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Publicly the industry denied and continues to deny the significance of gambling harm on a population level. This refusal to accept the reality is compounded by the industry's lack of funding in public health research, despite the WHO commenting on the need to prioritise gambling-harm on agendas due to the magnitude of harm from gambling being comparable to the harm accrued by alcohol-use disorder or major depressive disorder. Harms in affected others challenge the industry in two ways. First, measures to raise awareness and prevent gambling harms in individuals who do not gamble will reduce the appeal of gambling and contribute to its social unacceptability. Second, the 'freedom to gamble' argument is confounded if individuals who do not gamble are harmed. The industry has largely refused to acknowledge the significance of harms in affected others, individuals who gamble and suffer low-risk harms, moderate-risk harms, and legacy harms due to previous gambling. This situation has not been helped by the chronic underfunding and lack of independence in research, education, and treatment. Summary “The gambling-related burden of harm appears to be of similar magnitude to harm attributed to major depressive disorder and alcohol misuse and dependence. It is substantially higher than harm attributed to drug dependence disorder.” WHO: The epidemiology and impact of gambling disorder and other gambling-related harm 2017 1 Gambling addiction was first formally recognised as a mental disorder by professionals in the US through the Diagnostic and Statistical Manual of Mental Disorders-III in 1980. Over the past two decades, gambling harm has emerged as a pressing public health issue globally. Domestic and international studies have reported statistical links between gambling harm in adults and suicide, mortality, and poor health. When faced with evidence of the links of gambling and harm to health, industry lobbyists have commonly steered away from admitting any responsibility; instead, they have promised research, reform, or reiterated commitments to safer gambling standards. Moreover, the industry has worked to associate itself with the NHS and other health organisations. Gambling harm may be experienced by individuals that gamble, affected others of people who gamble, and by communities. Research from Australia in 2016 reported a taxonomy of harms over eight domains: financial, relationship, emotional, health, cultural, work or study, criminal activity, life course and intergenerational harms. Responsible gambling mantras have largely replaced public health messaging in Great Britain. Meanwhile, ideas of risk-free gambling and safer gambling have been furthered. Current safer gambling ads seldom reflect the significance of gambling harm, especially on affected others, due to them being industry-supported. Similarly, specialist treatment options and awareness among health care workers remain challenges and are limited by such efforts being primarily managed with voluntary donations. Moreover, public health research in New Zealand and Australia have explored the significance of gambling harm on quality of life by reporting disability weights. These disability weights allow researchers and public health stakeholders to understand the significance of gambling harm on the individual and the population through comparison to other health states. Based on this research, a WHO report found an "urgent need to place gambling on national and international public health agendas", among other things. At the time of writing, little is known about the significance of harm in young people, individuals who previously gambled, and former affected others (legacy harm). Whereas gambling-harm has featured in Australia's Monash guidelines for healthcare professionals for over a decade, the UK's National Institute for Health and Care Excellence (NICE) is yet to begin reviewing the evidence on gambling harm. What is known? Taxonomy of gambling harm Gambling-harm can manifest both in individuals that gamble and individuals that are affected by other people’s gambling, as general, crisis, and legacy harms, across the domains of 2 Financial harm Relationship disruption, conflict or breakdown Emotional or Psychological Distress Decrements to Health Cultural Harm Reduced Performance at Work or Study Criminal Activity Lifecourse and Intergenerational Harms Prevalence of harms in Family Member's affected by gambling disorder (Affected Others) 3 93% reported that their loved one's disordered gambling impacted their financial security (64% stating that the impact was significant) 89% reported a reduction in available spending money and a 88% reduction in savings 23% reported losing a major asset such as a car, home, or business, and 12% had become bankrupt 82% reported that their loved one's disordered gambling impacted their work and/or education (37% stating that the impact was significant) 76% reported reduced performance at work or study due to tiredness or distraction 55% and 50% reported being late and absent, respectively 99% reported that their loved one's gambling compulsion had harmed their health (46% stating that the impact was significant, 38% moderate, 15% slight) 95% reported loss of sleep due to stress or worry 64% reported reduced physical activity, 30% increased alcohol use, 33% increased tobacco consumption, 56% eating too much, and 44% eating too little 29% reported neglecting their medical needs, 36% reported increased use of health services, and 21% reported requiring emergency treatment for health issues caused or exacerbated by their loved one's gambling 16% reported committing acts of self-harm, and 8% had attempted suicide 96% reported experiencing relationship harms (67% stating that the impact was significant) 89% and 82% reported greater tension and conflict, respectively 71% reported feeling excluded from others 68% reported threatening separation or ending the relationship 33% reported separating or ending the relationship with the family member who gambles and potentially related others Other harms 21% reported incidents of violence 21% reported feelings of shame within their religious or cultural community 7% reported engaging in petty theft or dishonesty as a consequence of their family member's gambling Other addictions Family members of individuals with gambling disorder reported elevated rates of problematic use of substances Alcohol: 34.6% Drugs: 21.2% Legal highs: 3.2% Prescription drugs: 5.0% Severity of gambling-harm on quality of life in Adults 4.5 Disability Weights (where 0 = perfect health and 1 = death) Schizophrenia: acute state: 0.76 Heroin and other opioid dependence: 0.64 Gambling disorder harm (PGSI 8 or more): 0.54 (NZ 18) Manic episode of Bipolar Disorder: 0.48 Gambling disorder harm (PGSI 8 or more): 0.44 (AUS 17) Migraine: 0.43 Moderate alcohol use disorder: 0.39 Moderate-risk harm gambling (PGSI 2-7): 0.37 (NZ 18) Affected others at gambling disorder harms: 0.36 (AUS 17) Affected others at moderate-risk harms: 0.33 (AUS 17) Stroke: long-term consequences, moderate plus cognition problems: 0.31 Moderate-risk harm gambling (PGSI 2-7): 0.29 (AUS 17) Mild alcohol use disorder: 0.26 Low-risk harm gambling (PGSI 1-2): 0.18 (NZ 18) Urinary incontinence: 0.15 Affected others at low-risk harms: 0.17 (AUS 17) Low-risk harm gambling (PGSI 1-2): 0.13 (AUS 17) Hearing loss: complete, with ringing: 0.09 Significance of gambling-harm on the population in Years of Life Lost due to Disability (YLD) New Zealand (Adult population: 3.6m) 6 Combined total of years lost with gambling-harm related quality of life effects in the New Zealand Adult population: 162, 000 years Anxiety and depressive disorders: 106, 000 years Harms from someone else's gambling in adults: 94, 700 years (prevalence: 13.6%) Alcohol – Hazardous drinking (>8 AUDIT): 87, 600 years Harms from own gambling in adults: 67, 200 years (prevalence: 7.3%) Diabetes: 26, 000 years Drug use disorders: 22, 400 years Stroke: 12, 900 years Eating disorders: 3, 980 years Victoria, Australia (Adult population 4.4m) 7 Major depressive disorder: 148, 000 years Alcohol use and dependence: 148, 000 years Combined total of years lost with gambling-harm related quality of life effects in the Victorian Adult population: 118, 000 years Harms from own gambling in adults: 102, 000 years (past-year prevalence: 12.5%) Diabetes Mellitus: 22, 700 years Harms from someone else's gambling in adults: 16, 300 years (past-year prevalence: 2.8%) Cannabis dependence: 5, 780 England 2013 (Adult population: 53.9m) Gambling harm in adults: 1.62m Dietary risks: 1.47m Tobacco smoke: 1.46m Harms from own gambling in adults: 0.90m (prevalence: 8.5%) Harms from someone else's gambling in adults: 0.77m (prevalence: 6.0%) Alcohol use: 0.55m Drug use: 0.27m Significance of gambling-harm on the population in Years of Life Lost due to Mortality (YLL) Research from the UK involving bank data from over 100, 000 customers found that high levels of gambling were associated with a 37% increase in mortality 8 The last Adult Psychiatry Morbidity Survey 2007 that considered gambling-harm reported that individuals with gambling disorder were more likely to have thoughts about suicide (19.2% vs 4.1%) and to have made a suicidal attempt in the past year (4.7% vs 0.6%) compared to individuals who do not suffer gambling-harm. 9 A study of 16-24 year olds living in Great Britain found that Men and Women who indicated gambling disorder harms were 9.0 and 4.9 times more likely to attempt suicide, after adjusting for anxiety, impulsivity, life satisfaction, and other factors 10 Standardised mortality ratios 11 Men and Women in Sweden, aged 20-49 year olds and diagnosed with GD, were 19.3 times more likely to suffer from suicide when compared to the general Swedish population of the same ages Men and Women in Sweden, aged 20-49 years old and diagnosed with GD, were 6.2 more likely to suffer from any mortality when compared to the general Swedish population of the same ages What the industry said? Michael Dugher, CEO of the Betting Gaming Council 12 "The UK's addiction rate stands at 0.5% of the adult population, which is low compared to the international standard. The rates have also remained 'broadly steady around or below one percent for the past 20 years." Dugher frames the topic of gambling harm on the segment of adults suffering the most severe harms due to gambling in the past 12 months while omitting the experiences of affected others, individuals who previously had gambled, and individuals experiencing subclinical levels of gambling harm. Moreover, there are significant concerns with measuring gambling harm using self-completion forms included in health surveys, and as such, the stated 0.5% is expected to be a significant underestimate. The industry rarely comments on affected others as it recognises that this is likely to be the most damaging to their public relations strategies. Instead, the industry benefits from the fallacious societal stigma that gambling addiction is the individual's fault; however, the same cannot be easily argued for loved ones, especially the children who suffer harm. Gambling Commission in a briefing paper for Local Authorities and local Public Health providers February 2018 13 “The numbers of those who experience harm as a result of gambling by others will be considerably greater than the number of people who harm themselves.” “These are not small numbers. They suggest a significant public health issue which has received remarkably little attention relative to other population level concerns.” The Gambling Commission makes clear why gambling harm should be considered as a public health issue. Identifying gambling as a significant public health issue is in direct contrast to how the Gambling Commission falls under the remit of the Department of Culture, Media and Sport (DCMS) instead of the Department of Health and Social Care. Michael Dugher, CEO of the Betting Gaming Council 14 “NHS Charities said it wouldn't be possible for betting co's to make a direct donation, but they were happy for us to donate all the profits from this