulated industry's exploitative nature towards individuals on the addiction spectrum. Ultimately, there is no requirement for operators to prevent harm in those showing signs of addiction, and evidently, the industry's bottom-line benefits from these high-value customers. There is significant analysis reflecting that individuals on the addiction spectrum: wager larger amounts, lose more money, gamble more frequently, and gamble at less social hours relative to individuals who gamble but do not suffer gambling harm. By utilising this understanding, estimates indicate that more than half of the industry’s profits are derived from players who are on the addiction spectrum. In line with this analysis, the Gambling Commission's evidence using data from nine different operators reflects that significant percentages of deposits are universally derived from a small minority of VIP scheme customers. Over the past few years, the Gambling Commission has increasingly fined operators who are found to have exploited customers or for other failings through regulatory settlements. Moreover, operators have been reported to coerce individuals into settlements that repay victims of thefts related to gambling on the condition of non-disclosure agreements or confidentiality provisions that may, in turn, discourage the Gambling Commission from being informed by incidents of failings. Lastly, there are concerns that gambling-harm disproportionately affects ethnic minority communities and individuals in areas of deprivation, which may be in part due to the agglomeration of betting shops in these areas. What is known? Public opinion of how gambling is conducted Percentage of adults agreeing that gambling is conducted fairly and can be trusted 25 2010: 48% 2011: 49% 2012: 49% 2013: 42% 2014: 41% 2015: 39% 2016: 34% 2017: 33% 2018: 30% 2019: 29% Gambling industry profits from harmful gambling Research of bank data reflects that the top 1% of individuals that gamble surveyed spent 58% of their income on gambling 8 Online gambling VIP Schemes and Deposits comparison (online) 117 Respublica estimates 58.6% of online gambling profits are from individuals who gamble and who suffer significant amounts of harm 118 Individuals suffering low-risk harm: 17.0% Individuals suffering moderate-risk harm: 17.1% Individuals suffering gambling disorder harm: 24.5% Kindred’s self-reported data reflects that approximately 33.6% of the company’s revenue was accrued by individuals with probable gambling disorder in 2020 119 Geography of betting shops Betting shops in Great Britain are overwhelmingly in areas of deprivation by multiple deprivation 19% of betting shops are in the top 10% most deprived postcodes by multiple deprivation 16%, 2nd decile 16%, 3rd decile 13%, 4th decile 10%, 5th decile 8%, 6th decile 6%, 7th decile 5%, 8th decile 4%, 9th decile 2% of betting shops are in the bottom 10% of most deprived postcodes by multiple deprivation (least deprived postcodes) By ethnicity 83 Relative difference between ethnic distribution of populations around betting shops and national averages (2011 census) All betting shops White: -6.7% Mixed: 22.1% Asian: 40.6% Black: 49.8% Other: 56.5% Betting shops in postal districts with 10 or more betting shops White: -27.7% Mixed: 88.6% Asian: 160.5% Black: 231.5% Other: 222.6% Gambling industry fines by UK Gambling Commission 120,121 2015: £1.88M 2016: £2.01M 2017: £10.74M 2018: £27.20M 2019: £15.77M 2020: £33.93M What the industry said? Brigid Simmonds, Chair of the Betting and Gaming Council 122 “But you are right in that if people start asking them for their tax return, as somebody as suggested, people will start walking away - I mean, I wouldn't share my tax return with anybody. We will be driving people to a black market. We will be doing what they've done in Sweden, where the numbers are up to about 40% of people, because they've been too tight. We've got to be balanced. We believe the way forward is taking a risk-based approach founded on evidence. This means not considering affordability in isolation, but in the context of many other data points including frequency of bets and deposits, personal circumstances, time, products used and, crucially, changes in usual patterns of behaviour for each customer. When all these inputs are considered together, we can take an impactful approach to player protection. The vast majority of gambling activity in Great Britain is carried out in a fair and transparent fashion.” Simmonds utilises a strawman argument by failing to recognise that gambling companies already have access to financial data through credit check companies. Still, instead of using data analytics to protect customers, operators use data analytics for profit. Ian Proctor, Chairman of Flutter UK and Ireland 98 “At Flutter we believe it is important to ask ourselves the big questions and that the Government’s review of the Act represents a chance for real change. Gambling has gone through a technical transformation over the last 15 years, and the rules have not kept pace.” Proctor states that Flutter believes in self-reflection and that the review of the Act represents a chance for real change. Notably, Proctor points out that the need for gambling reform is due to a technical transformation instead of concerns for gambling-harm as a public health issue with evidence that emerged as early as 2007. Proctor also reflects a sentiment that there is a need for rules with this industry, which suggests that the industry cannot self-regulate. Brigid Simmonds, Chair of the Betting and Gaming Council 123 “Just as pubs, in my former incarnation, are important to high streets so are betting shops. Betting shops and their managers really care about their customers, and they want to make sure that they have the right experience but they also stay safe” Simmonds states that betting shops are important to the high-street and compares them to pubs. The Chair of the BGC also states that betting shops and managers care about their customers and that they want to make sure that they stay safe. Neil Goulden, Chair of the Responsible Gambling Trust and the Association of British Bookmakers 124 [Issue of problem gambling] “dwarfed by problems with drug use, alcohol abuse and obesity” “[Bookmakers] would not have released data or have taken the actions it continues to take in prevention of harm without my personal influence and urging,” [urging] “the industry to take consumer product protection more seriously or face more bad press and a loss of government and consumer confidence”. Goulden mendaciously diminishes the significance of gambling-harm relative to other public health issues such as drug use, alcohol abuse, and obesity. Scientific