GVC Holdings Plc – Written evidence (GAM0042)


  1. We are pleased to respond to the House of Lords Select Committee’s inquiry on the social and economic impact of the gambling industry. We would like to thank the House of Lords for allowing us the opportunity to set out our new measures in the area of safer gambling.


  1. We support the submission from the Betting and Gaming Council (BGC) and provide this submission to highlight the additional work GVC is contributing to in the area of safer gambling, through our industry leading ‘Changing for the Bettor’, global safer gambling strategy.


About GVC

  1. GVC is one of the world’s largest sports-betting and gaming groups, operating both online and in the retail sector. We own two of the UK’s oldest and most well-known brands - Ladbrokes and Coral - and are one of the top 20 UK taxpayers. We employ over 15,000 colleagues in the UK, and welcome more customers each year than the National Trust has members. 


  1. Millions of customers around the world bet with us every year.  They like the excitement of a small flutter and the thrill of winning. Betting is an enjoyable, sociable and memorable way to spend time; that's why it continues to be so popular. Our hardworking staff, ensure that community based service remains a long standing tradition in the sector, and our contributions to the fantastic sports we support as an industry, such as racing, means they can thrive and continue to provide entertainment for people from all walks of life.


  1. However, unfortunately, for a small percentage of people, gambling ceases to be entertainment and can cause personal, social, financial and health problems.


  1. It is our responsibility, as one of the largest betting operators, to help our customers gamble in a safe and responsible manner, reduce the risk of harm and help people who need treatment to get it.


  1. This is where our new global strategy, 'Changing for the Bettor' originates. Through this strategy, launched in January 2019, we are making safer gambling a non-negotiable cornerstone of the way we do business and we are fully committed to minimising gambling related harm.


Changing for the Bettor

  1. Problem gambling is a complex and multifaceted issue. In order to tackle this issue, we must adopt a holistic and comprehensive approach that is evidence led.


  1. The guiding principle of our safer gambling campaign is to be the most trusted and enjoyable betting operator in the world.  This is based around 7 pillars of action;

    1)      Understanding the problem and best solutions.

2)   Educating our key stakeholders.

3)   Promoting responsible attitudes.

4)   Empowering customers.

5)   Funding treatment for those in need.

6)   Championing responsible product design.

7)   Drive cultural change within our business.


  1. Behind each pillar are real, tangible measures we are taking, both internally as a company and externally, to expand our knowledge of the signs of problem gambling and create a safer betting environment for our customers.


  1. Our strategy has been independently reviewed by EPIC Risk Management with whom we have created a new partnership with. EPIC is the leading independent harm minimisation consultancy in the UK and Ireland, with a proven track record of minimising harms across the highest risk sectors including professional sport, financial services, the armed forces, the criminal justice system and education. GVC are working with EPIC in a committed long-term contract to drive culture change, review and improve processes and ensure sustainability and consumer protection in all channels.


  1. We support the BGC submission fully, however we would like to add some additional detail to the steps GVC individually is taking with regards to questions 7 – 14. Namely on the subjects of the levy, research, education, treatment, advertising and the relationship between gambling and sport.




Q7: 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. As an operator, we recognise that along with increased customer interaction, we need to ensure that support is available for those who need it. We recognise the need to invest more and that is why, in 2019, GVC doubled our donation to UK problem gambling Research, Education and Treatment from £2m to £4m a year - 0.1% to 0.2% of GGY. Furthermore, in April, GVC were the first operator to commit to increase this to 1% of GGY by 2022. Since then, GVC, working with the other big 4 operators, has led this call and the big 5 operators have now all committed to increase their RET donations to 1% by 2023. This will see a total of approximately £100 million donated over the next four years, and approximately £60 million annually thereafter.


  1. We are pleased that the industry is moving decisively to implement this increase to 1% of GGY voluntarily. The quickest means to put support in place is on a voluntary basis. Industry led initiatives enable a variety of approaches to be trialled to allow us to all learn more about how to tackle problem gambling in the quickest, most effective and most innovative manner with a range of partners.