special fun virtual Grand National to help the NHS at this difficult time. Most people agree there's nothing wrong with this...” Dugher states that NHS Charities were not accepting a direct donation from the gambling industry. This quote demonstrates the BGC’s interest in associating with the NHS for the 4.8m viewers who tuned in to watch this virtual horse race which raised £2.6m. 15 “You don’t have to bet. If you don’t want to have a bet, please make a donation direct to NHS Charities. But millions of people do enjoy an occasional flutter & do so responsibly & safely.” Dugher argues that millions of people enjoy an occasional flutter while ignoring the millions that suffer gambling harm and the individuals who gamble frequently and make up significant amounts of the industry’s profit. Betting and Gaming Council 16 “Suicide is a complex issue and the examination of any links to gambling or disordered gambling requires great care and sensitivity. We suggest that a collaborative and careful approach to understanding linkages is required. The aim of research should be to explore what is clearly a difficult subject and provide pragmatic solutions.” The BGC creates an aura of doubt around gambling-suicide, despite evidence from studies across the world reflecting that individuals with gambling-disorder are many times more likely to suffer from suicidal harm. “Through continued funding by our industry over more than 20 years, these charitable services are able to provide free of charge treatment, support & advice services for anyone affected by gambling.” The BGC boasts of their voluntary funding for treatment services for harms caused by their industry. Thus, the industry demonstrates that treatment services are available due to the industry's generosity while ignoring issues with treatment access, awareness, and chronic underfunding. Mark Etches, CEO of GambleAware 17 [Britain was] “in great danger of sleepwalking into a future public health storm over gambling-related harm”. Etches reflects on the numbers of 11–16 year olds with a gambling disorder and signifies concern for the future. Contrastingly earlier that year, evidence reported on by the World Health Organisation (WHO) reflected a worryingly significant ongoing neglected public health crisis with an “urgent need to place gambling on national and international public health agendas”. 1 References 1. Abbott M. The epidemiology and impact of gambling disorder and other gambling-related harm. Geneva: World Health Organization; 2017. Available from: https://www.who.int/docs/default-source/substance-use/the-epidemiology-and-impact-of-gambling-disorder-and-other-gambling-relate-harm.pdf?sfvrsn=5901c849_2 [Accessed: 25th March 2020] 2. Langham E, Thorne H, Browne M, Donaldson P, Rose J, Rockloff M. Understanding gambling related harm: A proposed definition, conceptual framework, and taxonomy of harms. BMC Public Health. 2016;16(1): 80. Available from: doi:10.1186/s12889-016-2747-0 3. Banks J, Andersson C, Best D, Edwards M, Waters J. Families Living with Problem Gambling: Impacts, Coping Strategies and Help-Seeking. 2018. Available from: https://about.gambleaware.org/ [Accessed: 13th March 2021] 4. Rawat V, Browne M, Bellringer M, Greer N, Kolandai-Matchett K, Rockloff M, et al. A tale of two countries: comparing disability weights for gambling problems in New Zealand and Australia. Quality of Life Research. 2018;27(9): 2361–2371. Available from: doi:10.1007/s11136-018-1882-8 5. Rawat V, Greer N, Langham E, Rockloff M, Hanley C. What is the harm? Applying a public health methodology to measure the impact of gambling problems and harm on quality of life. Journal of Gambling Issues. 2017;36(36). Available from: doi:10.4309/jgi.2017.36.2 6. Browne M, Bellringer M, Greer N, Kolandai-Matchett K, Rawat V, Langham E, et al. Measuring the Burden of Gambling Harm in New Zealand. Central Queensland University and Auckland University of Technology. 2017. 7. Browne M, Langham E, Rawat V, Greer N, Li E, Rose J. Assessing gambling-related harm in Victoria: a public health perspective. Victorian Responsible Gambling Foundation. 2016. 8. Muggleton N, Parpart P, Newall P, Leake D, Gathergood J, Stewart N. The association between gambling and financial, social and health outcomes in big financial data. Nature Human Behaviour. 2021;5(3): 319–326. Available from: doi:10.1038/s41562-020-01045-w [Accessed: 22nd March 2021] 9. Wardle H, Dymond S, John A, McManus S. Problem gambling and suicidal thoughts, suicide attempts and non-suicidal self-harm in England: evidence from the Adult Psychiatric Morbidity Survey 2007. Gambling Commission. 2019. 10. Wardle H, McManus S. Suicidality and gambling among young adults in Great Britain: results from a cross-sectional online survey. The Lancet Public Health. 2021;6(1): e39–e49. Available from: doi:10.1016/S2468-2667(20)30232-2 11. Karlsson A, Håkansson A. Gambling disorder, increased mortality, suicidality, and associated comorbidity: A longitudinal nationwide register study. Journal of Behavioral Addictions. 2018;7(4): 1091–1099. Available from: doi:10.1556/2006.7.2018.112 12. Michael Dugher. It’s important that the Gambling Review tackles betting by under-18s – but let’s deal in facts, not fiction. Available from: https://www.politicshome.com/members/article/michael-dugher-its-important-that-the-gambling-review-tackles-betting-by-under18s-but-lets-deal-in-facts-not-fiction [Accessed: 28th March 2021] 13. Gambling Commission. Gambling-related harm as a public health issue. 2018. Available from: https://www.gamblingcommission.gov.uk/PDF/Gambling-related-harm-as-a-public-health-issue.pdf [Accessed: 1st February 2021] 14. @MichaelDugher. ‘1. NHS Charities said it wouldn’t be possible for betting co’s to make a direct donation, but they were happy for us to donate all the profits from this special fun virtual Grand National to help the NHS at this difficult time. Most people agree there’s nothing wrong with this...’. [cited 2020 April 3.] Available from: https://twitter.com/MichaelDugher/status/1246177242939559944 [Accessed: 28th March 2021] 15. BBC Sport. Virtual Grand National raises £2.6m for NHS Charities Together. BBC Sport. 5 April 2020. Available from: https://www.bbc.co.uk/sport/horse-racing/52175385 [Accessed: 29th March 2021] 16. UK Parliament – Betting and Gaming Council. Betting and Gaming Council – Written evidence (GAM0068). 2019. Available from: https://committees.parliament.uk/writtenevidence/154/html/ [Accessed: 29th March 2021] 17. Davies R. 25,000 children in Britain are problem gamblers, report finds. The Guardian. 12 December 2017. Available from: https://www.theguardian.com/society/2017/dec/12/children-britain-problem-gamblers-report [Accessed: 29th March 2021]

A team of lived experience researchers surveyed 133 individuals from the lived experience community consisting primarily of individuals with gambling experience and a smaller contingent of affected others between 21st January 2021 and 29th January 2021. The value of lived experience cannot be overstated, especially in a neglected public health issue where understanding and awareness is limited. Ultimately, there is no way of ensuring that only individuals with genuine lived experience fill in an online survey. Therefore, we utilised a mixed-methods approach to maximise the internal validity of any findings reported. Contents 1. Duty of Care 2. Responsibility for Safe Gambling 3. Gambling Activity Data 4. Customer Data 5. Soft Cap 6. Hard Cap 7. Uniform Restrictions 8. Gambling as a Financial Service Duty of Care “Do online gambling companies have a duty of care, to interact appropriately and in a timely manner?” N = 132 survey participants. Nearly all (94%) survey participants felt that online gambling companies have a duty of care, to interact appropriately, and in a timely manner. Based on the experiences that you have seen, why do you think gambling companies should have a duty of care to its customers? (N=125) Both harm prevention and addiction (49/125) “I am a compulsive gambler that would make numerous attempts to load money into accounts when I had no funds…” “Because of the power of addiction and the harm it can cause to both addicts and their loved ones.” “Throughout my addiction…I never once received an intervention from anyone…despite displaying clear levels of harm…A compulsive gambler like myself just doesn't see responsible gambling messages. My addiction doesn't compute this self-serving system..” “My son took his own life due to his gambling addiction and one of the things I found after his death was his frustration with the gambling companies when he reached out to them for help.” Harm prevention (40/125) “Prevention of problem and underage gambling” “gambling has the ability to destroy life’s on the first interaction. Inheritance blown on choosing red over black.” “Player protection, LCCP, the right thing to do” “Because they sell a harmful product, and for moral obligations” Addiction (31/125) “from my own experiences it's pretty obvious when someone is struggling to control gambling and I'm sure the online sites can see this but choose to ignore it” “Because they provide a high intensity service with known addictive triggers” “They have the data and algorithms to identify their at risk users, but have too often exploited them by rewarding them with free bets and VIP bonuses rather than intervene positively.” “When sometimes they're the only person that can see how bad someone's gambling is. They should have a duty of care to step in and make sure that person is being responsible and isn't showing the signs of addiction” Neither (5/125) “Because the customer has found themselves in or on one of their licenced premises” Based on the experiences that you have seen, why do you think gambling companies should not have a duty of care to its customers? (N=8) Should have a duty of care (3/8) "They should care more" "As I am a compulsive gambler they should stop the TV adds and also we as people are starting to expect gambling as part of normal day live as everywhere you turn its about gambling" "They should care thats the end of it or even better they can f*** off!" Personal responsibility (2/8) "There is a lack of personal responsibility in the current climate with those who choose to commit crime being able to use gambling as an excuse for their actions with now many militant anti gamblers using crime as an excuse to profit in breach of the Gambling Commissions own objectives" "A person must take responsibility for their own actions." Unclear (2/8) "Yes" "I believe they take care of their customers to the extent that they are predisposed to consume and develop their spending power with them." Inadvertently caused more harm (1/8) "Creation of perverse incentives/ risk-free gambling. If vulnerable people can get their losses back, they are more likely to experience more gambling-related harm than less." Responsibility for Safe Gambling “Is it fair for safe gambling to be solely the responsibility of the customer?” N = 133 survey participants. Most (92%) survey participants believe it is unfair for safe gambling to be solely the customer's responsibility. Could you explain where you think the responsibility for safe gambling should lie and why? (N=133) Both the individual and the operator (50/133) “It is a joint thing for both customer and client but the overriding responsibility must be with the company providing the service. A pub would not keep serving alcohol to a customer until they died of alcohol poisoning, so a gambling company should not be allowed to facitate gambling to the point where a person has no money left for food, rent, heating etc...” “With the individual and the provider. Gambling is addictive and those who are susceptible and who become addicted need support and care that the providers, without regulation, would do nothing about because their sole motivation is profit.” “It should lie with both parties. But as a CG I couldn’t see that I was digging myself into a hole financially and had there been some safeguards in place to monitor or alert that I was gambling excessively I might not have gotten into so much trouble with it all.” The operator (44/133) “Bookies should be looking after their clients.” “The Gambling Industry profit from addiction. Their bottom line is profit. Their most profitable customers are those on the addiction spectrum. If they have no responsibility, they will encourage and permit addiction. That's what people think about drug dealers… Grooming like this is closer to what is seen among paedophile rings, and human trafficking.” Broad and multiple bodies (30/133) “Gambling Regulator/Commission/Public Health/Government. As with any legal activity that is known to cause harm, safeguarding must be put in place. The Customer of course is ultimately responsible however they most be informed/protected and not coesered into harmful behaviour by gambling companies” “responsibility ought to lie with everyone. The DCMS, The Gambling Commission; the banks, the operators; the people themselves. We all have a part to play” Unclear (6/133) “Amounts you’re able to stake should be some what relative to what you actually earn (money you’ve won would be treated differently) so that people don’t lose a months wage in minutes and then get into debt just to survive the rest of that month etc” Individual (3/133) "People have to take some responsibility" "The 18+ consumer. A gambling company can never accurately determine how much a person is able to spend on their leisure and entertainment activities, so the onus is on the adult to do so." "With the customer who makes a choice" Customer Data “What information should operators obtain to ensure customers are not gambling beyond their means?” N = 133 survey participants. The majority of survey participants consider income (80%), lines of credit (77%), loans (71%), payment history (68%). Just under a majority of participants felt that collections accounts (50%) should be considered and a small portion (6%) of survey participants regard that operators should obtain no further information. Additionally, 5% responded with suggestions such as "source of money" and “all and any suitable information that would be easily available”, should also be obtained. Gambling Activity Data “Which gambling-related factors, other than money spent, should operators have to consider?” N = 132 survey participants. Why should an operator look at other gambling-related factors as well as the amount of money spent? (N=128) "A gambler's behaviour and circumstances will directly influence the amount of money they spend gambling." "Because gambling when it becomes a problem is not just about money... Money is not the only factor, spending more time playing slots rather than spending time with family and friends or working for instance." "Because it would quite quickly become apparent to an operator that someone who is gambling 8 hrs a day, multiple deposits and manic activity that the person was/is out of control" "As the other factors often are an easier indication that individuals have lost all control" "Because gambling addicts lose interest in their lives and isolate themselves spending to much time gambling, Also could be drug related" Soft Cap “Do you agree with a £100 per month affordability threshold?” N = 133 survey participants. How would you have reacted if you were stopped from gambling until you passed an affordability assessment? (N=132) Positively (47/132) "If it was after £100 I would accept that. If it was after £1000’s of pounds I would be annoyed. To me it says, we can take a lot off you and then decide whether you are spending within your means and if you are not you have lost that money. If it’s done at the start the responsibility returns mainly to the customer." "I surpassed that threshold 100's possibly 1000's of times. If it was introduced early on in my gambling career then maybe I would have saved a lot of damage" "As a gambler without a disorder, I would be happy knowing that the operator was acting responsibly.I would be satisfied that they were acting in a matter that was both appropriate and acceptable. I would be appreciative that I might not be allowed to gamble if I could not prove I could afford to lose. However, as gambler with a disorder. I would be angry that I have to wait. I would not be understanding or patient. I would be bitterly disappointed and frustrated and I would be concerned that the affordability checks would prevent me from gambling." "Had it been done early on then it would have avoided many losses and harm and I would have engaged with that. If you don’t have a gambling disorder then why would you mind, if reasons are explained and they are fair I see no reason why a person wouldn’t want to engage." "I've gambled 3 times. Once, I gambled £300+ on a cricket game, as I chased and chased. I wasn't doing so well mentally. If they stopped me at £100, and that was set as the maximum of normal, then I wouldn't have continued to gamble. I would have thought that £100 is enough money lost." Both positively and negatively (39/132) "Angry. Frustrated. Relieved. Relaxed" "As a gambler without a disorder, I would be happy knowing that the operator was acting responsibly.I would be satisfied that they were acting in a matter that was both appropriate and acceptable. I would be appreciative that I might not be allowed to gamble if I could not prove I could afford to lose. However, as gambler with a disorder. I would be angry that I have to wait. I would not be understanding or patient. I would be bitterly disappointed and frustrated and I would be concerned that the affordability checks would prevent me from gambling." "At the time I would of been gutted but being a compulsive gambler and recovering addict looking at it now it is a major factor to helping people out" "I wouldn't have been happy, because I believed I was in control, but in hindsight it would have made a huge difference to my life. I would often gamble away a month's salary within minutes of waking up on payday. That's clearly not affordable. If my gambling was then limited the damage would have been limited. It seems to me to be a simple correlation." "I would have been disappointed later on with my gambling but it would have helped me at the start to highlight there was caution to me doing this so I need to take note." Negatively (32/132) "At the time thinking back I would have likely attempted ways to go elsewhere. Such as another operator. I'd likely also have attempted to show wasy in was affordable when wasn't." "I would have been angry because I only ever wanted to gamble - I would have never passed an assessment as I gambled to excess, maxed out on all forms of credit, and with stolen funds too. Whether this will have made me reach out for help sooner I really couldn't say. It would have made it tougher to gamble though. I think it's important to remember that most people in the UK won't come remotely close to spending £100 p/month on gambling. A study in March 2019 found the average disposable income in a British adult was just £276 - food for thought." "Angry, this has happened in the past on a number of occasions in the past in live casinos (although the limit was dramatically higher) I was only ever questioned whilst in a huge spiral with increasing bets, so my rage was the fact I could not instantly place a roulette bet, always felt, of course my number is going to come down now." "This happened to me and due to being a gambling addict I was quite annoyed and tried to open other betting accounts. Someone could have 10/20 betting accounts with different companies so the £100 per account could be questionable. The company in question asked for affordability and I provided wage slips which showed I was earning £1000 a month but depositing £3000+ per month. The company then allowed me to continue which looking back is shocking." "I wouldnt have liked it and just found somewhere else to gamble with no threshold issues always somewhere that will take your money" Unclear/unsure (14/132) "It would depend on the trigger point and the ease of completing the process." "Can’t say but I guess it would have made a difference" "Friction, slow down decision making, reconsider expenditure." Hard Cap “To prevent gambling-harm, what should be the maximum percentage of disposable income that should go towards gambling?” N = 129 survey participants. 75% of participants agree 20% or less should be the maximum disposable income going towards gambling. Half of the participants agree 10% or less of disposable income should be the maximum. The modal and median percentage reported was also 10%. Uniform Restrictions Should all gambling products be treated the same with the same set of limits and restrictions?”. N = 133 survey participants. Should be treated the same (93/133) "Because they can all get out of hand. An unmanageable for problem gamblers" "Because gambling is so prolific in our country its like its our national sport! With the level of abject poverty we have, coupled with the high suicide rate, its not something to be encouraged at a young age. With a blanket age restriction, we are protecting young people from harm. My gambling problem started at a young age and I did so much damage, I'm still paying for it 30 years later. If it were incredibly difficult to gamble at a young age, with the support that is available now, I would hope the vast majority of young people would not have to suffer the pain I went through." "Gambling is gambling. some people have problems with bingo some with horse racing some with slots. problem gamblers can be addicted to all types or just 1 specific type of gambling. everyone is an individual case." "Any form of gambling can become addictive" "Will stop people from spending above there means and getting in debt regardless of what they are gambling on" Should not be treated the same (40/133) "Blanket one size fits all approach wouldn't be applicable as product ranges differ drastically." "They have different risk profiles" "There are differences in SOME products, which have a dramatically larger amount of winning players, but thats games would be completely changed, poker for example in a live casino has an averagebuy in of £240 per game much higher on average than slots or casino games. The review would punish poker players in a much more aggressive manner" "Gambling differs. Think of alcohol. Spirits like Vodka are poured in measures. You can't order a pint of Vodka at the bar! Whereas lower impact alcohol (take lager), can be ordered in larger amounts. A similar approach should be taken with gambling. Gambling should be categorised. E.g. the more dangerous, rapid and most harmful products (i.e. online slots and roulette) should be limited, or at least forewarned. Less harmful products (i.e. lottery tickets) should be categorised as lower harm. A traffic light system could be used, like on food packets with sugars/salt content. Red= dangerous. Amber= not great for you. Green= fine to use." "Different sporting events may happen once a year for example the grand national, so someone may want to place £100 on numerous horses for that event. However, virtual horse racing is on every 30-45 seconds so placing £100 on each race every day should not be allowed. Maybe restrict a customer to so many virtual races or X amount of spins on slots and roulette" Gambling as a Financial Service “Should gambling operators be required to conduct as thorough checks as banks have to go through when issuing loans or credit?” (N=132) Yes (107/132) "I believe that they should and possibly the gambling companies set the limit for each customer depending on their credit history/score. If a customer believes this should be increased then they should provide clear evidence that it is affordable to them" "exactly correct, people are using large sums of money as a 'gamble' without any credit checks whatosever" "It would certainly help problem gamblers" Potentially (8/132) "Not at first only if want to wager larger and longer amounts" No (10/132) "No as customer not seeking a financial product. There are other ways to review customer affordability. What about customers who play lottery or go to Grand National once a year?" Unsure/unclear (7/132) "I think proof of income when setting up and online account is absolutely necessary."

