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  • 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, 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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. Families Living with Problem Gambling: Impacts, Coping Strategies and Help-Seeking. 2018. Available from: https://www.begambleaware.org/sites/default/files/2020-12/families-living-with-problem-gambling.pdf [Accessed: 13th March 2021] 16. 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] 21. Wardle H, Sproston K, Orford J, Erens B, Griffiths M, Constantine R, et al. British Gambling Prevalence Survey 2007. NatCen. 2007 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. 42. 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] 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. Available from: doi:10.1027/0227-5910/a000256 158. May-Chahal C, Humphreys L, Clifton A, Francis B, Reith G. Gambling Harm and Crime Careers. Journal of Gambling Studies. 2017;33(1): 65–84. Available from: doi:10.1007/s10899-016-9612-z 159. May-Chahal C, Wilson A, Humphreys L, Anderson J. Promoting an Evidence-Informed Approach to Addressing Problem Gambling in UK Prison Populations. The Howard Journal of Criminal Justice. 2012;51(4): 372–386. Available from: doi:10.1111/j.1468-2311.2012.00723.x 160. Thorley C, Stirling A, Huyuh E. Cards on the table: The cost to government associated with people who are problem gamblers in Britain. IPPR. 2016. 161. Gambling Harm UK. Gambling-harm and crime. Available from: https://www.gamblingharm.com/post/gambling-harm-and-crime [Accessed: 31st March 2021] 162. Neate R. Bet365 chief Denise Coates paid herself £217m last year. The Guardian. 12 November 2017. 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]

  • The end of influencers

    Create a blog post subtitle that summarizes your post in a few short, punchy sentences and entices your audience to continue reading. Welcome to your blog post. Use this space to connect with your readers and potential customers in a way that’s current and interesting. Think of it as an ongoing conversation where you can share updates about business, trends, news, and more. “Do you have a design in mind for your blog? Whether you prefer a trendy postcard look or you’re going for a more editorial style blog - there’s a stunning layout for everyone.” You’ll be posting loads of engaging content, so be sure to keep your blog organized with Categories that also allow visitors to explore more of what interests them. Create Relevant Content Writing a blog is a great way to position yourself as an authority in your field and captivate your readers’ attention. Do you want to improve your site’s SEO ranking? Consider topics that focus on relevant keywords and relate back to your website or business. You can also add hashtags (#vacation #dream #summer) throughout your posts to reach more people, and help visitors search for relevant content. Blogging gives your site a voice, so let your business’ personality shine through. Choose a great image to feature in your post or add a video for extra engagement. Are you ready to get started? Simply create a new post now.

  • 10 ads you should learn from

    Create a blog post subtitle that summarizes your post in a few short, punchy sentences and entices your audience to continue reading. Welcome to your blog post. Use this space to connect with your readers and potential customers in a way that’s current and interesting. Think of it as an ongoing conversation where you can share updates about business, trends, news, and more. Design with Ease “Do you have a design in mind for your blog? Whether you prefer a trendy postcard look or you’re going for a more editorial style blog - there’s a stunning layout for everyone.” Every layout comes with the latest social features built in. Readers will be able to easily share posts on social networks like Facebook and Twitter, view how many people have liked a post, made comments and more. With Wix, building your online community has never been easier. Create Relevant Content You’ll be posting loads of engaging content, so be sure to keep your blog organized with Categories that also allow readers to explore more of what interests them. Each category of your blog has its own page that’s fully customizable. Add a catchy title, a brief description and a beautiful image to the category page header to truly make it your own. You can also add tags (#vacation #dream #summer) throughout your posts to reach more people, and help readers search for relevant content. Using hashtags can expand your post reach and help people find the content that matters to them. Go ahead, #hashtag away. Stun Your Readers “Be original, show off your style, and tell your story.” Blogging gives your site a voice, so let your business’ personality shine through. Are you a creative agency? Go wild with original blog posts about recent projects, cool inspirational ideas, or what your company culture is like. Add images, and videos to really spice it up, and pepper it with slang to keep readers interested. Are you a programmer? Stay on the more technical side by offering weekly tips, tricks, and hacks that show off your knowledge of the industry. No matter what type of business you have, one thing is for sure - blogging gives your business the opportunity to be heard in a way in a different and unconventional way. Get Inspired To keep up with all things Wix, including website building tips and interesting articles, head over to the Wix Blog. You may even find yourself inspired to start crafting your own blog, adding unique content, and stunning images and videos. Start creating your own blog now. Good luck!

