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Betting and Gaming Council – Supplementary written evidence (GAM0129)

Following the evidence session on 4th February, at which I gave evidence, Lord Layard asked how much money is laid by people on their own, as opposed to what is being said now that it is basically a social activity?

I promised to write to the committee on this matter.

The extent to which gambling in Britain takes place with others or alone is unknown. However, there are a number of studies which can help inform as to how people gamble. I have included these separately with this letter.

With regards to Non-Disclosure agreements I understand that our members who were asked for evidence on this matter will be responding directly to the Committee on this matter. We do not have any further information to add.

With regards to social media and affiliates, we are supportive of affiliates being regulated (which is not currently the case). In addition we published a 10 point action plan to further guide members during the COVID crisis which includes a requirement for members to operate a one-strike-and-you’re-out policy on affiliates that breach our code of conduct. The COVID 10 point action plan is included below.

While millions of people regularly enjoy a flutter and do so safely, I am determined to ensure that the standards in our industry are the highest in the world. That is why we have announced our safer gambling commitments which include 22 actions based around 5 core areas of consumer safety and protection.

As part of these commitments, our members have already introduced a ‘whistle to whistle’ ban on advertising during sport; substantially increased funding for research, education and treatment; implemented new ID and age-verification checks; ended exclusive rights to screen FA Cup games and will implement a ban on betting with credit cards. We are also continuously developing new safer gambling tools with bespoke messaging and reviewing interactions to ensure that they have maximum positive impact.

I am determined to continue to drive change across the betting and gaming industry to ensure the highest standards are met.

Studies on gambling behaviour

The latest Health Survey data (England, 2018) indicates that the majority of people who gamble do so in the company of other people:

- 43% of people gamble (past-year), excluding the National Lottery

- only 15% of men gamble online and 4% of women (past-year)[1]

It is unclear how much of online gambling is solitary but clearly the majority of gambling must be in venues with other people present, in betting shops, on-course, pubs, arcades, casinos and bingo clubs.

A number of studies have highlighted the importance of gambling venues in bringing people together. For example, in 2007 the Henley Centre found that:

"Bingo plays an important role in promoting a sense of belonging to a local community. It is one of the few leisure pursuits that brings together people of all ages:

• When a bingo club closes, former patrons can feel isolated and alone, and some even cease to leave their homes altogether

• In comparison with the general population, bingo players spend a great deal of time with their families – 82 per cent of bingo players see their families either every day or a few times a week, compared with an average of 54 per cent among those involved in other social activities."

While the Health Survey data (England, 2018) shows that only 15% of men gamble online and 4% of women (past-year) the Gambling Commission statistics (2019) attempt to identify locations where that gambling takes place. Of those who gamble online rather than in a physical premises, the locations that they have gambled online in the past four weeks are 95% at home, 15% at work, 12% on their commute, 7% at a pub or club and 4% at a sports venue.[2] It may be a reasonable assumption that a large part of gambling at home is solitary. But that does not mean that other people are not present (which may be a critical mediating factor). Gambling online at home is also likely to be non-immersive and a large number of people use chat rooms when gambling (particularly on bingo), creating a level of social interaction.

Philander & McKay (2014) analysed data from the BGPS 2010 and found that - adjusting for endogeneity - participation in online gambling predicted lower problem gambling PGSI scores. They speculated that this may be because online gambling was subject to a wider range of natural interruptions and alternative pursuits:

"The convenience of access to online gambling is often noted as a source of risk but gambling in the home or another comfortable location may actually cause players to end playing sessions more quickly due to the availability of alternate activities. If a player reaches his/her predetermined money limit early in a session at home, he/she would be able to quickly perform many non-gambling activities at home – surf the Internet, watch TV, cook a meal, talk to family/room-mates, etc. ...The presence of the gambler at an Internet enabled device also implies quick and easy access to a wide range of online help materials for responsible gambling and problem gambling. Gamblers with concerns about their play, or simply seeking to improve their informed decision-making, are typically no more than a couple of clicks away from responsible gambling materials and contact information, which may or may not be easily available (or evident) in a physical gaming location. Online gamblers are also not restricted to accessing the materials provided by the operator, but can also immediately seek out information from non-profit and health providers."

Bernhard, Dickens and Sahpiro (2007) observed (in Las Vegas) that suggestions that slots gaming was non-social may be misplaced:

"Our data clearly contradict Putnam's impressionistic statement that the increasing popularity of machine gambling represents an anti-social (or at least non-social) development. While machine gambling does not appear to be as popular with those who gamble alone, perhaps other forces are at play here. For instance. solo gamblers tend to be more frequent and heavier bettors, and perhaps they have developed a savvy understanding that machine games cannot be "beaten" in the same way that other games (such as table poker or sports betting) can. What is more, it would seem that gambling should not be characterized monolithically, especially as it pertains to social interaction. For instance, while craps and sports betting spaces are loudly and visibly social, other gambling spaces have their own social nuances. Table game play incorporates not only the obvious sharing of space and inevitable small talk that occurs within these confines, but also distinct table etiquette and shared codes that most players eventually adopt. Sometimes chatter is intended to gain an advantage, as is often the case with table poker. Often, however, even in non-directly confrontational games such as blackjack, players readily strike up casual conversations -as might be expected among any individuals sharing common space, interests, and conversation material."