evidence and commentary from the World Health Organisation, directly contrasts with these statements. Goulden states that his ties and influence with the industry, combined with his role within safer gambling efforts have caused the industry to be more open and prevent harm. Goulden reflects that he could push the industry to take matters more seriously with the warning of public relation repercussions and a loss of government and consumer confidence. Through this, it is clear that the action against gambling-harm by the industry would still be motivated by profits and factors relating to profit-making, instead of a desire to be principled in not causing harm. Ulrik Bengtsson, CEO of William Hill 125 “Claiming the black market doesn’t exist is like saying the Earth is flat” “I do realise we have a huge obligation to make sure our customers play within their means. We should do a reasonable amount of affordability checks, but it can’t be to the extent where it is so intrusive that we force these people out. So it’s all about finding the right balance to keep the customers in the UK ecosystem; to keep them safe, to secure the tax base and to secure the industry” Bengtsson implies that individuals with lived experience and other campaigners for reform deny the existence of the black market. Spokesperson for Ladbrokes 126 “we recognise that (name removed) has problems with his gambling and have therefore shared the details of our multi-operator self-exclusion scheme with him” Ladbrokes reflects that their process for preventing gambling-harm in individuals with a loss of control is to send these individuals a message referring them to self-exclusion schemes. References 8. Muggleton N, Parpart P, Newall P, Leake D, Gathergood J, Stewart N. The association between gambling and financial, social and health outcomes in big financial data. Nature Human Behaviour. 2021;5(3): 319–326. Available from: doi:10.1038/s41562-020-01045-w [Accessed: 22nd March 2021] 25. Gunstone B, Gosschalk K, Joyner O, Diaconu A, Sheikh M. The impact of the COVID-19 lockdown on gambling behaviour, harms and demand for treatment and support. Gambling Research Exchange Ontario. 2020. 83. Gambling Harm UK. Gambling in BAME & Risk Factors. Available from: https://www.gamblingharm.com/post/gambling-in-bame-and-other-risk-factors [Accessed: 31st March 2021] 98. Proctor I. Flutter: Gambling industry is listening, and responding, to addiction concerns. CityAM. 12 February 2021. Available from: https://www.cityam.com/flutter-gambling-industry-is-listening-and-responding-to-addiction-concerns/ [Accessed: 29th March 2021] 117. Gambling Commission. What is a VIP. [Presentation] Gambling Commission. 118. UK Parliament. Chapter 5: Gambling-related harm. Available from: https://publications.parliament.uk/pa/ld5801/ldselect/ldgamb/79/7908.htm [Accessed: 20th September 2020] 119. Kindred Group plc. Our journey towards zero. Available from: https://www.kindredgroup.com/sustainability/our-journey-towards-zero/ [Accessed: 27th March 2021] 120. Gambling Business Group. FOI Request: Info Reg Settlements 070220. Available from: https://gamblingbusinessgroup.co.uk/wp-content/uploads/2020/03/FOI-Request-Info-Reg-Settlements-070220.pdf [Accessed: 27th March 2021] 121. Gambling Industry Fines. Gambling Industry Fines. Available from: https://gamblingindustryfines.com/ [Accessed: 27th March 2021] 122. Racing TV. ‘Racing must stand alongside betting industry’ in Gambling Act review: Simmonds. Racing TV. 13 December 2020. Available from: https://www.racingtv.com/news/racing-must-stand-alongside-betting-industry-in-gambling-act-review-simmonds [Accessed: 29th March 2021] 123. Burley Hannah. ‘Sponsorship in sport should be allowed’ - The Big Interview with Brigid Simmonds, chair of the Betting and Gaming Council. The Scotsman. 10 February 2020. Available from: https://www.scotsman.com/business/sponsorship-sport-should-be-allowed-big-interview-brigid-simmonds-chair-betting-and-gaming-council-1555471 [Accessed: 30th March 2021] 124. Ramesh R. Gambling charity chair lobbied for bookmakers, documents show. The Guardian. 6 January 2016. Available from: https://www.theguardian.com/society/2016/jan/06/documents-reveal-gambling-charity-chair-conflict-of-interest [Accessed: 30th March 2021] 125. Racing TV. ‘Racing must stand alongside betting industry’ in Gambling Act review: Simmonds. Racing TV. 13 December 2020. Available from: https://www.racingtv.com/news/racing-must-stand-alongside-betting-industry-in-gambling-act-review-simmonds [Accessed: 29th March 2021] 126. UK Rehab. Gambling Addict Says Betting Companies Are Not Doing Enough to Help. Available from: https://www.uk-rehab.com/behavioural-addictions/problem-gambling/gambling-addict-says-betting-companies-are-not-doing-enough-to-help/ [Accessed: 30th March 2021]
- Gambling and voluntary bans
The gambling industry’s efforts to promote safer gambling are inadequate and often a thin-veiled effort to drive public relations. Self-exclusion is the most effective tool for individuals to regain control of their gambling. Yet, the process to self-exclude is unnecessarily complicated, which is further compounded by issues with awareness and accessibility of self-exclusion. Moreover, the Betting and Gaming Council’s voluntary whistle-to-whistle ban has been unsuccessful despite being regularly proclaimed otherwise; not all operators volunteered, and the ban did not apply to sports sponsorships or online advertising. Without a comprehensive and mandatory ban, similar to tobacco advertising, gambling advertising will continue to shift to less regulated and less scrutinised mediums. Summary Over the past decade, the gambling industry has increasingly come under fire for quasi-safer gambling efforts, which appear to be driven by public relation efforts instead of a public-health approach. Some of the critical issues surrounding gambling-harm prevention include the design and characteristics of products, how gambling is conducted, and the volume and content of advertising. The Betting and Gaming Council (BGC) have widely proclaimed the success of their voluntary whistle-to-whistle (W2W) ban in reducing exposure of gambling to children. The W2W ban meant that operators who are part of the BGC group voluntarily opted out of displaying gambling ads in TV commercial breaks during and immediately surrounding sports fixtures except for horse-racing. However, the W2W ban did not apply to all licensed UK operators, nor did it affect sports sponsorships or advertising through other media channels such as online. Moreover, during the COVID-19 pandemic, the BGC responded to gambling advertising concerns by voluntarily committing to remove all TV and radio