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]

The gambling industry is international; headquarters are based in low-tax and low-regulation countries, and online operators have global customers. The UK is strategically important, not only as a source of income but also for the unique and global exposure of its sports, particularly Premier League Football. Moreover, advertisement through football club sponsorships can reach millions of fans in countries where gambling may be prohibited. Hence, many of these UK-based gambling corporations have huge worldwide influences. Summary The gambling industry is an international one; company headquarters are commonly based in low-tax and low-regulation countries, and online operators often have customers worldwide. The UK is not only strategically valuable as a source of income for operators, influence as an example of a liberalisation case-study, but it also boasts a unique global exposure of sports, particularly Premier League Football. Interestingly, despite the industry being critical of non-regulated brands in the UK, many UK operators often profit from unregulated markets themselves. 138 Before December 2014, remote operators based outside of the UK were not required to pay UK gambling duty on profits made from UK residents. After being legally mandated to hold a UK license and pay UK gambling duty, the number of remote operators licensed more than doubled in a year. The prohibition of gambling products remains in numerous countries such as Turkey and China. Top English football clubs, which have millions of fans in these countries, are closely involved in betting companies' promotional efforts, either through prominent shirt sponsorships, pitch-side advertising, and the direct use of player endorsements. Countries in Africa, the United States, and Latin America provide growth opportunities due to increased digitalisation and legalisation. Many of the larger businesses dominating the global online gambling industry are UK-based, demonstrating the size and global influence of these operators. What is known? Football sponsorships Premier League Clubs with an association with a betting brand in the 20/21 season (18 out of 20) 139 International gambling brands based in the UK SportPesa (based in Liverpool) Arsenal sent its former star, Sol Campbell, to Nairobi for children's coaching sessions with SportPesa 141 Took £1.15bn in revenue from Kenya (95% of its total global income) 142 Hull City players went to a Nairobi shanty town, where they handed out SportPesa branded wristbands and football strips to schoolchildren 141 Families watch television adverts featuring Arsenal, which is sponsored by a betting firm. The slogan is "They play, you win” 143 Editec (based in London) 141 Trades in Kenya as PremierBet, made pre-tax profits of £17m on a turnover of £51m in 2017, almost entirely from Africa The “casino” section of PremierBet’s Kenya website includes a number of cartoon-character gambling games that appeal to children. They have names such as Lucky Pirates, fronted by a friendly toucan; Spellcraft, with smiling witches; and Rainbows In Cameroon, PremierBet has sponsored a school with its corporate logo on the wall An example of how gambling companies operate in black markets without licenses Bet365, like others, operates in many countries where it does not have a license 144 Important betting markets where Bet365 is available include: Australia, Austria, Argentina, Bulgaria, Canada, China, Croatia, Denmark, Germany, Great Britain, Hungary, Iceland, Ireland, Italy, Norway, Russia, Spain, Sweden and Switzerland Countries that Bet365 is licensed in as of Q4 2019: Australia, Denmark, Gibraltar, Great Britain, Italy, Malta, and Spain Number of licensed gambling operators in the UK Number of licensed gambling software operators 102 2013: 96 2014: 89 Prior to November 1st 2014, online operators were not required to have a Great British Gambling Commission licence and did not have to pay UK betting duty taxes) 2015: 216 2016: 241 2017: 254 2018: 299 2019: 314 2020: 321 Number of licensed remote casino, betting, and bingo operators 102 2013: 182 2014: 173 Prior to November 1st 2014, online operators were not required to have a Great British Gambling Commission licence and did not have to pay UK betting duty taxes) 2015: 499 2016: 506 2017: 528 2018: 608 2019: 626 2020: 596 A few of the UK’s largest gambling businesses, where they are based, and subsidiary trading names 145 888 Holdings PLC: Gibraltar: (Market Cap: £1bn, Great British remote license from 1st November 2014) 888 UK Limited: Gibraltar 777.com, 888.co.uk, 888.com, 888.info, 888bingo.com, 888casino.com, 888ladies.com, 888poker.co.uk, 888poker.com, 888poker.net, 888pokercam.com, 888pokeruk.com, 888responsible.com, 888sport.com, 888vipcasinoclub.com, angrybingo.com, bbqbingo.com, beatlebingo.com, betyoucan.com, bingoappy.com, bingoballroom.com, bingofabulous.com, bingohearts.com, bingohollywood.co.uk, bingohollywood.com, bingostreet.com, casino-www.888poker.com, casino-www.888sport.com, celebbingo.com, citybingo.com, costabingo.com, costagames.com, daisybingo.com, dinobingo.com, fancybingo.com, frozenbingo.com, giantbingo.com, magic888casino.com, monkeybingo.com, online-casino.com, play-www.777.com, poshbingo.co.uk, redbusbingo.com, riobingo.com, seasonbingo.com, singbingo.com, snowybingo.com, sparklybingo.com, tastybingo.com, treasurebingo.com, trexbingo.com, winkbingo.com, winkbingo.net, wishbingo.com, www.888poker-promotions.com, www.bigteasebingo.com, www.bingoloft.com, www.bringobingo.com, www.crocodilebingo.com, www.deepseabingo.com, www.easterbingo.com, www.fantasticspins.com, www.farmyardbingo.com, www.farmyardbingo.info, www.jinglebingo.com, www.kingdomofbingo.com, www.realdealbingo.com, www.rewindbingo.com, www.scarybingo.com, www.skyhighslots.com, www.slotcrazy.com, www.snowybingo.com, www.spybingo.com, www.sweetshopbingo.com, www.winkslots.co.uk, www.winkslots.com, www.winkslots.net, www.winkslots.uk William Hill: England (Market Cap: £3bn, Great British remote license from 1st November 2014) purchased by Caesar’s Entertainment (USA) for £3bn due to be concluded in April 2021 WHG (International) Limited: Gibraltar www.williamhill.com Mr Green Limited: Malta www.mrgreen.com Bet365: England (Market Cap: £5bn, Great British remote license from 1st November 2014) Hillside ENC: Malt bet365.com Entain plc: Gibraltar (Market Cap: £9bn, Great British remote license from 1st November 2014) LC International Limited: Gibraltar betdaq.com, bwin.com, cheekybingo.com, coral.co.uk, foxybingo.com, foxygames.com, galabingo.com, galacasino.com, galaspins.com, gamebookers.com, ladbrokes.com, partycasino.com, partypoker.com, sportingbet.com, sportingbet.uk Flutter Entertainment: Ireland (Market Cap: £29bn, Great British remote license from 1st November 2014) PPB Entertainment Limited: Malta www.betfair.com, www.paddypower.com Stars Interactive Limited: Isle of Man www.betstars.uk, www.fulltilt.uk, www.pokerstars.uk, www.pokerstarscasino.uk, www.uk.fulltilt.com FanDuel Limited: USA www.fanduel.com Bonne Terre Limited: England www.skybet.com, www.skybingo.com, www.skycasino.com, www.skypoker.com, www.skyvegas.com Kindred Group: Gibraltar (Market Cap: £34bn, Great British remote license from 1st November 2014) 32Red Limited: Gibraltar 32red.com, 32redbingo.com, 32redpoker.com, 32redsport.com Platinum Gaming Limited: England touch.unibt.co.uk, www.unibet.co.uk Taxes paid and taxes avoided by the gambling industry Kindred Group 32 Red, which is based in Gibraltar, paid just £812,000 in corporation tax in the ten years to 2016 – an effective tax rate of 3 per cent 146 Entain plc (formerly GVC) 2017 147 UK corporation tax: £14m, business rate & other taxes: £34m betting duties: £396m employer national insurance: £37m irrecoverable VAT: £72m Foreign taxes: £244 2019 148 UK corporation tax: £-17m business rate and other taxes: £29m betting duties: £393m employer national insurance: £34m irrecoverable VAT: £68M Foreign taxes: £420m What the industry said? William Hill PLC Annual Report 2019 149 "The US remains our most significant near-term opportunity. As we continue to hold leading positions in existing states, and work to launch in newly accessible states, the complexity of our US business" William Hill identifies to shareholders that the US represents the source of the most significant growth in the near-term due to online sports betting's legalisation. Kindred 146 “Kindred Group and all our brands – including 32Red – pays all taxes required in every market we operate including the UK.” Kindred states that they pay all their taxes required but omits the concern that UK corporation tax is being avoided and instead corporation tax is being paid in low tax and low regulation countries. GVC (Entain Group) 146 “GVC is a global business. Nevertheless, group companies paid more than £2.5billion of UK taxes from 2015 - 2019, making it one of the top 20 largest taxpayers in the country.” GVC had conveniently reported figures from 2015 when remote operators had to register for a license and could no longer avoid UK betting duties and UK corporation tax. Businesses like GVC still benefit from their offshore bases by avoiding UK corporation tax in place of lower rates in Gibraltar. Bet365 150 “A geographical analysis of turnover has not been given, as in the opinion of the directors, such a disclosure would be severely prejudicial to the interests of the group” Bet365 is primarily owned by the Coates Family (93%) and a minority stake owned by Will Roseff (7%). A lack of investors means that Bet365 has no need to be transparent