COVID-19 action plan - pledges:

Pledge #1: Members will increase safer gambling messaging across all sites, apps and channels including inbox messaging to all existing and new customers reminding them of the safer gambling tools available.

Messaging is a crucial method of nudging customers into taking actions to remain in control. Actions include using tools that offer customers an important way to set limits and raise awareness of their play. Their prominence in the customer journey should be emphasized during this period.

Pledge #2: Members will implement heightened monitoring and data collection in the knowledge that customers are required to abide by social distancing measures. Any material change in customer play patterns, including any increase in time and spend, beyond normal patterns before the crisis, indicates potential markers of harm and operators must step up interventions.

While total gambling has reduced due to no UK sporting events taking place internal tracking and customer protection systems should be adjusted where necessary to ensure that changes in customer behaviour are identified.

Pledge #3: Members, operating heightened monitoring, shall actively promote deposit limits and send a deposit limit message with link to the tool to any player exhibiting abnormal patterns of play that are a marker of harm.

The current crisis can lead to changing patterns of consumer behaviour, particularly online. Where gambling companies are aware of customers increasing their play beyond their normal routine, they should ensure this triggers an appropriate response in establishing the customer’s welfare and being prepared to intervene with a deposit limit message or mandatory limited where appropriate.

Pledge #4: Members shall commit to an immediate and ongoing review of their marketing and advertising – in volume, content and targeting – and will act to ensure it is both appropriate and responsible given the increased risk.

Members should ensure that that gambling is not portrayed as a suitable or desirable response to those experiencing boredom or frustration during self-isolation.

Telephone, text and e-mail contact should not be increased from normal patterns during this period with the exception of promoting safer gambling messaging.

The industry is acutely aware of the risks arising from potential new patterns of work and leisure caused by the current lockdown. As such the industry is determined to ensure that marketing and advertising is appropriate and sensitive to these potential risks.

Pledge #5: Members will report to the BGC instances of illegal rogue and inappropriate advertising and the BGC will report these to the regulator.

Illegal offerings and their advertising can be found on the web and are unethical where they seek to take advantage of a customer’s vulnerability. BGC members should report such advertising to BGC who will inform the regulator. This is part of the overall effort to clean up advertising which is irresponsible and accessible to the UK public.

Pledge #6: These Pledges will fully apply to all affiliates. Members will enforce a strict one-strike-and-you’re-out policy for breaches of these Pledges.

Affiliates provide an important role in providing messaging and responsible advertising to customers. This means affiliates must in no way mention or use the words associated with the Coronavirus such as ‘’bored’’, ‘’isolation’’, ‘’stay at home’ ’amongst others. The BGC will collect and provide a list of key words and phrases to members, affiliates and social media platforms to prevent their misuse.

Pledge #7: Members will sign-post to GAMCARE advice and the 24-hour free to call National Gambling Helpline and GamStop for self-exclusion in their safer gambling messaging, particularly where issues around anxiety or isolation are apparent from monitoring systems or customer interactions.

The industry provides safer gambling messaging to all customers. At this time, it also needs to address issues arising directly from the current crisis. To this end members shall incorporate additional information for customers requiring intervention as part of our corporate responsibility to the public.

Pledge #8: Members restate their commitment to maintaining the vital flow of important funding for Research, Education and Treatment (RET).

There are a great many companies and people reliant on our businesses as suppliers, many of them small organisations that may lack the resilience to navigate this crisis.  This is even more important for charities and organisations that deliver the crucial Research, Education and Treatment services which need to stay available to customers.

Pledge #9: Members shall conduct welfare checks on employees during this crisis.

Our employees are similarly affected by the same challenges and emotional risks as others.  Companies should ensure that they have the mechanisms in place to make regular welfare checks on employees and fulfil their duty of care to ensure their safety and wellbeing.

Pledge #10: Members should play a full part in supporting the Government’s ‘National Effort’ by encouraging staff to volunteer for community service, as well as offering premises where possible for use by those supporting the effort to tackle the Coronavirus.

For those companies with large retail businesses on the high street, our employees will often know of people who may live alone or be unable to fully support themselves during this crisis. They are in a good position to assist where possible. The NHS also has a volunteer service which we would encourage those willing employees to volunteer.

7 April 2020