advertising for six weeks. In this period, ads were replaced with social responsibility messages, advising customers to gamble responsibly, and thus, were widely criticised as thinly veiled adverts. Like tobacco advertising, without a comprehensive and mandatory ban, advertising will simply be displaced to less regulated and less scrutinised marketing areas such as online advertising or sponsorships. The most effective tool that individuals that gamble can utilise to regain control is self-exclusion, whereby individuals can opt-out of gambling. Self-exclusion still faces issues with awareness, accessibility, and in the past, coverage too. Notably, self-exclusion does not affect marketing. Since April 2016, the Gambling Commission has required all non-remote operators in the land-based arcade, betting, bingo, and casino sectors to participate in multi-operator self-exclusion schemes. Before multi-operator schemes were mandated for as a licensing requirement, self-exclusion was limited to individual operators and could easily be circumvented. All self-exclusion schemes, except for betting shops and online gambling, require an individual to enter a betting venue or contact the gambling industry, thus significantly reducing accessibility for those suffering from a compulsion to gamble. It should also be noted that the scheme for online gambling only became mandatory in March 2020, despite initially being announced in June 2017 and released for use in 2018. What is known? Whistle to whistle ban What is covered TV commercial ads 5 minutes before, during and 5 minutes after sports broadcasts before 9pm 127 TV = 15% of all industry marketing spend; 80% is spent online 57 What is excluded sponsorships online casino’s, lotteries, bingo, poker, and scratch cards non-BGC gambling companies which are not subject to the voluntary commitment ads during horse racing and greyhound racing Significance of sport sponsorships Frequencies of gambling sponsorship references in sports per broadcast minute 128 (Percentage of marketing references that were commercial ad breaks) Boxing: 4.70 (0%) Football: 2.75 (2%) Rugby Union: 0.55 (0% Tennis: 0.11 (12%) Formula 1: 0.00 (0%) Issues with industry interpretation of evidence 129 Industry claim: the “whistle to whistle” ban has slashed the amount of TV gambling ads seen by 4 to 17 year olds by 97 per cent. Reality: From Aug - EOY 2018 to August - EOY 2019, BGC results show that the total number of gambling ads views across all TV channels fell by 11.3% (15, 222 million views to 13, 499 million views) COVID-19 TV & Radio ban Industry claim: BGC members to remove TV and radio gaming product advertising during covid-19 lockdown 130 What was proposed To be implemented for six weeks, by no later than Thursday 7th May 2020, and remain in force until 5th June 2020 (4 weeks) Existing TV and radio advertising for casino, slots and bingo to be replaced by safer gambling messages, donated to charities or removed from broadcast where contracts permit BGC members currently account for around 50 per cent of all gambling advertising on TV and radio. Criticisms 131 BGC criticised for running thinly veiled ads as social messages which still feature the widely criticised “When the FUN stops, stop”. Online casino Mr Green, a brand owned by William Hill, aired a safer gambling message which ended “Enjoy award-winning online casino with Mr Green”. A message from SkyVegas also said “That’s why I play at SkyVegas”, A Paddy Power message aired on Comedy Central didn’t seem to contain any safer gambling advice at all. Multi-operator self-exclusion schemes Online: GAMSTOP Option 1 Verify email Complete online form Arcades: British Amusement Catering Trade Association (BACTA) Option 1 Attend local Adult Gaming Centre Option 2 Phone BACTA Betting: MOSES part of the Betting Gaming Council Option 1 Phone MOSES Send a copy of photo ID and a recent photo by post or by email Bingo: Bingo Association Option 1 Attend local bingo Option 2 Telephone local venue or contact them by their website Option 3 Contact bingo association who will provide telephone number for their venue (leads to Option 2) Casino: Betting and Gaming Council Option 1 Attend a local casino Option 2 Download and print enrolment application form Fill in the form Scan or take a digital picture of the completed form Send an email to BGC with: Completed enrolment application form A recent photo A photocopy of your driving license or passport Proof of your current home address What the industry said? Michael Dugher, CEO of the Betting Gaming Council 132 “And all adults who open a new gambling account are asked at the outset if they want to opt in to marketing and advertising. If they do opt in but change their mind and want to take a break or self-exclude, tools are available online to pause or stop receiving marketing.” Dugher suggests that adults with accounts with operators have control of whether they receive gambling marketing and advertising. Although this may be true for direct marketing, there is not much that can be done to prevent those who suffer from gambling addiction from being exposed to the sheer volume of non-direct marketing online and offline. Brigid Simmonds, Chair of the Betting Gaming Council 133 “The success of the whistle to whistle ban – which has reduced the number of TV betting commercials seen by children during live sport pre-watershed by 97 per cent – is a perfect example of what we can achieve together.” Simmonds uses the industry-funded research statistic of a decrease of 97% but fails to recognise that the same research partner, Enders Analysis, has reported that industry efforts have been an ‘inadequate solution to online harm’. Moreover, the overall number of gambling ads on TV fell by around 10%. Gambling Commission 134 “It is up to you to stick to your self-exclusion agreement, but if you try to gamble during that time the gambling business should take reasonable steps to prevent you from doing so. Once you have made a self-exclusion agreement, the gambling company must close your account and return any money in your account to you. It must also remove your name and details from any marketing databases it uses.” According to the Gambling Commission, responsibility for prevention of gambling still falls on customers who have identified that they have a compulsion to gambling and need help to stop them from doing so. Moreover, little consideration has been given to the fact that self-exclusion processes are inaccessible and burdensome, often requiring individuals to attend a gambling venue or contact the industry to exclude. Peter Jackson, CEO of Flutter Entertainment 135 “It has been suggested in recent weeks that football clubs