about risks and opportunities, and thus, it refuses to identify the significance of its revenues from ‘black-market’ regions. Michael Dugher 12 “Unfortunately, in the same way that it is true that regulated betting employs 100,000 people and pays around £3 billion in tax, none of this evidence suits the anti-gambling lobby.” Dugher refers to the levels of employment and tax revenue provided by regulated betting. Ironically, Dugher is keen to avoid discussion of the harms caused by gambling to society and the scale of tax avoidance on the part of gambling companies Sam Chibambo, Premier Bet (Editec) Sales Manager 151 “We are here to change people’s lives. With little money, one wins huge amount of money. I can only encourage people to visit our shops and our agents to place their bets. They can also bet online.” A sales manager for a UK-headquartered operator with customers in Africa encourages the idea of gambling to achieve a better life. Fady Younes, Malawi Marketing Manager of Premier Bet (Editec) 141 “We hope that everyone who places bets will win up to 20m [kwacha — about £21,000].” A marketing manager for another UK-headquartered operator with customers in Africa, disingenuously implies that the operator hopes that everyone will win a small fortune. Mor Weizer, CEO of Playtech 152 “Being too focused on regulated markets actually comes with a lot of risks, not just rewards. There is a balance companies, bookmakers and operators – definitely the pan-European ones – need to maintain between unregulated and regulated income streams. It is extremely important to enjoy the benefits of operating in certain unregulated markets, generating income that can then be deployed in the same markets as they become regulated, and in other markets where online gaming is already regulated.” Weizer highlights the strategic importance of unregulated markets', recommending that operators involve themselves as part of the black-market. GVC 153 “Unregulated gambling markets in Asia and North America make up a big portion of the global online gaming market. About 4% of the company's revenue currently comes from these markets, and GVC said by the end of the year the number would be cut to 1%.” Interestingly, 4% of GVC’s revenue in 2020 was accrued from black market gambling in Asia and North America. The 4% is relatively higher than the 1.2% valuation of the black market in the UK, which is so often proclaimed as the bogeyman of gambling in Britain. Shay Segev, CEO of GVC 154 “making great progress towards being the leading operator in the US.” Segev reports on the growth opportunity of the US and customer acquisition efforts in a recently legalised market. Philip Bowcock, CEO of William Hill 155 “Just one year on since PASPA [Federal Ban on Sports Betting] was overturned William Hill has doubled the sports wagering it handles in the US, seen record performances at the Super Bowl and March Madness, is live in all seven states to have allowed sports betting and expects to enter further states soon, with Indiana and Iowa the most recent states to pass bills to legalise sports betting.” Bowcock reports on the success of expansion to the US as sports betting becomes legalised. References 12. Michael Dugher. It’s important that the Gambling Review tackles betting by under-18s – but let’s deal in facts, not fiction. Available from: https://www.politicshome.com/members/article/michael-dugher-its-important-that-the-gambling-review-tackles-betting-by-under18s-but-lets-deal-in-facts-not-fiction [Accessed: 28th March 2021] 102. Gambling Commission. Industry statistics. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/Statistics-and-research/Statistics/Industry-statistics.aspx [Accessed: 31st March 2020] 138. Goodley S. Revealed: how bet365 profits from Chinese punters who risk jail for gambling online. The Guardian. 3 October 2014. Available from: https://www.theguardian.com/society/2014/oct/03/bet365-profit-china-online-gambling [Accessed: 21st March 2021] 139. Ebejer M. The Evolution Of Premier League Betting Sponsorship. Available from: https://www.thepunterspage.com/evolution-premier-league-betting-sponsorship/ [Accessed: 31st March 2021] 140. DraftKings. Daily Fantasy Sports For Cash. Available from: https://www.draftkings.co.uk/ [Accessed: 30th March 2021] 141. Gilligan A. Gambling, Africa’s new child plague. The Sunday Times. 14 July 2019. Available from: https://www.thetimes.co.uk/article/gambling-africas-new-child-plague-b5xvlct2n [Accessed: 13th February 2021] 142. Faull L. UK firms part ways with stricken Kenyan betting giant SportPesa. Finance Uncovered. 22 January 2021. Available from: https://www.financeuncovered.org/investigations/uk-firms-part-ways-with-stricken-kenyan-betting-giant-sportpesa/ [Accessed: 30th March 2021] 143. SportPesa. They Play You Win! Sportpesa #MadeOfWinners. [Video] 2016. Available from: https://www.youtube.com/watch?v=bVIUEoP0fCs [Accessed: 30th March 2021] 144. Betcreative. Bet365 will no longer provide services in 47 countries. Available from: https://webcache.googleusercontent.com/search?q=cache:VKM8qhPyEHgJ:https://www.bookmakersranking.com/bookmakers_news/bet365_will_no_longer_provide_services_in_47_countries+&cd=1&hl=en&ct=clnk&gl=uk [Accessed: 30th March 2021] 145. Gambling Commission. Register of gambling businesses. Available from: https://beta.gamblingcommission.gov.uk/public-register/businesses [Accessed: 31st March 2021] 146. Witherow T. Betting giants Flutter, Bet 365 and William Hill in tax haven row. This is Money. 7 August 2020. Available from: https://www.thisismoney.co.uk/money/markets/article-8605137/Betting-giants-Flutter-Bet-365-William-Hill-tax-haven-row.html [Accessed: 30th March 2021] 147. GVC. OUR APPROACH TO TAX. GVC; 2016. Available from: https://entaingroup.com/wp-content/uploads/2018/12/GVC-Approach-to-tax-2018-Final.pdf [Accessed 31st March 2021] 148. Entain. Our approach to tax. Available from: https://entaingroup.com/sustainability/tax-statement/ [Accessed: 30th March 2021] 149. Kelly-Bisla B. William Hill PLC 2019 Annual Report and Accounts. Available from: https://www.williamhillplc.com/media/13261/2020-02-26-publication-of-2019-annual-report-accounts-final.pdf. [Accessed: 30th March 2021] 150. Dunnagan A. bet365 and tax havens. TaxWatch. 1 April 2020. Available from: https://www.taxwatchuk.org/bet365_tax_havens/ [Accessed: 30th March 2021] 151. Maona B. Blantyre man wins K109 million in Premier Bet wager. Kulinji. 15 April 2019. Available from: https://kulinji.com/article/news/business/2019/blantyre-man-wins-k109-million-premier-bet-wager [Accessed: 30th March 2021] 152. Gannage-Stewart H. Don’t ignore unregulated markets, warns Playtech chief. iGaming Business. 6 February 2018. Available from: https://igamingbusiness.com/dont-ignore-unregulated-markets-warns-playtech-chief/ [Accessed: 30th March 2021] 153. Reuters. Bookmaker GVC to exit unregulated markets by 2023. Reuters. 12 November 2020. Available from: https://www.reuters.com/article/us-gvc-holdings-strategy-idUKKBN27S0ZG [Accessed: 30th March 2021] 154. Hancock A. GVC raises forecast again as online betting surges. Financial Times. 8 October 2020. Available from: https://www.ft.com/content/34b3fb64-5f1e-4275-bd39-70f968fad01b [Accessed: 30th March 2021] 155. O’Connor D. US William Hill Sports Betting Operations Keep UK Bookmaker in the Black. Casino.org. 16 May 2019. Available from: https://www.casino.org/news/us-william-hill-sports-betting-operations-keep-uk-bookmaker-in-the-black/ [Accessed: 30th March 2021]

Evidence from Great Britain reflects that gambling is one of the more popular activities among 11–16 year olds. However, the industry comment that most of this gambling is done legally through private betting, significant numbers of young people enter licensed gambling venues illegally. Brain imaging studies have shown that brain development continues until the age of 25. The brain area related to decision-making and addictive behaviour is among the last to develop. Thus, it is not surprising that gambling harms, similar to other harmful behaviours, are most common in 16–24 year olds. As well as being vulnerable to harms from their gambling with potentially devastating life-long effects, young people are especially susceptible to harms from a family member’s gambling, which has not been considered in research until recently. The Gambling Act 2005 sets out three licensing objectives 42 “preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime ensuring that gambling is conducted in a fair and open way protecting children and other vulnerable persons from being harmed or exploited by gambling” Summary The third licensing objective in the Gambling Act 2005 specifically singles out children as a vulnerable group who should be protected from being harmed or exploited by gambling. Gambling-harms in young people are of particular significance; young people are more vulnerable to harm, and these harms can have a significant impact, both now and in the future. Moreover, as well as experiencing harm from their gambling, young people can also be susceptible to harm from an immediate family member's gambling through parental neglect or from other stresses, as detailed in the appendix. There is consistent and robust evidence from imaging studies that brain development continues through adolescence and does not complete until the age of 25 or later. Furthermore, the prefrontal cortex, an area of the brain tied to addictive behaviours due to its role in regulating reward regions of the brain and its involvement in higher-order executive function, is among the last to develop. Moreover, similar to