  1. Whilst we will maintain our commitment to fund GambleAware in the UK, the rest of our donations will be spent on projects that fit with our guiding principles. These include, but are not limited to, projects with charities and organisations such as GamCare, YGAM, the Safer Online Gambling Group (SOGG) and EPIC Risk Management. We will also work with the Government and independent stakeholders that assess the need for additional provisions for treating problem gambling.




Q8. 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?

Q9. 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. We will answer Q8 and Q9 together. We believe that more research, in a variety of areas is needed to better understand the scale of problem gambling, and to identify the most effective way of reducing this. That is why key to underpinning our flagship Safer Gambling strategy, is a new partnership between GVC and Harvard University to produce cutting edge research on problem gambling.


  1. This 5-year partnership will see us invest $5 million with Harvard's specialised Division on Addiction, providing them with access to our anonymised data sets, for independent and robust scrutiny, and to evaluate the effectiveness of our current systems and procedures. From this Harvard will provide advice and suggest modifications on how these can be improved to identify and more quickly respond to customers at risk of harm.


  1. These data sets will also be open sourced so that other academics and research institutions can utilise them for similar purposes. We are keen to extend the benefits of this collaboration with the rest of the industry, sharing our learnings and knowledge from the partnership.


  1. In addition, we are also scoping a series of literature reviews and new research reports with Harvard on a variety of subject areas. Reviewing existing research pieces, along with learnings from international markets on best practice, will provide us with the knowledge to ensure our commercial decisions do not have unintended consequences that negatively affect vulnerable customers.




Q10. Is enough being done to provide effective public education about gambling? If not, what more should be done?


  1. We know that prevention is key to reducing the impact of gambling-related harm, and that is why we are investing in a variety of awareness and harm minimisation educational programmes in the UK. These include the following:


  1. Working with the charity GamCare: To fund a youth outreach programme nationwide – called the Big Deal. The project focuses on raising awareness among young people, and professionals working with young people, about the problems associated with gambling and the signs of harm. The pilot project delivered programmes to 2,500 young people, and was independently evaluated by LKMco, an education and youth ‘think and action-tank’. This found that 91% of those taking part in the sessions were able to spot the signs and symptoms of problem gambling by the end of the sessions. Our partnership will enable GamCare to expand this programme and roll it out nationally, delivering workshops to 8,000 young people and train 8,000 professionals.


  1. Developing and funding a new pilot project with EPIC Risk Management: To educate students in state-schools on the signs of problem gambling. EPIC Risk Management will lead a new state-school pilot initiative, working with schools and their students to raise awareness to prevent gambling related harm amongst young people. Using their lived experience, the aim is to present awareness raising and harm-minimisation education seminars to Years 9, 10 and 11 (ages 13-16) on the risks of problem gambling. This will be independently evaluated through a leading UK University before it is expanded.


  1. Supporting YGAM University Digital Champions Programme: GVC and YGAM are working together on a project that will see specially trained ‘digital champions’ in Universities throughout the UK, who will raise awareness of the risks around gambling. They will provide independent advice to those students who need support, and help them to build digital resilience at a time when they may be vulnerable whilst away from home.


  1. We want to ensure that when children turn 18, and can consider betting, they are making fully informed decisions about gambling, and they can recognise the signs of gambling getting out of control, whether amongst themselves or their friends and family.


  1. Driving and embedding cultural change within our business: We want to ensure that all colleagues in all teams have safer gambling at the forefront of their mind when making day to day decisions at work. We have introduced new mandatory colleague training on safer gambling measures, with specific modules and face-to face sessions for our customer facing teams. In addition, EPIC Risk Management are also advising us on the most appropriate language to use when talking to customers who shows signs of problem gambling.




