Dr Steve Sharman and Professor John Turner – Written evidence (GAM0037)

 

About the authors

Dr Steve Sharman is a Research Fellow at the University of East London. He is a specialises in gambling research and is an academic fellow of the Society for the Study of Addiction. Steve works closely with the National Problem Gambling Clinic in London, and with the Gordon Moody Association. He was recently on the organising committee for the first Current Advances in Gambling Research conference in the UK, and has received funding from the SSA, NIHR, internal UEL funding and GambleAware.

Professor John Turner is a founding member of the Drugs and Addictions Research group in the School of Psychology at the University of East London, with over 25 years’ experience of research and teaching in this field. Recent and continuing research collaborations with the National Problem Gambling Clinic and Gordon Moody Association, and education links to charities including the Young Gamblers Education trust (YGAM) and BetKnowMore. Research funding received from National Institute on Abuse (NIDA-NIH, US), Cancer Research UK, Office for Students, Society for Study of Addictions and GambleAware.

Opinions expressed are those of the authors and are not necessarily representative of the University of East London, or of the bodies funding any of the authors work.

 

Answers to specific questions posed by the select committee

(NC = No Comment)

 

The Gambling Act

Are the three primary aims of the Gambling Act 2005 (to prevent gambling from being a source of crime or disorder, to ensure that gambling is conducted in a fair and open way, and to protect children and other vulnerable persons from being harmed or exploited by gambling) being upheld?

  1. In relation to aim one, to prevent gambling from being a source of crime and disorder, there are different types of crime associated with gambling, from financially motivated crimes committed by gamblers to generate income for continued gambling, to crimes committed against operators such as criminal damage, or gambling related crimes such as courtsiding. Therefore, it should be recognised that gambling related crime/disorder is hard to quantify, and any evaluation depends on the parameters set for these measures. The same limitation applies to aim three, to protect children and other vulnerable persons; for example, our research has suggested increased violence and domestic harm associated with gambling (Roberts et al, 2016[1]; 2019[2]), but it’s not clear that such links would be detected within normal crime / harm analysis. It is therefore currently unclear if the key aims are being upheld.

What changes, if any, are required to bring the Act up to date with new technology and the latest knowledge about how gambling harm is distributed?

  1. Our recent data looking at trends in treatment seeking gamblers suggests steep increases in online gambling as a clear preference for problematic behaviour, highlighting the significance of technology. Those seeking treatment show an increasing use of the internet to access different forms of gambling (Sharman et al, 2019[3]). The Act needs to ensure detailed analysis of online provision is undertaken and legislation to parallel on site gambling policy drafted as a priority, especially for products which are similar or near similar to land-based products.
  2. There are types of gambling, such as crytopcurrencies and blockchain gambling (Scholten et al 2019)[4] that were not even in existence when the Act was brought into force. These types of gambling are therefore operating in an almost completely unregulated fashion. It is essential that any new legislation includes these newer types of gambling and retains the flexibility to evolve and to keep pace with the ever changing and developing gambling industry. 

Is gambling well regulated, including the licensing regime for both on- and off-shore operations? How successfully do the Gambling Commission, local authorities and others enforce licensing conditions including age verification? What might be learned from comparisons with other regulators and jurisdictions?

  1. See 2 above

Should gambling operators have a legal duty of care to their customers?

  1. Given the nature of gambling products are fundamental to gambling behaviour, and that certain products are over represented amongst those with problems (again see Sharman et al, 2019, and the rise of use of online products, poker and FOBTs), it is clear that operators have a legal duty to care for customers, at the very least in terms of the nature of the products they provide and restrictions/controls for such products

 

Social and economic impact

What are the social and economic costs of gambling? These might include costs associated with poor health and hospital inpatient services; welfare and employment costs; the cost of benefit claims; lost tax receipts; housing costs through statutory homelessness applications; and criminal justice costs.