should be banned from carrying sponsorship by betting brands. But, unlike tobacco, gambling is not inherently harmful for an individual if done responsibly and commensurately with someone’s financial means.” Jackson suggests that gambling should not be considered in the same way as tobacco as not everyone who gambles will suffer harm. Here, Jackson fails to recognise that the magnitude of quality-of-life harm accrued from gambling on a population level is expected to be as significant as the harm accrued by tobacco use, and just like tobacco, gambling is a harmful and addictive product. Lord Browne, House of Lords debate 23/11/17 136 “My first engagement with online gambling came in 2014, when I responded to the Gambling (Licensing and Advertising) Act, which was narrowly concerned with online gambling. During the debates on the Bill I argued that online problem gamblers are discriminated against because they cannot access one of the main protections for problem gamblers—self-exclusion—on anything resembling a level playing field with offline problem gamblers. In response to this I proposed, through amendments, multi-operator self-exclusion, whereby the online problem gambler needs to self-exclude only once with the Gambling Commission or its nominated body, and all online sites with a Gambling Commission licence are required to respect the self-exclusion. On Report the Government announced that they were finally persuaded of the need for multi-operator self-exclusion but explained that they did not want to implement it on a statutory basis. I was asked to withdraw my amendment on the basis that the Government had asked the Gambling Commission to introduce multi-operator self-exclusion and it would make substantial progress towards its realisation in the next six months. Mindful of the Government’s willingness to compromise, I decided to withdraw my amendment. In June this year it was finally announced that the Remote Gambling Association would run multioperator self-exclusion—or MOSES, as it is now referred to—for the Gambling Commission, and that it would be called GAMSTOP and would be up and running by the end of the year. As we address this subject nearly four years later, I make the following points. … First, it is regrettable that nearly four years on from when the commitment was made we still do not have multi-operator self-exclusion up and running. We cannot afford to waste any more time” Lord Browne reflects on the influence of industry on Government and the shortfalls of voluntary commitments to reduce or prevent gambling-harm. Brigid Simmonds, Chair of the Betting and Gaming Council (BGC) 137 "We will implement a ban on credit cards and indeed our members will go further to study and improve the early identification of those at risk," "The use of credit cards were previously used as a potential marker of harm which might lead to further intervention with customers." When the Gambling Commission announced that it would introduce a ban on the use of credit cards from the 14th of April 2020, Simmonds stated that they would implement the ban. Simmonds also reflects that previously, signs of harmful gambling were indicated through credit cards, were used to help stratify customers such that intervention may be considered. However, it is unclear what interventions would look like and if they would be helpful or meaningful. References 57. REGULUS PARTNERS. Industry Advertising spend 2014-2017. Available from: https://www.begambleaware.org/media/1853/2018-11-24-rp-ga-gb-marketing-spend-infographic-final.pdf [Accessed: 28th February 2021] 127. Betting & Gaming Council. ‘Whistle to whistle’ ban success. Betting & Gaming Council. 21 August 2020. Available from: https://bettingandgamingcouncil.com/news/whistle-to-whistle-ban-dramatically-reduces-number-of-betting-adverts-seen-by-children [Accessed: 31st March 2021] 129. Betting & Gaming Council. Review of Voluntary Whistle-to-Whistle Advertising Restrictions. Betting & Gaming Council. 2021. 130. Betting & Gaming Council. BGC Members to Remove TV and Radio Gaming Product Advertising During COVID-19 Lockdown. Betting & Gaming Council. 27 April 2020. Available from: https://bettingandgamingcouncil.com/news/gaming-advertising-removed [Accessed: 31st March 2021] 131. Davies R. Gambling firms’ social messages are ‘thinly veiled’ adverts, say MPs. The Guardian. 10 May 2020. Available from: https://www.theguardian.com/world/2020/may/10/gambling-firms-social-messages-are-thinly-veiled-adverts-say-mps [Accessed: 31st March 2021] 132. Dugher M. Lockdown is easing and live sport returning, but the commitment to safer gambling must continue. Politics Home. 5 June 2020. Available from: https://www.politicshome.com/members/article/lockdown-is-easing-and-live-sport-returning-but-the-commitment-to-safer-gambling-must-continue [Accessed: 30th March 2021] 133. Simmonds B. Looking ahead to another year of progress in promoting safer gambling. Available from: https://bettingandgamingcouncil.com/news/brigid-simmonds-looking-ahead [Accessed: 30th March 2021] 134. Gambling Commission. Self-exclusion. Available from: https://www.gamblingcommission.gov.uk/for-the-public/Safer-gambling/Self-exclusion.aspx [Accessed: 30th March 2021] 135. Jackson P. Why a review of gambling laws is badly needed - Flutter chief executive. Racing Post. 10 November 2020. Available from: https://www.racingpost.com/news/gambling-review-long-overdue-to-reflect-drastic-changes-in-the-betting-landscape/458481 [Accessed: 30th March 2021]] 136. Gambling With Lives. Expanded Answers to Committee Questions: House of Lords Select Committee on the Social and Economic Impact of the Gambling Industry (25th February 2020). 2020. Available from: https://238317bb-a8fb-4ec4-89e8-33db4ae69de7.filesusr.com/ugd/c47eec_125a5181f41f4e1a8b1ad6d3b5f58f67.pdf [Accessed 31st March 2021] 137. iGaming Business. Gambling Commission confirms credit card ban from April. iGaming Business. 14 January 2020. Available from: https://igamingbusiness.com/gambling-commission-confirms-credit-card-ban-from-april/ [Accessed: 30th March 2021]
- Gambling operators as multinational corporations