other addictive products, such as alcohol and recreational drugs, the age of onset for first gambling is significantly associated with gambling disorder in later life. In Great Britain, the legal age for gambling varies by product. Some gambling products have no age-restrictions, others restricted for individuals 16 years and older, with traditional gambling products having the legal age of 18. Remarkably, loot boxes, although the most popular wagering activity among under 16s, are not yet considered a form of gambling and therefore unregulated. On top of games of chance where children can lose money, popular video games such as Grand Theft Auto 5 feature simulated gambling where players can gamble for virtual currencies. Despite all this, young people have profoundly limited access to appropriate treatment, help, or support. Notably, contrasting with the widespread recognition for substance-use harm, gambling-harm does not feature in competency-based curriculums for specialists in child and adolescent psychiatry (CAMHS). What is known? Legal definitions of youth and age of maturity 43 The age of majority is 18 years in all EU Member States except for Scotland, where children are considered to have full legal capacity from the age of 16 years. In EU Member States, the term ‘youth’ is the only term used to describe an age group that goes beyond 18 years. It is often used when States want to include young adults as well, sometimes up to the age of 30 years. The UN’s definition on the term ‘youth’ includes all persons between the ages of 15 and 24 years; UNESCO uses a wider and more flexible definition depending on the context. In the EU Strategy for Youth, the term ‘youth’ refers to teenagers and young adults aged between 13 and 30 years. EUROSTAT statistics consider the youth population to be aged between 15 and 29 years. Brain development during adolescence and youth 44 Brain maturation occurs during adolescence due to a surge in the synthesis of sex hormones. Types of studies that have provided evidence that structural and functional brain development is an active stage of maturation until at least the age of 25 neuromorphological, neurochemical, neurophysiological, neurobehavioral, neuropharmacological, and brain imaging studies Legal age of gambling by product 45 No age limit Private or Non-Commercial Betting Equal chance gaming Prize gaming at entertainment centre or travelling fair Category D gaming machines Games of chance in video-games (not considered gambling) 16 years old National lottery tickets and scratchcards in shops (18 from October 2021) National lottery tickets and scratchcards online (18 from April 2021) 18 years old Casino, betting shops or licensed premises Category A, B1, B2, B3, B3A, B4 and C gaming machines Football pool Gambling among secondary school students (11-16 year olds) >1 million 11-16 year olds gambled in the past-year 46 In 2018, gambling (14%) was more popular as a past-week activity among 11-16 year olds than alcohol use (13%), tobacco use (4%), and drug-taking (2%) 47 In 2019, gambling (11%) was less prevalent as a past-week activity among 11-16 year olds than alcohol use (16%), but more common than tobacco cigarettes (6%), e-cigarettes (7%), and drug-taking (5%) 46 In 2019, the most prevalent past-week gambling activity (excluding video game gambling) among 11-16 year olds was placing a private bet for money (e.g. with friends) at 5%, followed by: 46 Fruit or slot machines (e.g. at an arcade, pub or club): 4% National Lottery scratchcards which you bought in a shop: 3% Playing cards for money with friends: 3 Personally placing a bet at a betting shop: 3% Lotto (the main National Lottery draw): 2% National Lottery instant win games on the internet: 2% Any other National Lottery games (e.g. EuroMillions): 2% Other Lotteries: 2% Bingo at a bingo club: 2% Bingo at somewhere other than a bingo club: 2% Personally visiting a betting shop to play gaming machines: 2% Playing other gambling machines: 2% Personally visiting a casino to play casino games: 2% Gambling websites/apps where you can win real money: 2% Any other gambling: 3% The most popular form of games of chance with money are in video games Ever-played 46 Used in-game items to open loot boxes/crates/packs to get other in-game items within the game you were playing 11-16 year olds: 28% Paid money to open loot boxes/crates/packs to get other in-game items within the game you were playing 11-16 year olds: 23% Bet with in-game items on website outside of the game or privately (e.g. with friends)11-16 year olds: 3% Past-year 48 Paid money to open loot boxes 10-16 year olds: 20% Past-week 49 Paid money to open loot boxes 11-14 year olds: 27% 18+ year olds: 16% Investigations into under age gambling The Gambling Commission ran a test at the Royal Ascot in 2014, where all 20 bookmarkers served a 16-year old without asking for proof of age, and consequently received a written warning. In 2019, this test was repeated, with 7 out of 17 failing to ask for ID. 50,51 Gambling-harm among children and young people In 11-16 year old school students 46,52 Meta-analysis of prevalence in 2018 – 2020 46,47,52 By frequency Past week gambling: 9% - 14% Past year gambling: 36% - 39% By harm level Low-risk and moderate-risk harm gambling: 2.2% - 2.7% Gambling disorder harm gambling: 1.7% - 1.9 Other gambling: 32% - 33% DSM-IV-MR J harms: 46 Found yourself thinking about gambling or planning to gamble often: 1.7% Gambled to escape from problems or when you were feeling bad sometimes or often: 2.0% Felt bad or fed up when trying to cut down on gambling sometimes or often: 1.2% Needed to gamble with more and more money to get the amount of excitement you want sometimes or often: 1.9% Spent much more than you planned to on gambling sometimes or often: 1.6% Taken money without permission to spend on gambling (any one or more of the following: dinner money or fare money, money from family, money from things you’ve sold, money from outside the family, or somewhere else) Any one or more of the above: 3.8% Gambling led to risk relationships (any one or more of the following: arguments with family/friends or others, missing school): Any one or more of the above: 2.5% Gambling ever led to telling lies to family/friends or others once or twice or sometimes or often: 2.1% After losing money by gambling, have you returned another day to try to win back the money you lost more than half the time or every time: 1.6% Other harms 52 Lost sleep at night because you went to bed late because you were gambling rarely or sometimes or often or all the time: 2.5% often or all the time: 1.1% Lost sleep at night because you were worried about own gambling rarely or sometimes or often or all the time: 1.7% often or all the time: 0.3% Stopped you from buying things you wanted rarely or sometimes or often or all the time: 4.3% often or all the time: 1.3% Made it hard for you to concentrate at school rarely or sometimes or often or all the time: 3.8% often or all the time: 1.4% Made it hard for you to put effort into your homework or personal study rarely or sometimes or often or all the time: 3.4% often or all the time: 1.4% Made you not feel comfortable around your friends rarely or sometimes or often or all the time: 2.7% often or all the time: 0.9% In 11-16 year olds school students (statistics of harmed by an immediate family member(s) gambling) 52 Felt bad because of gambling among family members: 5.5% 46 Lost sleep at night because of worrying about a family member’s gambling rarely or sometimes or often or all the time: 4.9% often or all the time: 1.3% Not had enough food (food at home or money on school canteen card/account) rarely or sometimes or often or all the time: 1.8% often or all the time: 1.1% Stopped you from belonging to clubs or doing activities you like doing rarely or sometimes or often or all the time: 1.3% often or all the time: 1.0% Stopped you from going on trips (e.g. family holidays or school outings rarely or sometimes or often or all the time: 1.8% often or all the time: 0.9% Parent’s or guardians have less time to spend with you rarely or sometimes or often or all the time: 1.6% often or all the time: 1.0% More arguments or tension at home rarely or sometimes or often or all the time: 2.1% often or all the time: 1.2% Has made you feel sad rarely or sometimes or often or all the time: 2.4% often or all the time: 0.6% Has made you feel worried rarely or sometimes or often or all the time: 2.9% often or all the time: 0.7% In 18-24 year old university students 53 47% of students gambled in the past 12 months 8% of which suffer low-risk harm 8% of which suffer moderate-risk harms 8% of which suffer gambling disorder harms Overall, 11% of students suffer significant harm from their gambling, and 4% of students suffer the most severe level of harm from their gambling What the industry said? Matthew Hill, Director of the Gambling Commission 50 “This was a pretty poor result. Preventing under 18s from gambling is one of the most basic obligations every bookmaker has, on or off the course. The industry must do better or operators are likely to find themselves facing formal sanctions.” Hill warns operators of the possibility of sanctions for failing to protect children from gambling as all twenty operators tested allowed a 16 year old to gamble at the Royal Ascot 2014. Richard Watson, Executive Director of the Gambling Commission 51 “Every single gambling business must protect children from gambling but the on course bookmakers results have remained unacceptable. Despite various educational attempts to raise standards, by ourselves and the