Regulus Partners, the strategic consultancy focused on international gambling and related industries, takes a look at some key developments for the gambling industry in its ‘Winning Post’ column.
UK: Problem Gambling Rate Declines – That’s Good, Right?
Good things it appears, do come to those who wait. GB Gambling Commission executives have made much in recent times of the need to get problem gambling rates down – and according to the publication this morning of the gambling section of the 2016 Health Survey, this wish has been granted (in part).
The headline rate (adult population level) of problem gambling declined slightly from 0.8% to 0.7% while at-risk scores fell from 3.9% to 3.5% (with the entirety of the decline falling within the low-risk category). Problem gambling amongst those who gamble also edged down – from 1.4% in 2015 to 1.2% in 2016.
These are not perhaps particularly significant movements – they fall within the bounds of the previous five major surveys and may well reverse in the next one, such is the nature of things. Some may argue that any rate of problem gambling above zero is too high. However, it is the regulatory establishment (rather than operators) that has selected the national problem gambling rate as the barometer of the industry’s health and so on that basis, the figures ought to be welcomed (cautiously).
Across most of the product verticals, problem gambling rates remained broadly in line with previous years. Online sports betting (a matter of considerable controversy due to advertising) was reported to have a 2.5% problem gambling rate; only lottery products have lower rates. While this was less than half the level recorded in 2015 (when it was a middle-of-the-pack 5.4%), it is fairly consistent with previous recorded rates (which had fallen within the 3% to 6% range).
Problem gambling rates for online casino remain relatively high at 9.2% but were at least lower than in 2015 (10.6%). The problem gambling rate for FOBTs ratcheted up to 13.7% (from 11.2% in 2015), despite all the ABB’s harm prevention measures – giving further cover to the Government on stake reduction and providing an important nuance to overall figures.
The latest data-set will keep the spin doctors, scribblers, activists and policy nerds busy – but it is debatable how much of this is practically useful from a harm prevention perspective. Problem gambling diagnosis is an imperfect and somewhat arbitrary process – particularly when applied to large survey populations. It may show correlation between gambling behaviour, cognitions and effects but is reliant on honesty and accuracy of recall on behalf of the individual; and it is silent on cause. When taken down to individual product level, the sample sizes involved can be very small indeed.
Moreover, when we reflect on problem gambling rates, it is important to bear in mind exactly what is being measured. As Howard Shaffer of Harvard Medical School memorably wrote (in 2001): “One of the primary concerns about DSM-IV [one of the two problem gambling screens used within the Health Survey] centres on how it has advanced the reliability of psychiatric diagnosis at the cost of diagnostic validity. That is, different clinicians – or the same clinician on different occasions – can use DSM-IV criteria evaluate the presence of mental disorders with consistency; but the underlying nature of these disorders remains uncertain.”
Interpretation of prevalence survey data is often stretched to fit dogma rather than to understand what is going on. Two particularly egregious examples are the tendency amongst the pro-gambling lobby to ignore moderate risk levels; and the public health lobby’s misuse of low-risk levels to promote alarm.
In due course, problem gambling prevalence rates will come to be supplemented by harm reporting. This represents a new level of sophistication in terms of how we consider the social and economic costs of gambling (sadly, interest in the consumer benefits side of the ledger remains largely non-existent). What is not clear is whether the ability of those engaged (on all sides) in public policy discourse to interpret such data with nuance and objectivity will also evolve.
UK: in Parliament – Crouch End to Waiting on FOBTs?
The FOBT saga, which has had more twists to its tale than Peppa Pig, popped out yet another kink this week as the gambling minister, Tracey Crouch suggested that the reduction in maximum stake from £100 to £2 could take place next year, with legislation hopefully introduced ‘this quarter’ and further details possibly revealed at the November budget (contradictory on a calendar view but indicative of a window nevertheless).
Speaking at the FOBT APPG, Crouch hinted that the Government may split the difference between anti-FOBT campaigners and the bookmaking sector by implementing the change in autumn 2019 – six months earlier than press reports had indicated.
Of course, one of the few certainties about the Government’s approach to gambling policy is that there are few certainties – and there is many a blip between bet and slip. The minister’s willingness to appear before the APPG did at least indicate that the Government may at last be ready to make a decision and so give the LBO sector some visibility about when they – and the industry at large – might draw a line under this acrimonious and damaging episode.
Fresh from his appearance at the APPG, Ronnie Cowan (SNP, Inverclyde) had hoped to put the new Culture Secretary, Jeremy Wright on the spot on the question of “what steps his department is taking to tackle gambling-related crime”. If Cowan had hoped to stimulate a debate about Government policy, he was left frustrated. Parliamentary interest in the question of broadband coverage across the UK dominated proceedings and timed out the opportunity for (yet another) discussion of gambling policy on the green benches.