  1. Homelessness can have a significant social and economic cost. Our previous research has indicated that gambling can often act as a contributary factor in the cycle of homelessness. Gambling problems were more commonly identified in a homeless population in comparison to the general population (Sharman et al, 2015[5]). Further research indicates that gambling is more commonly a cause of homelessness, however in some cases the individual only developed problems after becoming homeless (Sharman et al[6]). In all cases, gambling contributes to the continued cycle of being trapped in homelessness. There are also a number of hidden costs to gambling in relation to poor health and hospital service use (see again Roberts, 2016; 2019)

What are the social and economic benefits of gambling? How can they be measured and assessed?

  1. NC

 

Levy

Is the money raised by the levy adequate to meet the current needs for research, education and treatment? How effective is the voluntary levy? Would a mandatory levy or other alternative arrangement be more productive and effective? How should income raised by a levy be spent, and how should the outcome be monitored? What might be learned from international comparisons?

  1. We do not wish to comment on every component of this question, only the components referencing the effectiveness of the voluntary levy, and alternative arrangements. The current arrangement regarding the voluntary levy is not adequate. The gambling industry should not be able to exert any influence over how funds generated through the levy are used or distributed, either through official representation on boards, groups, and commissions, or through unofficial channels were pressure can be exerted.

 

  1. Whilst the levy remains voluntary, there is the potential for contributions to be reduced, or even terminated. A large proportion of treatment services in the UK rely on money generated from the voluntary levy; withdrawal of support would provoke a crisis amongst those individuals utilising support services. Everyone involved in the legislation and regulation of gambling, from the RGSB to GambleAware to the Gambling Commission knows this and knows this situation must be avoided at all costs. Therefore, whilst the capacity to reduce or withhold donations remains within the grasp of the gambling industry, the threat to services remains. Whilst the gambling industry holds the purse strings that fund treatment, research and education, appropriate challenges to industry practices, and appropriate punishments for serious transgressions will not be made to the gambling industry.

 

  1. A mandatory levy would reduce the potential for contributions to be reduced or withheld. Changing the levy from voluntary to mandatory would entirely shift the balance of power within the legislative environment, taking power out of the hands of the gambling industry, and placing it within the grasp of the legislators and regulators.

 

  1. A mandatory levy would also ensure that all operators are contributing to research, education and treatment. It has been well reported that certain operators make a tokenistic contribution, whilst other operators contribute more than the recommended amount. A mandatory contribution of a specified percentage of profit would ensure all operators contribute appropriately. This would raise funds for research and support well beyond that already available, and from a funding body completely independent from industry.

 

  1. For international comparison, the UK could follow the model in New Zealand, where harm reduction is a legislative requirement, generating a budget of over $NZ18m, equivalent to over £9m. This funding is used to combat gambling related harm in a population of 4.7million. In the UK, for a population of over 65 million, the voluntary levy in 2017-18 raised approximately £8m for research, education and treatment. The NZ model clearly emphasises how a mandatory levy, over a voluntary levy, is able to generate fund sufficient to adequately address the research, education and treatment needs for gambling related harm (Wardle et al, 2019[7]).

 

Research

How might we improve the quality and timeliness of research in the UK? What changes, if any, should be made to the current arrangements for funding, commissioning and evaluating research in the UK? What might be learned from international comparisons?

  1. Please see the points above in relation to a levy. The funds raised by a NZ style levy, in addition to supporting treatment provision, would significantly invigorate and expand the capacity for high quality and timely research in gambling, specifically the unique context of UK gambling

 

  1. Although not directly addressing the question, we feel that a major problem with the current arrangement for funding and commissioning research in the UK is the narrative used to promote the concept of ‘responsible gambling’. This construct not only removes all responsibility from the operators and places all responsibility squarely on the shoulders of the individual, it also implies that those experiencing gambling related harm are somehow irresponsible, thus increasing feelings and perceptions of shame and embarrassment, and reinforcing stigma. This in turn reduces the willingness of the gambler to seek support prior to reaching crisis point.