trade bodies, the on-course sector has historically performed poorly in both underage gambling test purchase exercises and Think 21 testing. Pass rates have failed to meet the standards expected and the sector has consistently performed to levels below those we see in other gambling and age restricted products. By way of example, over the past four years, the on-course sector has a pass rate of around 35% for Think 21 testing.” Watson reports that on-course bookmakers fail to meet the standards expected in preventing underage gambling following an investigation where 7 out of 17 operators allowed a 16 year old to gamble at the Royal Ascot 2019. Michael Dugher, CEO of the Betting Gaming Council 12 “We have already done a lot and we are ready to go even further to prevent underage gambling” Dugher refuses to accept responsibility for industry failings in meeting one of the three licensing objectives. Instead, he uses a vague statement and commitment to defend the prevalence of underage gambling. Michael Dugher, CEO of the Betting Gaming Council 12 "far from trying to entice children to gamble, regulated members of the BGC have a zero tolerance approach to betting by under-18s," and that they welcome the raising of the age limit from 16 to 18 for lottery products. Dugher suggests that regulated members of the BGC have a zero-tolerance approach to underage gambling, despite prevalence statistics and undercover investigations by the Gambling Commission reflecting the contrary. Michael Dugher, CEO of the Betting Gaming Council 36 "I'm also pleased to see that new age-verification and ID checks have resulted in literally hundreds of thousands of accounts being closed recently, where the customer was unable or unwilling to meet the new strict criteria" Dugher reports feeling pleased that the Gambling Commission set rules that mandate operators to verify customers age and identity before allowing them to gamble. Tim Miller, Executive Director of the Gambling Commission 54 “There's no doubt that today's figures on children and gambling should make people sit up and listen, he said. But while discussions about children gambling might conjure up images of kids sneaking into bookies or sitting alone on their iPad gambling on an online casino, our latest research paints a more complex picture. The most common activities that children gamble on are not licensed casinos, bingo providers or bookies. Instead we found children preferred to gamble in informal environments, out of sight of regulation - private bets between friends or playing cards with their mates for money.” Miller states that gambling figures for young people are worrying but argues that underage gambling is not happening mainly in betting shops or online. Although non-regulated forms of activity such as video game gambling and private betting may be more common among 11-16 year olds, staggering numbers of this population are able to enter licensed betting premises and gamble. Marc Etches, CEO of GambleAware 17 "Computer gaming with gambling presents real future challenges to the current regulatory framework. We've been saying for some time we have concern about the normalisation of gambling for young people..." Etches points to the regulatory gap in recognising games of chance in computer gaming as part of gambling. Michael Dugher, CEO of the Betting Gaming Council 55 “tackling betting by under 18s is a top priority. BGC members have a zero tolerance approach to underage betting - unlike the illegal, online black market - but are determined to do more to protect young people.” Dugher acknowledges that betting by under 18s is an issue and that it is a top priority. He also states that BGC members have a zero-tolerance approach to underage betting despite consistent statistics of 11-16 year olds entering licensed betting premises such as casinos and betting shops in the past week. References 12. Michael Dugher. It’s important that the Gambling Review tackles betting by under-18s – but let’s deal in facts, not fiction. Available from: https://www.politicshome.com/members/article/michael-dugher-its-important-that-the-gambling-review-tackles-betting-by-under18s-but-lets-deal-in-facts-not-fiction [Accessed: 28th March 2021] 17. Davies R. 25,000 children in Britain are problem gamblers, report finds. The Guardian. 12 December 2017. Available from: https://www.theguardian.com/society/2017/dec/12/children-britain-problem-gamblers-report [Accessed: 29th March 2021] 36. Dugher M. We Need Big Changes And A Race To The Top On Standards In Gambling. Available from: https://bettingandgamingcouncil.com/news/michael-dugher [Accessed: 29th March 2021] 42. Gambling Commission. Part 5: Principles to be applied by licensing authorities. Available from: https://www.gamblingcommission.gov.uk/for-licensing-authorities/GLA/Part-5-Principles-to-be-applied-by-licensing-authorities.aspx [Accessed: 30th March 2021] 43. European Union Agency for Fundamental Rights. Age of majority. Available from: https://fra.europa.eu/en/publication/2017/mapping-minimum-age-requirements/age-majority [Accessed: 22nd March 2021] 44. Arain M, Haque M, Johal L, Mathur P, Nel W, Rais A, et al. Maturation of the adolescent brain. Neuropsychiatric Disease and Treatment. 2013;449–461. Available from: doi:10.2147/NDT.S39776 45. Great Britain. Gambling Act 2005: Elizabeth II. Chapter 19. London: The Stationery Office; 2001. 46. The Gambling Commission. Young People and Gambling Survey 2019. The Gambling Commission. 2019. 47. Gambling Commission. Young People & Gambling 2018. Gambling Commission. 2018. 48. Parent Zone. The Rip-Off Games: How the new business model of online gaming exploits children. Parent Zone. 2019. 49. Royal Society for Public Health. Skins in the Game. Royal Society for Public Health. 2019. 50. Gambling Commission. Twenty bookmakers at Ascot allowed 16-year-old to bet: operators warned they must improve underage gambling controls. Gambling Commission. 2 July 2014. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/News/twenty-bookmakers-at-ascot-allowed-16-year-old-to-bet-operators-warned-they-must-improve-underage-gambling-controls [Accessed: 23rd March 2021] 51. Gambling Commission. On course bookies face licence reviews. Gambling Commission. 30 July 2019. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/news/2019/On-course-bookies-face-licence-reviews.aspx [Accessed: 23rd March 2021] 52. Gambling Commission. Young People and Gambling. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/Statistics-and-research/Levels-of-participation-and-problem-gambling/Young-persons-survey.aspx [Accessed: 28th February 2021] 53. Young Gamers and Gamblers Education Trust. How gaming & gambling affect student life. Young Gamers and Gamblers Education Trust. 2019. 54. BBC News. Number of child gamblers quadruples in just two years. BBC News. 21 November 2018. Available from: https://www.bbc.co.uk/news/business-46286945 [Accessed: 29th March 2021] 55. Betting and Gaming Council. BGC Chief Executive @MichaelDugher says tackling betting by under 18s is a top priority. BGC members have a zero tolerance approach to underage betting - unlike the illegal, online black market - but are determined to do more to protect young people. Available from: https://www.facebook.com/BettingAndGamingCouncil/photos/a.105106001278691/330551518734137/?type=3 [Accessed: 29th March 2021]

Prevalence of gambling in Young People (11-16 year olds) Prevalence of gambling harm in Young People (11-16 year olds) Miscellaneous

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]

I was invited by Alcohol Change UK to share my lived experience of gambling harm and alcohol dependence. In addition to gambling and alcohol addiction and recovery I shared my experience of being recently diagnosed with ADHD. Please do take 20 minutes out of your day to watch.

We have been building a fruitful relationship with Healthwatch Essex for a while now, so it was great being asked to take part in an episode of their Hidden Voices podcast which was dedicated to gambling harm. It was wonderful to be joined by my friend and fellow in recovery Lisa for the episode. The episode "New Beginnings" - Living with Gambling Addiction can be listened to here https://open.spotify.com/episode/3Sj5hbu5zsnRGMDpea6696?si=61671945c2584a26

Gary and Ant are two great guys who like me love football. They love it so much they decided to talk about it a lot and started their podcast What A Ball Ache. It's a podcast I have enjoyed listening to regularly. So when Ant got in touch and asked me to come on and talk about gambling harm and it's relationship with sport, particularly football, amongst other things I was really excited. What I didn't realise was that Ant was going to use the podcast to share his own experiences of gambling harm. I feel incredibly privileged to have been part of this recording. Well done Ant, top man! https://open.spotify.com/episode/5tvu77BMxqnHtAwzpCCNCn?si=1OMblgYpRSewCv7wmQEB-g

Woodbridge High School, what can I say? A truly amazing experience from start to finish. From the first point of call to the end of the day, Woodbridge High School welcomed us with open arms, which set the scene perfectly for us to deliver our Preventing Gambling Harm in Diverse Communities project. We were given centre stage (quite literally, as the venue was changed to the drama hall). Each sixth form student truly did themselves proud in engaging, listening and soaking in all discussions held today. I would like to thank Mr Graham Samuels and every other member of staff throughout the day who helped us to get our programme to run as smoothly as possible.