The gambling industry is international; headquarters are based in low-tax and low-regulation countries, and online operators have global customers. The UK is strategically important, not only as a source of income but also for the unique and global exposure of its sports, particularly Premier League Football. Moreover, advertisement through football club sponsorships can reach millions of fans in countries where gambling may be prohibited. Hence, many of these UK-based gambling corporations have huge worldwide influences. Summary The gambling industry is an international one; company headquarters are commonly based in low-tax and low-regulation countries, and online operators often have customers worldwide. The UK is not only strategically valuable as a source of income for operators, influence as an example of a liberalisation case-study, but it also boasts a unique global exposure of sports, particularly Premier League Football. Interestingly, despite the industry being critical of non-regulated brands in the UK, many UK operators often profit from unregulated markets themselves. 138 Before December 2014, remote operators based outside of the UK were not required to pay UK gambling duty on profits made from UK residents. After being legally mandated to hold a UK license and pay UK gambling duty, the number of remote operators licensed more than doubled in a year. The prohibition of gambling products remains in numerous countries such as Turkey and China. Top English football clubs, which have millions of fans in these countries, are closely involved in betting companies' promotional efforts, either through prominent shirt sponsorships, pitch-side advertising, and the direct use of player endorsements. Countries in Africa, the United States, and Latin America provide growth opportunities due to increased digitalisation and legalisation. Many of the larger businesses dominating the global online gambling industry are UK-based, demonstrating the size and global influence of these operators. What is known? Football sponsorships Premier League Clubs with an association with a betting brand in the 20/21 season (18 out of 20) 139 International gambling brands based in the UK SportPesa (based in Liverpool) Arsenal sent its former star, Sol Campbell, to Nairobi for children's coaching sessions with SportPesa 141 Took £1.15bn in revenue from Kenya (95% of its total global income) 142 Hull City players went to a Nairobi shanty town, where they handed out SportPesa branded wristbands and football strips to schoolchildren 141 Families watch television adverts featuring Arsenal, which is sponsored by a betting firm. The slogan is "They play, you win” 143 Editec (based in London) 141 Trades in Kenya as PremierBet, made pre-tax profits of £17m on a turnover of £51m in 2017, almost entirely from Africa The “casino” section of PremierBet’s Kenya website includes a number of cartoon-character gambling games that appeal to children. They have names such as Lucky Pirates, fronted by a friendly toucan; Spellcraft, with smiling witches; and Rainbows In Cameroon, PremierBet has sponsored a school with its corporate logo on the wall An example of how gambling companies operate in black markets without licenses Bet365, like others, operates in many countries where it does not have a license 144 Important betting markets where Bet365 is available include: Australia, Austria, Argentina, Bulgaria, Canada, China, Croatia, Denmark, Germany, Great Britain, Hungary, Iceland, Ireland, Italy, Norway, Russia, Spain, Sweden and Switzerland Countries that Bet365 is licensed in as of Q4 2019: Australia, Denmark, Gibraltar, Great Britain, Italy, Malta, and Spain Number of licensed gambling operators in the UK Number of licensed gambling software operators 102 2013: 96 2014: 89 Prior to November 1st 2014, online operators were not required to have a Great British Gambling Commission licence and did not have to pay UK betting duty taxes) 2015: 216 2016: 241 2017: 254 2018: 299 2019: 314 2020: 321 Number of licensed remote casino, betting, and bingo operators 102 2013: 182 2014: 173 Prior to November 1st 2014, online operators were not required to have a Great British Gambling Commission licence and did not have to pay UK betting duty taxes) 2015: 499 2016: 506 2017: 528 2018: 608 2019: 626 2020: 596 A few of the UK’s largest gambling businesses, where they are based, and subsidiary trading names 145 888 Holdings PLC: Gibraltar: (Market Cap: £1bn, Great British remote license from 1st November 2014) 888 UK Limited: Gibraltar 777.com, 888.co.uk, 888.com, 888.info, 888bingo.com, 888casino.com, 888ladies.com, 888poker.co.uk, 888poker.com, 888poker.net, 888pokercam.com, 888pokeruk.com, 888responsible.com, 888sport.com, 888vipcasinoclub.com, angrybingo.com, bbqbingo.com, beatlebingo.com, betyoucan.com, bingoappy.com, bingoballroom.com, bingofabulous.com, bingohearts.com, bingohollywood.co.uk, bingohollywood.com, bingostreet.com, casino-www.888poker.com, casino-www.888sport.com, celebbingo.com, citybingo.com, costabingo.com, costagames.com, daisybingo.com, dinobingo.com, fancybingo.com, frozenbingo.com, giantbingo.com, magic888casino.com, monkeybingo.com, online-casino.com, play-www.777.com, poshbingo.co.uk, redbusbingo.com, riobingo.com, seasonbingo.com, singbingo.com, snowybingo.com, sparklybingo.com, tastybingo.com, treasurebingo.com, trexbingo.com, winkbingo.com, winkbingo.net, wishbingo.com, www.888poker-promotions.com, www.bigteasebingo.com, www.bingoloft.com, www.bringobingo.com, www.crocodilebingo.com, www.deepseabingo.com, www.easterbingo.com, www.fantasticspins.com, www.farmyardbingo.com, www.farmyardbingo.info, www.jinglebingo.com, www.kingdomofbingo.com, www.realdealbingo.com, www.rewindbingo.com, www.scarybingo.com, www.skyhighslots.com, www.slotcrazy.com, www.snowybingo.com, www.spybingo.com, www.sweetshopbingo.com, www.winkslots.co.uk, www.winkslots.com, www.winkslots.net, www.winkslots.uk William Hill: England (Market Cap: £3bn, Great British remote license from 1st November 2014) purchased by Caesar’s Entertainment (USA) for £3bn due to be concluded in April 2021 WHG (International) Limited: Gibraltar www.williamhill.com Mr Green Limited: Malta www.mrgreen.com Bet365: England (Market Cap: £5bn, Great British remote license from 1st November 2014) Hillside ENC: Malt bet365.com Entain plc: Gibraltar (Market Cap: £9bn, Great British remote license from 1st November 2014) LC International Limited: Gibraltar betdaq.com, bwin.com, cheekybingo.com, coral.co.uk, foxybingo.com, foxygames.com, galabingo.com, galacasino.com, galaspins.com, gamebookers.com, ladbrokes.com, partycasino.com, partypoker.com, sportingbet.com, sportingbet.uk Flutter Entertainment: Ireland (Market Cap: £29bn, Great British remote license from 1st November 2014) PPB Entertainment Limited: Malta www.betfair.com, www.paddypower.com Stars Interactive Limited: Isle of Man www.betstars.uk, www.fulltilt.uk, www.pokerstars.uk, www.pokerstarscasino.uk, www.uk.fulltilt.com FanDuel Limited: USA www.fanduel.com Bonne Terre Limited: England www.skybet.com, www.skybingo.com, www.skycasino.com, www.skypoker.com, www.skyvegas.com Kindred Group: Gibraltar (Market Cap: £34bn, Great British remote license from 1st November 2014) 32Red Limited: Gibraltar 32red.com, 