 

  1. Furthermore, the term ‘responsible gambling’ has evolved, and is still evolving, to shift responsibility away from the operator and onto the individual. The term has evolved from ‘responsible provision of gambling’, which places the onus on the operator, to responsible gambling, to gamble responsibly, which places the onus on the gambler. More recently, adverts have been played on the radio for the national lottery that encourage gamblers to ‘play responsibly’. Therefore, issues around the language used, and where the burden of responsibility is placed, need to be considered and addressed.

If, as the Responsible Gambling Strategy Board (RGSB)1 has suggested, there is limited evidence on which to base sound decisions about gambling by children and young people, what steps should be taken to rectify this situation?

  1. NC

Education

Is enough being done to provide effective public education about gambling? If not, what more should be done?

  1. NC

 

Treatment

Are the services available for the treatment and support of people at risk of being harmed by gambling sufficient and effective? How might they be improved? What steps might be taken to improve the uptake of treatment, particularly among groups who are most likely to experience harm from gambling and least likely to seek help?

  1. Treatment could be expanded substantially via the changes to levies as suggested above – current provision relies too heavily on funding that is directly or (only minimally) indirectly linked to industry (notably via GambleAware). A new expanded and enforced levy system would allow for the provision of greater capital for treatment and research and would be completely free from industry influence.

What steps should be taken better to understand any link between suicide and gambling?

  1. In a paper we are about to submit for publication, we analysed factors the predict suicide attempts in treatment seeking gamblers. Results indicate that factors contributing to the collapse of an individual’s social and support network, including partners, friends and family, are significant predictors of suicide attempts. Furthermore, analysis also indicates that gamblers who gamble on FOBTs are more likely to attempt suicide than those who do not gamble on FOBTs (Sharman et al, 2019)[8]. Therefore, it is suggested that gamblers are not treated as a homogenous group, rather the circumstance of the individual and the types of gambling engaged in should be considered as these may offer an earlier indication of suicidal ideation. 

 

Advertising

The RGSB has said that by not taking action to limit the exposure of young people to gambling advertising “we are in danger of inadvertently conducting an uncontrolled social experiment on today’s youth, the outcome of which is uncertain but could be significant.” 2 Do you agree? How should we make decisions about the regulation of gambling advertising? What might be learned from international comparisons?

  1. Much has been made in the UK media regarding the proliferation of gambling advertising. In anticipation of potentially more restrictive legislation, the gambling operators proposed a whistle to whistle ban on advertising during live sport before the watershed. Whilst on the surface this move may seem motivated by a genuine desire to reduce the number of gambling adverts seen by children, TV adverts and voluntary regulation distract from the proliferation of other forms of advertising. Gambling companies sponsor over 60% of teams in the top two divisions of football in England, and many more have gambling partners. During the live game, advertising on pitchside hoardings and sponsors on shirts ensure gambling company logos and marketing are often on the screen. Additionally, operators are spending more money on online marketing than TV advertising, where messages can be tailored to the individual. However due to the focus remaining on TV adverts, little attention has been paid to the regulation of online marketing. Therefore, we suggest that the legislative and regulatory interest in TV advertising should not be at the expense of other forms of direct and indirect advertising.

 

  1. In a recent study, we analysed the proportion of pages in matchday programmes for premier league and championship matches that contained gambling adverts and incidental exposure and found that gambling marketing was found on over 20% of pages. When examining the child specific sections of programmes, over 50% had gambling marketing exposure (Sharman et al, 2019)[9]. Therefore, we agree with the RGSB assertion that we are in danger of conducting an uncontrolled social experiment on today’s youth, and that more effective legislation needs to be put in place to protect children from consistent over exposure to gambling marketing. 

 

Gambling and Sport

Gambling is becoming an integral part of a growing number of sports, with increasingly close relationships between operators and sports clubs, leagues and broadcasters. What are the risks attached to this?

  1. NC

 

Gambling by young people and children

How are new forms of technology, including social media, affecting children’s experiences of gambling? How are these experiences affecting gambling behaviour now, and how might they affect behaviour in the future?