Tracey Crouch MP did subsequently make a written response, highlighting the Government’s pending action on FOBTs as well as modest sabre-rattling on remote gambling regulations – but this is unlikely to have given concerned parliamentarians much in the way of comfort.
In the upper chamber, attention turned (as it has so often amongst peers in the past two years) to the question of harm to children from gambling. The Liberal Democrat Lord Storey submitted a Parliamentary Question, asking what the Government was doing “to prevent children and young people becoming addicted to gambling”.
Also in the Lords, the Government cited its proposed action on FOBTs as part of an overall approach to tackle levels of household debt in Great Britain (a somewhat marginal measure perhaps given participation rates). Meanwhile in the Commons, the remote gambling sector was cited by the Government as a positive example in a debate over the control of bladed weapons (as I learned long ago, we must take our compliments where we find them).
Next week, the attention is expected to shift to the remote sector as the bookie-bashing Bishop of St Albans, the Rev Alan Smith will lead a debate on this increasingly vexed subject of gambling advertising. Given Tracey Crouch’s highly defensive response this week to a pre-recess PQ on gambling ads from her opposite number, Dr Rosena Allin-Khan (Lab, Tooting) it seems unlikely that the noble prelate’s prayers will be answered.
UK: machines in pubs – making up like bandits…
In late August, UK pub group JD Wetherspoon had an application for a fifth AWP at its Perry Bar Birmingham pub turned down. Under local licensing rules, the provision of up to four machines is licensed by individual council members, but subsequent machine license applications have to go before a council committee. The committee rejected the proposal, citing a number of objections, centred on lack of vulnerable player protection. What is interesting (or alarming depending on your point of view) is the comments from councillors used to justify their stance including:
‘I am not happy with it. Too many [machines] are being put into places like these and they are ending up becoming amusement arcades with drinking licenses’
‘I know people who are addicted to these things, they try and sit in a pub where they are away from them, but they are everywhere’
‘You can’t sit somewhere without something flashing in your eyes’
‘You walk into them, I don’t know how people with Epilepsy cope’
‘They entice people in with cheap beer, and make the money back on the bandits’
The application was unsurprisingly rejected based on the sentiment of the committee’s comments, but few if any facts were presented to back up the many claims and concerns. The overriding concern centred on controlling access for minors, yet ignored the fact that the four machines currently licensed operate under the same conditions with the same controls (regardless of their adequacy).
The latest results from JDW saw a long running decline in machines income turned into an H1 increase of 4.6%, though with machine revenue at just 2.5% of overall sales (still a £42m annual gaming revenue position). It is not clear whether JDW will appeal the decision, however, the case brings into focus the lack of evidence based decision making and highly subjective nature of the local licensing process of machines, mirroring the increasingly politicised and negative process of developing gambling regulation being seen in several other sectors and markets.
UK: Gambling sponsorship in football – clubs score own goals as NHS mis-fires?
A BBC investigation has revealed that 15 English and Scottish football clubs (all with gambling companies as shirt sponsors) featured betting operator logos or links to gambling sites on pages of their websites aimed at junior supporters. The ASA has demanded immediate action, and the Gambling Commission and the Children’s Commissioner have expressed their surprise and dismay. Three of the clubs have immediately removed adverts from the pages in question, and the EFL has instructed all clubs with betting partners to remove logos from web pages aimed at minors.
This is an example of another entirely avoidable own-goal (we are reminded of Newcastle United’s under-18 kit featuring the Fun88 logo) by football clubs on gambling-related matters. It also comes in the same week in which the head of the NHS has called on Premier League clubs to do more to ensure gambling operators do “the right thing” in co-funding RET, amid reports that a number of the overseas operators which sponsor football clubs in GB have not so contributed. This raises an interesting wider question about funding for RET, in our view, while we are not sure that football clubs (while they clearly have a CSR-type role to play) are the right target for criticism regarding RET funding arrangements.
Operators which sponsor English and Scottish football clubs must first be licensed by the Gambling Commission, and therefore are required to contribute to RET funding under the LCCP. If that is not happening, then it is a matter for the regulator to enforce. While GambleAware has used this as an opportunity to call on all stakeholders to help fund treatment, the LCCP does not require contributions to a specific charity, nor does it set a specific amount (or minimum threshold) to contribute. One might also question where such contributions should be directed for operators not active in (other than marketing from) GB; this might be in Asia if the purpose is to fund services required as a result of negative externalities, or in GB if it is simply a cost of being a licensee or intended to address harm caused by advertising (the available evidence suggests modest effects).
Whatever the answer to those structural and philosophical questions, we suggest that this investigation highlights the flaws in the system rather than provide more bullets to legitimately fire at operators or external stakeholders such as football clubs (save for their (surely) cock-ups rather than conspiracies over gambling logos). A good starting point to addressing these flaws might be to clarify whether the system is voluntary or mandatory, when it appears that some are trying to make it both.