32redbingo.com, 32redpoker.com, 32redsport.com Platinum Gaming Limited: England touch.unibt.co.uk, www.unibet.co.uk Taxes paid and taxes avoided by the gambling industry Kindred Group 32 Red, which is based in Gibraltar, paid just £812,000 in corporation tax in the ten years to 2016 – an effective tax rate of 3 per cent 146 Entain plc (formerly GVC) 2017 147 UK corporation tax: £14m, business rate & other taxes: £34m betting duties: £396m employer national insurance: £37m irrecoverable VAT: £72m Foreign taxes: £244 2019 148 UK corporation tax: £-17m business rate and other taxes: £29m betting duties: £393m employer national insurance: £34m irrecoverable VAT: £68M Foreign taxes: £420m What the industry said? William Hill PLC Annual Report 2019 149 "The US remains our most significant near-term opportunity. As we continue to hold leading positions in existing states, and work to launch in newly accessible states, the complexity of our US business" William Hill identifies to shareholders that the US represents the source of the most significant growth in the near-term due to online sports betting's legalisation. Kindred 146 “Kindred Group and all our brands – including 32Red – pays all taxes required in every market we operate including the UK.” Kindred states that they pay all their taxes required but omits the concern that UK corporation tax is being avoided and instead corporation tax is being paid in low tax and low regulation countries. GVC (Entain Group) 146 “GVC is a global business. Nevertheless, group companies paid more than £2.5billion of UK taxes from 2015 - 2019, making it one of the top 20 largest taxpayers in the country.” GVC had conveniently reported figures from 2015 when remote operators had to register for a license and could no longer avoid UK betting duties and UK corporation tax. Businesses like GVC still benefit from their offshore bases by avoiding UK corporation tax in place of lower rates in Gibraltar. Bet365 150 “A geographical analysis of turnover has not been given, as in the opinion of the directors, such a disclosure would be severely prejudicial to the interests of the group” Bet365 is primarily owned by the Coates Family (93%) and a minority stake owned by Will Roseff (7%). A lack of investors means that Bet365 has no need to be transparent about risks and opportunities, and thus, it refuses to identify the significance of its revenues from ‘black-market’ regions. Michael Dugher 12 “Unfortunately, in the same way that it is true that regulated betting employs 100,000 people and pays around £3 billion in tax, none of this evidence suits the anti-gambling lobby.” Dugher refers to the levels of employment and tax revenue provided by regulated betting. Ironically, Dugher is keen to avoid discussion of the harms caused by gambling to society and the scale of tax avoidance on the part of gambling companies Sam Chibambo, Premier Bet (Editec) Sales Manager 151 “We are here to change people’s lives. With little money, one wins huge amount of money. I can only encourage people to visit our shops and our agents to place their bets. They can also bet online.” A sales manager for a UK-headquartered operator with customers in Africa encourages the idea of gambling to achieve a better life. Fady Younes, Malawi Marketing Manager of Premier Bet (Editec) 141 “We hope that everyone who places bets will win up to 20m [kwacha — about £21,000].” A marketing manager for another UK-headquartered operator with customers in Africa, disingenuously implies that the operator hopes that everyone will win a small fortune. Mor Weizer, CEO of Playtech 152 “Being too focused on regulated markets actually comes with a lot of risks, not just rewards. There is a balance companies, bookmakers and operators – definitely the pan-European ones – need to maintain between unregulated and regulated income streams. It is extremely important to enjoy the benefits of operating in certain unregulated markets, generating income that can then be deployed in the same markets as they become regulated, and in other markets where online gaming is already regulated.” Weizer highlights the strategic importance of unregulated markets', recommending that operators involve themselves as part of the black-market. GVC 153 “Unregulated gambling markets in Asia and North America make up a big portion of the global online gaming market. About 4% of the company's revenue currently comes from these markets, and GVC said by the end of the year the number would be cut to 1%.” Interestingly, 4% of GVC’s revenue in 2020 was accrued from black market gambling in Asia and North America. The 4% is relatively higher than the 1.2% valuation of the black market in the UK, which is so often proclaimed as the bogeyman of gambling in Britain. Shay Segev, CEO of GVC 154 “making great progress towards being the leading operator in the US.” Segev reports on the growth opportunity of the US and customer acquisition efforts in a recently legalised market. Philip Bowcock, CEO of William Hill 155 “Just one year on since PASPA [Federal Ban on Sports Betting] was overturned William Hill has doubled the sports wagering it handles in the US, seen record performances at the Super Bowl and March Madness, is live in all seven states to have allowed sports betting and expects to enter further states soon, with Indiana and Iowa the most recent states to pass bills to legalise sports betting.” Bowcock reports on the success of expansion to the US as sports betting becomes legalised. References 12. Michael Dugher. It’s important that the Gambling Review tackles betting by under-18s – but let’s deal in facts, not fiction. Available from: https://www.politicshome.com/members/article/michael-dugher-its-important-that-the-gambling-review-tackles-betting-by-under18s-but-lets-deal-in-facts-not-fiction [Accessed: 28th March 2021] 102. Gambling Commission. Industry statistics. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/Statistics-and-research/Statistics/Industry-statistics.aspx [Accessed: 31st March 2020] 138. Goodley S. Revealed: how bet365 profits from Chinese punters who risk jail for gambling online. The Guardian. 3 October 2014. Available from: https://www.theguardian.com/society/2014/oct/03/bet365-profit-china-online-gambling [Accessed: 21st March 2021] 139. Ebejer M. The Evolution Of Premier League Betting Sponsorship. Available from: https://www.thepunterspage.com/evolution-premier-league-betting-sponsorship/ [Accessed: 31st March 2021] 140. DraftKings. Daily Fantasy Sports For Cash. Available from: https://www.draftkings.co.uk/ [Accessed: 30th March 2021] 141. Gilligan A. Gambling, Africa’s new child plague. The Sunday Times. 