Research since 2007, commissioned by the Gambling Commission, has repeatedly and consistently indicated that gambling disorder disproportionately affects 16-24-year-olds, males, and individuals of minority ethnic backgrounds. Prevalence of gambling - any gambling activity in the past year % (regular, at least monthly, gambling %) The last gold-standard prevalence survey, BGPS 2010 showed that past-year gambling prevalence is significantly less common amongst ethnic minority groups than in white ethnic groups. White/White British: 76% (56%) Black/Black British: 41% (29%) Asian/Asian British: 52% (37%) Other ethnic groups: 53% (34%) Prevalence of gambling harm from own gambling by ethnic group The BGPS 2010 also showed that more than 1 in 10 adults (16+) from ethnic minority backgrounds suffered gambling harm from their gambling in the past year. White/White British: Low-risk harm: 5.5%, Moderate-risk harm: 1.5%, Gambling Disorder harm: 0.8% = 7.8% 1 in 7 White/White British individuals who gambled in the past year suffered gambling-harm Black/Black British: Low-risk harm: 7.8%, Moderate-risk harm: 4.8%, Gambling Disorder harm: 1.5% = 14.1% 1 in 3 Black/Black British individuals who gambled in the past year suffered gambling-harm Asian/Asian British: Low-risk harm: 3.7%, Moderate-risk harm: 3.6%, Gambling Disorder harm: 2.8% = 10.1% 1 in 5 Asian/Asian British individuals who gambled in the past year suffered gambling-harm Other ethnic group: Low-risk harm: 7.2%, Moderate-risk harm: 5.0%, Gambling Disorder harm: 0.8% = 13.0% 1 in 4 Other ethnic group individuals who gambled in the past year suffered gambling-harm Prevalence of gambling disorder in Great Britain by ethnicity and by religion The most recent gold-standard gambling prevalence surveys, BGPS 2007 and BGPS 2010, found that Asian and Black ethnic groups were disproportionately affected by gambling disorders. In 2012, the NHS Survey Data found this relationship again and a significant relationship for 'other' ethnic groups. The studies' primary limitation is the small sample sizes of people from minority backgrounds; hence, the estimates lack precision. British Gambling Prevalence Survey (BGPS) (gold-standard) BGPS 2007 (According to DSM-IV) White: 0.5% (Odds ratio: 1, n=7724) Asian or Asian British: 1.4% (Odds ratio: 3.55, n=263) Black or Black British: 2.0% (Odds ratio: 3.80, n=171) Other: 2.2% (Odds ratio: 2.86, n=192) BGPS 2010 (According to DSM-IV) White: 0.8% (Odds ratio: 1, n=7073) Asian or Asian British: 2.8% (Odds ratio: 3.06, n=308) Black or Black British: 1.5% (Odds ratio: 1.72, n=202) Other: 0.8% (Odds ratio: 0.60, n=151) Self-completion forms included as part of a broader health survey (replaces BGPS after 2010 and a 50% decrease in research funding at the Gambling Commission) Gambling behaviour in England and Scotland: Findings from the Health Survey for England 2012 and Scottish Health Survey (According to either DSM-IV or PGSI) Ethnicity White: 0.4% (Odds ratio: 1, n=10132) Black/Black British: 2.5% (Odds ratio: 7.37, n=178) Asian/Asian British: 2.4% (Odds ratio: 5.02, n=452) Mixed: Other: 2.2% (Odds ratio: 6.86, n=136) Religion No religion: 0.5% (n=3626) Christian - Catholic: 0.6% (n=1846) Christian - other denominations: 0.3% (n=4787) Muslim: 0.8% (n=240) Any other religion: 3.4% (n=329) Gambling behaviour in England and Scotland: Findings from the Health Survey for England 2015 and Scottish Health Survey (According to either DSM-IV or PGSI) White: 0.7% (n=14013) Black/Black British: 1.0% (n=221) Asian/Asian British: 1.5% (n=458) Other: 3.3% (n=217) Gambling behaviour in England and Scotland: Findings from the Health Survey for England 2016 and Scottish Health Survey (According to either DSM-IV or PGSI) White: 0.6% (n=9850) Black/Black British: 2.8% (n=188) Asian/Asian British: 0.4% (n=462) Other: 1.2% (n=191) YouGov Online 2020 Gambling among adults from Black, Asian and Minority Ethnic communities: a secondary data analysis of the Gambling Treatment and Support study White Low-risk harm: 7.2% + Moderate-risk harm: 3.0% + Gambling disorder harm: 2.2% = 12.4% Black, Asian and Minority Ethnic Low-risk harm: 7.6% + Moderate-risk harm: 5.6% + Gambling disorder harm: 7.2% = 20.2% In summary, odds ratios are available from BGPS 2007, BGPS 2010, and Health Survey 2012 and are the following for minority ethnic groups: 0.60, 1.72, 2.86, 3.06, 3.55, 3.80, 5.02, 6.86, 7.37. Mean, μ:3.87. Standard Deviation, σ: 2.09. Median = 3.55. Hence, we estimate that ethnic minority populations are between 3 to 5 times more likely to suffer from a gambling disorder relative to white populations. Black, Asian, and other ethnic minority populations account for 12% of England and Wales's population. However, according to previously existing odds ratio analysis in three studies, Black, Asian, and other ethnic minority populations account for 31% (BGPS 2007), 17% (BGPS 2010), and 47% (NHS Survey 2012) of all individuals in the population with gambling disorder. As well as the effect of small sample sizes, these estimates are likely to be affected by cultural stigma, pride, mental health, health awareness, and other factors related to health inequality that may impact ethnic minority populations differently. Factors towards gambling 'Coping', 'Recreation' & 'Money' The British Gambling Prevalence Survey in 2010 is the only study in Britain to have explored the different factors that motivate an individual to gamble. In this research, significant differences were seen between ethnic minority and White groups, and particularly on the factors of ‘coping,’ ‘recreation,’ and ‘money.’ The ethnic minority groups identified coping as a motivator more strongly than the low-risk harm group and White ethnic groups Coping no gambling-harm: -0.07 White/White British: 0.01 low-risk harm: 0.29 Asian/Asian British: 0.44 Black/Black British: 0.52 Other ethnic groups: 0.54 moderate-risk harm: 1.32 gambling disorder harm: 2.40 Asian and Black groups were less motivated towards gambling for recreation purposes relative to other groups Recreation Asian/Asian British: -0.13 Black/Black British: -0.15 no gambling-harm: 0.06 White/White British: 0.12 Other ethnic groups: 0.14 low-risk harm: 0.41 moderate-risk harm: 0.51 gambling disorder harm: 0.51 Black groups were more likely to be motivated towards gambling to make money or gambling for the chance of winning big money when compared to others Money Other ethnic groups: -0.15 low-risk harm: 0.16 no gambling-harm: 0.17 White/White British: 0.17 moderate-risk harm: 0.17 Asian/Asian British: 0.22 gambling disorder harm: 0.34 gambling disorder harm: 0.34 Black/Black British: 0.53 As well as differences in attitudes, there are other factors such as the locations of betting shops, that lead to a disproportionately negative effect of gambling harm in ethnic minority communities. Betting shops in England and Wales are in postcode districts where the population is on average, disproportionately composed of individuals from minority ethnic groups. In postcode districts where there are 10 or more betting shops, the population is even more disproportionately composed of all minority ethnic groups except for those under other. Furthermore, the locations of 6518 betting shops in England are overwhelmingly in deprived areas, according to 2019 Office for National Statistics Deprivation data. Other factors (odds ratios) Qualitative perspectives from the GambleAware/Clearview Research study Cultural stigma “... in our culture or community, gambling has a bad reputation, and so if you gamble, you have a bad name.” “... yeah, our community is harsh… people have harsh opinions about people… so if you are doing anything that is seen as bad, you are seen are bad.” “Yeah, people don’t speak a thing about gambling.” “All the bookies are in the hood, and you see a lot of yardies (translation: Jamaicans) in them.” Health awareness “…like on the packages, it says smoking kills, so you know what you are getting into, but I don’t see anything like that with gambling at all.” “Oh yeah, it’s treated different; even when it becomes a problem - for white people, it’s like ‘they need help’ whereas, for us, it’s treated like it’s a sickness.” “Black and Asian communities they are more strict about gambling, and they think it’s a mental illness.” Getting help None of the 65 participants confidently knew where to get help. One participant whose gambling had become a problem stated that “No, I didn’t know at all… my mental health suffered, I was in 15 grand of debt… I was in a bad place, man.” Nearly nine in 10 (89%) participants said there is a difference between how gambling is seen in ethnic and white cultures. Reasons for gambling “I feel like Black people see gambling as a glimpse of a way out, but for white people, it just for bants.” “White people go into the bookies for banter, whereas people from my culture go to actually make money.” Conclusions Gambling harm is more prevalent and is likely to have a worse impact on those from a minority ethnic background, and this is in part due to differences in cultural attitudes, stigma, and health awareness Furthermore, this is worsened by betting shops being overwhelmingly crammed into areas where there are higher percentages of ethnic minority individuals and in areas of deprivation We estimate that ethnic minority populations are between 3 to 5 times more likely to suffer from a gambling disorder relative to white populations Education professionals and treatment providers should look to rapidly develop and expand consideration for gambling harm in ethnic minority communities At present, gambling harm is a neglected race and equality issue that has and is likely to further inequalities Appendix Map of betting shops in GB Define vulnerable person The Commission does not seek to define ‘vulnerable persons,’ but it does, for regulatory purposes, assume that this group includes people who gamble more than they want to, people who gamble beyond their means and, people who may not be able to make informed or balanced decisions about gambling due to, for example, mental health, a learning disability, or substance misuse relating to alcohol or drugs "If you are targeting vulnerable people, who will become addicted, then it is immoral." - Young BAME perspective