  1. Children are exposed to gambling like experiences, even when these behaviours are not directly labelled as gambling. These are apparent in ‘freemium’ games, betting within computer games, social casino play, and as highlighted in the media, loot boxes. Many of these behaviours are linked with disordered gambling and are freely available to children. I would refer the committee to the excellent work of David Zendle and colleagues[10]

The legal availability of certain forms of commercial gambling to under-18s in Great Britain is unusual by international standards and has been described as an ‘historical accident’. 3 Should young people between 16 and 18 be able to purchase National Lottery products, including draw-based games, scratch cards and online instant wins?

  1. We recently published a study examining the age of gambling onset and associated subsequent behaviour. Analysis reveals that in general, those who started gambling at a younger age were likely to experience more negative life events, and more severe gambling problems (Sharman et al, 2019)[11]. The take-home message from this study was that the younger an individual starts gambling, the worse gambling associated harm can become. Therefore, would argue that no forms of gambling should be available, either online or land-based, to any individual under the age of 18.

Should children be allowed to play Category D games machines (which include fruit machines, pushers and cranes)?

  1. Please see previous answer

Lotteries

The restrictions on society lotteries were relaxed by the Gambling Act 2005, and there is concern that some of them are effectively being taken over by larger commercial lotteries. Is this concern well founded? If so, what should be done?

  1. NC

Should changes be made to the statutory regime governing the National Lottery, to bring it into line with the regime governing operators of other lotteries?

  1. NC

 

6 September 2019


[1] Roberts, A., Coid, J., King, R., Murphy, R., Turner, J., BowdenJones, H., ... & Landon, J. (2016). Gambling and violence in a nationally representative sample of UK men. Addiction, 111(12), 2196-2207.

[2] Roberts, A., Sharman, S., Landon, J., Cowlishaw, S., Murphy, R., Meleck, S., & Bowden-Jones, H. (2019). Intimate Partner Violence in Treatment Seeking Problem Gamblers. Journal of Family Violence, 1-8.

[3] Sharman, S., Murphy, R., Turner, J. J., & Roberts, A. (2019). Trends and patterns in UK treatment seeking gamblers: 2000–2015. Addictive behaviors, 89, 51-56.

[4] Scholten, O. J., Hughes, N. G. J., Deterding, C. S., Drachen, A., Walker, J. A., & Zendle, D. I. (2019, August). Ethereum Crypto-Games: Mechanics, Prevalence and Gambling Similarities. In CHI PLAY 2019. ACM.

[5] Sharman, S., Dreyer, J., Aitken, M., Clark, L., & Bowden-Jones, H. (2015). Rates of problematic gambling in a British homeless sample: A preliminary study. Journal of Gambling Studies, 31(2), 525-532.

[6] Sharman, S., Dreyer, J., Clark, L., & Bowden-Jones, H. (2016). Down and out in London: addictive behaviors in homelessness. Journal of behavioral addictions, 5(2), 318-324.

[7] Wardle, H., Reith, G., Langham, E., & Rogers, R. D. (2019). Gambling and public health: we need policy action to prevent harm. BMJ, 365, l1807.

[8] Sharman, S., Murphy, R., Turner, J. J., & Roberts, A. (2019). Predictors of suicide attempts in UK treatment seeking gamblers. Manuscript in preparation

[9] Sharman, S., Ferreira, C. A., & Newall, P.W.S. (2019) Exposure to Gambling and Alcohol Marketing in Soccer Matchday Programmes (Under review)

[10]Zendle, D. (2019, September 4). Gambling-like video game practices: Links with problem gambling and disordered gaming in a nationally representative sample. https://doi.org/10.31234/osf.io/fh3vx  https://psyarxiv.com/fh3vx

[11] Sharman, S., Murphy, R., Turner, J., & Roberts, A. (2019). Psychosocial correlates in treatment seeking gamblers: Differences in early age onset gamblers vs later age onset gamblers. Addictive behaviors, 97, 20-26.