14 July 2019. Available from: https://www.thetimes.co.uk/article/gambling-africas-new-child-plague-b5xvlct2n [Accessed: 13th February 2021] 142. Faull L. UK firms part ways with stricken Kenyan betting giant SportPesa. Finance Uncovered. 22 January 2021. Available from: https://www.financeuncovered.org/investigations/uk-firms-part-ways-with-stricken-kenyan-betting-giant-sportpesa/ [Accessed: 30th March 2021] 143. SportPesa. They Play You Win! Sportpesa #MadeOfWinners. [Video] 2016. Available from: https://www.youtube.com/watch?v=bVIUEoP0fCs [Accessed: 30th March 2021] 144. Betcreative. Bet365 will no longer provide services in 47 countries. Available from: https://webcache.googleusercontent.com/search?q=cache:VKM8qhPyEHgJ:https://www.bookmakersranking.com/bookmakers_news/bet365_will_no_longer_provide_services_in_47_countries+&cd=1&hl=en&ct=clnk&gl=uk [Accessed: 30th March 2021] 145. Gambling Commission. Register of gambling businesses. Available from: https://beta.gamblingcommission.gov.uk/public-register/businesses [Accessed: 31st March 2021] 146. Witherow T. Betting giants Flutter, Bet 365 and William Hill in tax haven row. This is Money. 7 August 2020. Available from: https://www.thisismoney.co.uk/money/markets/article-8605137/Betting-giants-Flutter-Bet-365-William-Hill-tax-haven-row.html [Accessed: 30th March 2021] 147. GVC. OUR APPROACH TO TAX. GVC; 2016. Available from: https://entaingroup.com/wp-content/uploads/2018/12/GVC-Approach-to-tax-2018-Final.pdf [Accessed 31st March 2021] 148. Entain. Our approach to tax. Available from: https://entaingroup.com/sustainability/tax-statement/ [Accessed: 30th March 2021] 149. Kelly-Bisla B. William Hill PLC 2019 Annual Report and Accounts. Available from: https://www.williamhillplc.com/media/13261/2020-02-26-publication-of-2019-annual-report-accounts-final.pdf. [Accessed: 30th March 2021] 150. Dunnagan A. bet365 and tax havens. TaxWatch. 1 April 2020. Available from: https://www.taxwatchuk.org/bet365_tax_havens/ [Accessed: 30th March 2021] 151. Maona B. Blantyre man wins K109 million in Premier Bet wager. Kulinji. 15 April 2019. Available from: https://kulinji.com/article/news/business/2019/blantyre-man-wins-k109-million-premier-bet-wager [Accessed: 30th March 2021] 152. Gannage-Stewart H. Don’t ignore unregulated markets, warns Playtech chief. iGaming Business. 6 February 2018. Available from: https://igamingbusiness.com/dont-ignore-unregulated-markets-warns-playtech-chief/ [Accessed: 30th March 2021] 153. Reuters. Bookmaker GVC to exit unregulated markets by 2023. Reuters. 12 November 2020. Available from: https://www.reuters.com/article/us-gvc-holdings-strategy-idUKKBN27S0ZG [Accessed: 30th March 2021] 154. Hancock A. GVC raises forecast again as online betting surges. Financial Times. 8 October 2020. Available from: https://www.ft.com/content/34b3fb64-5f1e-4275-bd39-70f968fad01b [Accessed: 30th March 2021] 155. O’Connor D. US William Hill Sports Betting Operations Keep UK Bookmaker in the Black. Casino.org. 16 May 2019. Available from: https://www.casino.org/news/us-william-hill-sports-betting-operations-keep-uk-bookmaker-in-the-black/ [Accessed: 30th March 2021]
- Gambling and crime
Although the Gambling Act 2005 clearly states gambling should be prevented as a source of crime or disorder, it has been linked to opportunity, duress, violence, and negligence crimes. Moreover, international and national studies have shown a disproportionate number of individuals suffering from gambling addiction in the prison population. Furthermore, gambling-related harm is omitted from screening as first-stage health assessment in correctional services dictated by NICE guidelines includes substance abuse but omits gambling. The industry has drastically downplayed the magnitude of crimes linked to gambling via blame deflection on the black market. Summary The Gambling Act 2005 sets out three licensing objectives 42 preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime ensuring that gambling is conducted in a fair and open way protecting children and other vulnerable persons from being harmed or exploited by gambling. Gambling has been linked to crimes of: opportunity such as theft, duress such as drug trafficking to pay debt, & negligence such as leaving children unsupervised As well as crimes to facilitate gambling, gambling can conversely be used to facilitate crime by offering a means for money laundering. Moreover, crimes of abuse, intimidation, and violence can be related to gambling and may be induced by the psychologically taxing effects of harms on individuals that gamble. Familicide, which is at the extreme end of family violence harms, has seldom been measured or reported in research. Moreover, as well as potentially being victims of gambling-related crime, affected others have also been reported to commit crimes such as petty theft and illegal drug use. Studies worldwide have identified that prison populations contain disproportionate numbers of individuals who have suffered gambling harm. Furthermore, a significant percentage of the crime committed by individuals suffering from gambling disorder is directly gambling-related. NICE guidelines on "Mental health of adults in contact with the criminal justice" at first-stage health assessment include alcohol and substance misuse but omits gambling. The industry downplays the significance of gambling-related crime in Great Britain, primarily by suggesting that Great Britain's situation is somehow better than in other countries and by deflecting blame for crime to black market operators. What is known? Public perception of gambling related crime Agree that gambling in this country is associated with criminal activity 25 2010: 37% 2011: 37% 2012: 40% 2013: 40% 2014: 41% 2015: 40% 2016: 39% 2017: 41% 2018: 38% 2019: 43% Prevalence of gambling related crime Prevalence of gambling-related crime in individuals that gamble A review found that approximately 50% of the crime committed by individuals with gambling disorder was gambling-related; this is in line with studies (presented in the same review) that reflect between 4%-9% of all crime is gambling-related crime committed by individuals with gambling disorder. 