bet365 response to the DCMS Select Committee Call for Evidence

Introduction

1.1 bet365 is grateful to the DCMS Select Committee for providing an opportunity for us to submit evidence to your inquiry on gambling regulation. We are responding to set out clearly our views on gambling harm and the action taken by bet365 to promote safer gambling.

1.2 The Committee’s inquiry comes at an important time for the industry: the Government has said it is finalising its review of gambling legislation and will publish a White Paper shortly. bet365 has welcomed the review from the outset as an important opportunity to review the way the gambling industry is regulated in the UK, and we have sought to engage constructively with policymakers throughout this process. We are keen that proposals are announced as soon as possible to provide certainty to customers and the gambling industry, and to allow us to focus on implementing an ambitious set of reforms to reduce gambling-related harm.

Background to bet365

2.1 bet365 is a private, family-owned company which was founded in Stoke-on-Trent in 2000. We are now one of the world’s largest online sports betting companies, licensed in 22 different jurisdictions and employing almost 5,800 staff in the UK. bet365 and our founders are the second highest taxpayers in the UK with £493.1m paid in 2021/22.

2.2 The gambling industry more broadly is a major contributor to UK prosperity. In total, the regulated betting and gaming sector supports 110,000 jobs, contributes £7.1bn to the economy and generates £4.2bn in taxes for the Treasury annually. The jobs provided by the sector include many highly skilled tech jobs and are in regions of the country that have been traditionally lacking in such opportunities, such as the West Midlands.

2.3 bet365 Group owns Stoke City Football Club (SCFC). Our investment and contribution has allowed the club to support fans by freezing season ticket prices for 15 years, providing free away travel and supporting women’s football both in the club and local area.

2.4 Stoke City FC supports the local community through the SCFC Community Trust which aims to engage with and benefit the lives of approximately 150,000 children and young people each year through its activities. This includes on sports participation, education, health and wellbeing.

2.5 Last year, we contributed £100m to the Denise Coates Foundation, bringing total donations received to date to £631.7m. Examples of projects funded through the Foundation include funding for The University Hospitals North Midlands Charity to fully fund a significant upgrade of the cancer treatment facilities at the Hospital and a donation towards humanitarian relief in Ukraine through the Disasters Emergency Committee, as well as a range of other projects across education, arts and community development.

bet365’s approach to player protection

3.1 The vast majority of people who gamble today enjoy doing so without experiencing harm: the Gambling Commission’s latest participation and problem gambling statistics show the overall problem gambling rate has fallen to 0.3%[1]. While this is a step in the right direction, we are not complacent and continue to consider new and innovative ways to protect customers.

3.2 Progress has not halted while we await the White Paper. bet365 has worked independently and with other BGC members to bring forward voluntary initiatives where it is clear improvements to player safety can be made. This includes changes to online product design, the whistle-to-whistle ban on television advertising around football matches and strengthening the industry advertising code, the IGRG [2], to ensure paid-for social media adverts are targeted at those aged over 25 unless age accuracy can be proven for 18+.

3.3 We continue to be a significant contributor towards funding Research, Education and Treatment (RET) and take our responsibility to contributing our fair share seriously. In 2022/23 we will have contributed 0.75% Gross Gambling Yield (GGY) towards RET, rising to 1% GGY thereafter. We have no say over how these funds are used, with the vast majority of our funding going to GambleAware to use as they see fit in support of their commissioning activities.

3.4 We have also engaged constructively with the Gambling Commission and DCMS on our vision of an evidence-based, proportionate outcome to the issues identified in the Gambling Act Review based on our own experiences.

3.5 As a responsible business, protecting customers is a top priority for bet365 and we have consistently been at the forefront of industry efforts to reduce risks and intervene when there are signs of individual harm. Our Early Risk Detection System monitors customer activity for behaviours that may indicate the customer is at risk of or experiencing harm. We use this to tailor our interventions to individual customers.

3.6 On affordability, we have taken voluntary action ahead of the White Paper to introduce default net deposit limits for new customers, after which documentary evidence is required. From our experience, we have found obtaining documentary evidence from customers a significant challenge. We support efforts by DCMS to consider other available options and look forward to working constructively on a way forward in the coming months.

3.7 We also go to great lengths to utilise the most innovative advertising technology available in order to target our adverts away from inappropriate audiences, both in terms of age and vulnerability (such as those registered as self-excluded from gambling). This has included working with platforms such as Twitter to develop their do-not-reach-list functionality [3]. This was a significant change that allowed us to prevent self-excluded customers of bet365 being targeted with our ads.

Perspectives on White Paper measures

4.1 bet365 has welcomed the Government’s review from the outset as an important opportunity to look closely at how industry and regulation have developed since the Gambling Act was introduced, and to find ways to reduce gambling-related harm.

4.2 We have been proactive in supporting DCMS and the Gambling Commission to explore potential solutions, including contributing our vision for an effective affordability framework that balances the need to protect those at-risk with the interests of the vast majority of people who gamble without experiencing harm.

4.3 We continue to advocate for the review to be evidence-led and reflect the benefits of the gambling industry: individual value from enjoyment of gambling as a leisure activity (almost half of adults gambled in the year to September 2022 [4]) and the valuable jobs and tax revenues that the sector delivers.

4.4 A successful review will balance these interests. While we cannot pre-empt the outcome of the review, we would note the following areas of importance:

4.4.1 The former Gambling Minister’s speech at this year’s BGC AGM represented a step change in the way the industry will assess a customer’s ability to gamble affordably. We welcome the emphasis on this process being ‘frictionless’ and based on ‘financial risk’ and hope that this can avoid making millions of people hand over personal information when gambling at relatively low levels.

4.4.2 We agree with the comments of the former Minister that such checks must be tried and tested before they are implemented and stand ready to support this process. We know from our own experience that only a small minority of customers will ever share financial information on request, and it is essential we get this right to avoid driving players into the black market.

4.4.3 The same is the case for stake limits on online slots. In the online environment, operators have access to information on a customer’s activity which can allow an assessment to be made to support a tailored solution. Coupled with an effective affordability framework, customers who can afford to stake at higher levels should not be constrained by arbitrary limits at low levels.

4.4.4 As noted, we are committed to providing 1% of GGY towards RET to be spent independently by GambleAware and others on the approved RET list. We believe that all operators should make a meaningful contribution to funding RET to tackle the underlying causes of gambling harm and its treatment where it occurs.

Concluding remarks

5.1 We believe that now is the time to focus on implementation of the proposals that have been developed to reduce problem gambling further. Publication of the White Paper is an important first step to delivering a stable regulatory regime from which we can plan for the future.