  • Stigma

    What is Stigma? Stigma is a social phenomenon where certain characteristics, qualities or features of an identifiable group are regarded in a strongly negative light. As a consequence, stigmatisation can operate in a discriminatory way, create increased isolation, punish individuals further and lead to increased levels of harm. This article discusses some of the consequences of the stigma that people with gambling harm may experience before explaining how language can be used to remove stigmatisation. How does stigma affect people with gambling harm? It is reported that stigma hinders or prevents treatment for individuals suffering from substance abuse and problem gambling (Yang, Wong, Grivel and Hasin, 2017). Stigma can lead to policymakers underfunding necessary treatment programmes. Equally, stigma can dissuade individuals from speaking openly. If people who have a gambling disorder experience less stigma, they may feel more able to ask for help and take steps towards recovery. Studies have shown that people who suffer from gambling harm experience anxiety over how their disorder might be perceived and the potential negative consequences accompanying this. Because of this anxiety, other less healthy coping mechanisms are adopted, such as hiding and cognitive distancing (Dąbrowska and Wieczorek, 2020). The Victorian Responsible Gambling Foundation make a distinction between self-stigma and public stigma. The former refers to stigma from the point of view of people with a gambling disorder and how they perceive themselves. The latter describes the point of view of others, perceiving individuals with a gambling disorder. Stigmatising beliefs can lead to people who gamble compulsively experiencing greater difficulties and further harm, such as increased self-blame and intensified feelings of guilt. Moreover, individuals with problem gambling experience high levels of fear regarding how others perceive them, despite experiences of direct discriminatory behaviours being relatively low (Hing, Nuske, Gainsbury and Russell, 2015). Why is some language stigmatising? It is important to think about why certain language is stigmatising. The choice of certain language and phrases over others can have far-reaching implications for the way in which topics, such as gambling harm, are discussed. Whether or not something is stigmatising often comes down to how the topic is framed. Subtle differences in the words we use, often chosen unconsciously, can create vastly different impressions. The language we use is important because of the non-explicit messages which are conveyed. Depending on how we phrase our words, we have the ability to avoid accidentally implying unnecessarily punitive attitudes and individual blame. For example, when speaking about people who gamble, phrases such as “a compulsive gambler” or “a gambling addict” place gambling as the central aspect of the identity of an individual. Placing gambling as the central aspect of the identity of an individual can be stigmatising because it defines the individual in terms of gambling which could be considered as placing ultimate responsibility, or even blame, on the individual, and add to the pre-existing harm they experience. Alternatively, individuals who gamble compulsively may prefer to be described as exactly that: “a person who gambles compulsively”. This language is non-stigmatising and centres the focus on the person, acknowledging them as an individual first and foremost, while also speaking about gambling in a clear and neutral way. It conveys the meaning that a person “has” a problem rather than that a person “is” a problem (Kelly, Saitz and Wakeman, 2016). When these ideas about stigmatisation are applied to all language used to discuss gambling harm, a far healthier environment is created. What are the stigmatising terms for gambling harm and drug use and what are the terms that they should be using? The table below has been prepared to provide examples of non-stigmatising language alongside equivalent stigmatising language, based on a table provided for similar terms relating to drug addiction. On the right-hand side of the table are two columns. The first is a list of terms that can be used to describe Problem Gambling in a way which frames the conversation by putting individuals first. The second column is a list of terms that are often used yet stigmatise those who gamble compulsively. For reference, the two left-hand columns provide the original table of terms concerning drug usage. References Dąbrowska, K. and Wieczorek, Ł. (2020) ‘Perceived social stigmatisation of gambling disorders and coping with stigma’, Nordic Studies on Alcohol and Drugs, 37(3), pp. 279–297. Hing, N., Nuske, E., Gainsbury, S. and Russell, A., 2015. Perceived stigma and self-stigma of problem gambling: perspectives of people with gambling problems. International Gambling Studies, 16(1), pp.31-48. Kelly, J., Saitz, R. and Wakeman, S., 2016. Language, Substance Use Disorders, and Policy: The Need to Reach Consensus on an “Addiction-ary”. Alcoholism Treatment Quarterly, 34(1), pp.116-123. Yang, L., Wong, L., Grivel, M. and Hasin, D., 2017. Stigma and substance use disorders. Current Opinion in Psychiatry, 30(5), pp.378-388.

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