156 A study in Hong Kong reported the prevalence of suicidal ideation and familicidal-suicidal ideation among individuals presenting to gambling disorder treatments services of 20.0% and 0.6%, respectively 157 In 2010, 1 in 500 or 0.2% of adults in Great Britain reported committing crimes to finance their own gambling in the past year such as forgery, fraud, theft, and embezzlement 19 (1 in 1000 or 0.1% of adults in 2007) 21 Prevalence of gambling-related crime in affected others 3 18% reported not fully attending to needs of children 7% reported engaging in petty theft or dishonesty as a consequence of their family member's gambling 5% reported leaving children unsupervised 4% reported taking money or items from friends or family without asking first 3% reported feeling compelled or forced to commit crime or steal to fund family member’s gambling or pay debts Prevalence of gambling-harm among prison populations Multi-centre studies of gambling harm in Great Britain's prisons have reported significantly elevated rates of prevalence compared to the general population In a 2017 study, 34.3% of those surveyed in English and Scottish prisons suffered gambling harm due to their gambling in the past year 158 11.2% suffered low-risk gambling harm 11.0% suffered moderate-risk gambling harm 12.1% suffered gambling disorder harm A study in two English prisons (one male and one female) reported that 13.4% of males and 7.2% of females admitted to committing a crime to finance gambling or pay off debts 159 Cost of gambling related crime Estimated cost of crime According to the IPPR, between £40m (0.9% of the overall spend on prisons) and £190m (4.3%) are spent on gambling disorder related incarcerations in Great Britain 160 Czech Republic (population: 10.7m) 81 Total: £61.1m - £69.6m Police (4.7 – 6.5% of all major cases, and 0.6 – 0.8% of all minor cases were related to gambling): £22.3m to £30.8m Courts: £1.8m Prisons (15.8% of prisoners were in jail because of crimes related to gambling): £37.0m Sweden (population: 10.2m) 80 Total: £10.1m Police: £7.4m Courts: £0.9m Prisons: £1.8m Geography of gambling related crime Location of betting shops and deprivation by crime decile Betting shops in Great Britain are overwhelmingly in areas of deprivation by crime 161 29% of betting shops are in the top 10% most deprived postcodes by crime 16%, 2nd decile 13%, 3rd decile 11%, 4th decile 10%, 5th decile 8%, 6th decile 6%, 7th decile 4%, 8th decile 2%, 9th decile 1% of betting shops are in the bottom 10% of most deprived postcodes by crime (least deprived postcodes) What the industry said? The Betting and Gaming Council 16 “By international standards, Great Britain has a well-regulated and well-functioning gambling market with high levels of consumer choice and low levels of crime and problem gambling.” Firstly, the BGC argues in relation to international standards to deflect responsibility, despite there being no reliable evidence to support this claim. Great Britain has low levels of gambling-related crime, demonstrating the industry’s refusal to accept evidence and scientific consensus. “On the basis of data available, licensed gambling in Great Britain is almost entirely free from criminal involvement from an operational or ownership perspective.” The following statement offers a favourable view that, crucially, focuses on criminal involvement on owners and operators. In doing so, the BGC omits consideration of crime committed to fund gambling or gambling used to facilitate crime such as money laundering. “…the percentage of respondents who bet more than they could afford has fallen. The same is true of those borrowing money, selling items or committing a crime in order to gamble.” The last statement contrasts with the last series of gold-standard gambling prevalence studies, which reflect an increase in gambling-harm and gambling-related crime. Denise Coates, Joint-CEO of Bet365 162 “[Bet365] recognises its responsibility to minimise gambling-related harm and to keep crime out of gambling. The group is committed to developing an evidence-based approach to responsible gambling. To this end, the group continues to work with research partners on a number of projects to improve its methods of identifying harmful play and deliver more effective harm-minimisation interventions.” Coates, CEO of Bet365, acknowledges gambling-related harm and the risks of crime associated with gambling. While donating millions to the Denise Coates Foundation, which now has a burgeoning balance sheet of over £300m funds and yet no donations had been made to either gambling or addiction charities. 163 Ulrik Bengtsson, CEO of William Hill 164 "[The black market] is a problem we must keep pace with and confront. Not doing so, risks an increase in crime and problem gambling." Bengtsson conflates crime with the black-market industry despite evidence reflecting significant issues with gambling-related crime in Great Britain despite the unregulated market making up approximately 1.2% of total stakes. References 3. Banks J, Andersson C, Best D, Edwards M, Waters J. 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Available from: https://fra.europa.eu/en/publication/2017/mapping-minimum-age-requirements/age-majority [Accessed: 22nd March 2021] 80. Hofmarcher T, Romild U, Spångberg J, Persson U, Håkansson A. The societal costs of problem gambling in Sweden. BMC Public Health. 2020;20(1): 1921. Available from: doi:10.1186/s12889-020-10008-9 81. Winkler P, Bejdová M, Csémy L, Weissová A. Social Costs of Gambling in the Czech Republic 2012. Journal of Gambling Studies. 2017;33(4): 1293–1310. Available from: doi:10.1007/s10899-016-9660-4 156. Williams RJ, Royston J, Hagen BF. Gambling and Problem Gambling Within Forensic Population: A Review of the Literature. Criminal Justice and Behaviour. 2005;32(6). Available from:doi: 10.1177/0093854805279947 157. Wong PWC, Blaszczynski A, Tse S, Kwok N, Tang J. Suicidal Ideation and Familicidal-Suicidal Ideation Among Individuals Presenting to Problem Gambling Services: A Retrospective Data Analysis. Crisis. 2014;35:219-232. 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Available from: https://www.theguardian.com/business/2017/nov/12/bet365-chief-denise-coates-paid-217m-last-year [Accessed: 29th March 2021] 163. Denise Coates Foundation. REPORT AND FINANCIAL STATEMENTS. Denise Coates Foundation; 2019.Available from: https://register-of-charities.charitycommission.gov.uk/charity-search?p_p_id=uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet&p_p_lifecycle=2&p_p_state=maximized&p_p_mode=view&p_p_resource_id=%2Faccounts-resource&p_p_cacheability=cacheLevelPage&_uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet_objectiveId=A9993065&_uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet_priv_r_p_mvcRenderCommandName=%2Faccounts-and-annual-returns&_uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet_priv_r_p_organisationNumber=5031042 [Accessed: 30th March 2021] 164. @UlrikBengtsson. ‘p2. ....this is a problem we must keep pace with and confront. Not doing so, risks an increase in crime and problem gambling. https://t.co/4RXR5iRki8’. [cited 4 February 2021] Available from: https://twitter.com/UlrikBengtsson/status/1357277446450642944 [Accessed: 30th March 2021]