Q11. 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. We believe that current treatment provision in the UK should be expanded. That is why we were the first operator to commit to increasing our donations to RET to 1% (by 2022), with the rest of the big 5 operators now all committing to this figure by 2023. As part of this agreement, representatives from the big 5 have asked Lord Chadlington, a vocal campaigner on safer gambling, to chair an independent committee that will recommend how best to administer funds committed to safer gambling initiatives, including the treatment of problem gambling. Membership of the committee will be announced in September 2019 and it will publish its recommendations before the end of the year.


  1. We are also pursuing additional avenues of support with external partners. GVC are funding a private treatment facility in Manchester - Leon House - which prioritises spaces for at-risk groups, such as armed forces personnel and blue light workers. The clinic is set up in partnership with Cognacity, who are one of the UK’s leading providers of private mental health services. All patients will receive an independent psychiatric assessment on referral and will be recommended a bespoke recovery and treatment plan to fit around their specific needs and lifestyle.


  1. We are also funding, and exclusively working with the Safer Online Gambling Group (SOGG) to support them in developing a digital therapy app. Using their expertise and lived experience, the SOGG are creating a digital therapy app as a new and innovative way of identifying potential problematic behaviour, resulting in earlier intervention. This new medium also provides a different type of support and ensures that if someone is seeking help, there are a variety of avenues they could take.


Q12. What steps should be taken better to understand any link between suicide and gambling?


  1. Suicide and self-harm are incredibly important issues and ones that as a business we take very seriously. We believe this is an area that is relatively under-researched and that it is only by evaluating the evidence that we can begin to understand how best to combat it. We support the increased focus and efforts to have more research in this area, to better understand the link between suicide and gambling, and how we can better support customers at risk.  In addition, working with independent organisations and charities we are looking at how we can improve our procedures to ensure that customers at risk get the support they need quickly.




Q13. 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. In 2018, GVC was the first company to call for a pre-watershed advert ban during live sports. Earlier this year, an industry wide ‘Whistle to Whistle’ ban on UK TV adverts around live sports, pre 9pm, was agreed, beginning August 2019. Since then, GVC has called for a full TV Ad ban around live sports (except horseracing), and for the tone and volume of advertising to be addressed, suggesting there should be responsible gambling adverts only, and only one per advertising break.


  1. In addition, GVC have designed RG adverts for both the Ladbrokes and Coral brands that began airing during the launch of the new football season. These adverts only feature content that raises awareness of our account management tools and encourages customers to gamble safely.


Gambling and Sport


Q14. Gambling is becoming an integral part of a growing number of sports, with increasingly close relationship between operators and sports clubs, leagues and broadcasters. What are the risks attached to this?


  1. Gambling and sport share many links, which, as with racing, can complement each other. However, at GVC, we recognise that there are certain sports where the link between gambling and sport has become of concern, especially for children and younger fans. Football is an example of this. The safety of our customers and the integrity of sports is of paramount importance to GVC, and that is why earlier this year we were the first operator to unilaterally end all football shirt sponsorship deals with UK teams and ban perimeter board advertising at football grounds. This will allow sporting fans to watch their favourite teams without seeing any incentives to bet. To honour all existing agreements, we are donating our previous advertising space to either white label responsible gambling messaging, such as with our SPFL sponsorship, or messaging of our charitable partner - Children with Cancer - such as with our sponsorship of Sunderland and Charlton football teams.



  1. Changing for the Bettor is an acknowledgement from GVC that we can and should do more to support problem gamblers and those at risk.


  1. We see Changing for the Bettor as an evolving strategy, that will advance as new initiatives and actions come to light, and we learn from best practices across the industry and elsewhere. There are a variety of pieces of ongoing work, and we hope this submission has highlighted our very real commitment to tackle problem gambling in a safe and measured way.


  1. From research, to workshops and internal changes within our business, we are committed to addressing the complex issue of problem gambling, and continue to work in all areas to tackle this from all angles. We can see there is a challenge ahead, and know the impact of these initiatives will not be felt instantly, but we believe that these pillars provide a strong foundation for real change within GVC, and strive to be industry leading in this important area.


  1. We thank you for this opportunity to engage and we await the outcome of your inquiry with interest.


6 September 2019