Evangelical Alliance UK – Written evidence (GAM0072)

Background

1. The Evangelical Alliance UK is the largest and oldest body representing the UK’s two million evangelical Christians. Formed in 1846, we currently work across a diverse constituency of 81 denominations, 4,000 churches, 600 organisations and thousands of individual members. Members include those from both denominational and independent churches. Along with other churches and faith groups, the Alliance has been concerned for a long time about the risks associated with gambling and the impact it can have on individuals, families and wider communities.

Response

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?

2. We believe that research, education and treatment are vital concerns. With this in mind, we support a mandatory levy on the gambling industry, to raise the funds that are required for these activities, rather than relying on voluntary contributions. A mandatory levy on all companies would spread the cost more fairly across the industry. It would also raise funds which are in proportion to the profits made. In addition, a guarantee of funding (through a mandatory levy) would remove the prospect of any influence from the industry on those projects which are funded by it.
    
3. The money gained could be used for research where more is needed, such as on the effect of gambling on young people and the impact of gambling advertising, or on fast-moving areas such as online gambling. On treatment, this funding should also be used to ensure that treatment is equally accessible across the country.

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

4. We support additional investment in digital literacy and teaching on addiction in all its forms (including problem gambling) in schools. At the same time, there must be greater public awareness of the vulnerability of young people to problem gambling in connection with questions around their online safety, such as the dangers of internet and gaming addiction and the increased vulnerability of young people to targeted advertising. These issues were considered, for example, in the House of Lords Communications Committee inquiry: Growing Up with the Internet.[1]
    
5. As for how teaching on gambling addiction could be delivered, we suggest that the pilot study supported by GambleAware and run by Demos and others, of lessons covering impulse control, assessing risk and spotting manipulative behaviour, is a good case study.[2]

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.” Do you agree? How should we make decisions about the regulation of gambling advertising? What might be learned from international comparisons?

6. We agree with the caution that the RGSB has expressed on the issue of gambling advertising. We continue to believe that a ban on gambling advertising before the 9pm watershed is justified, and we welcome the recent decision by gambling companies to limit advertising during live sports events, in recognition of the widespread concern at the quantity of this advertising.[3] Such advertising contributes to the normalisation of gambling in society, particularly among children and young people. There must now also be discussions around other contexts in which children and young people are exposed to gambling advertising, particularly online.

Q14: 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?

7. We believe that the quantity of gambling advertising in particular has had a detrimental impact on sport (see the answer to question 13 above). In addition, the increasing dominance of gambling in connection with sports has an impact on those players who, for reasons of conscience, do not wish to be complicit in promoting the gambling industry. We therefore urge the Committee to consider ways in which the conscience of these players can be protected and acknowledged.
    
8. For example, in a report published by the Evangelical Alliance, the Lawyers’ Christian Fellowship and ADF International entitled Christianity in the Workplace, we cited the example of Sonny Bill Williams, the New Zealand Rugby Union player. Sonny Bill is a Muslim, and was allowed an exemption from wearing logos or participating in sponsorship work with companies related to alcohol or gambling. This was a good example of reasonable accommodation and religious literacy on the part of his employer, but also highlights the risk of such clashes arising as gambling becomes more dominant in advertising.
    
9. Furthermore, quite apart from religious groups, as the harms associated with gambling become more widely known, it is conceivable that players without religious reasons may nonetheless object on ethical grounds to gambling sponsorship. The rights of players in these circumstances should be considered.

Q16: 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’. Should young people between 16 and 18 be able to purchase National Lottery products, including draw-based games, scratch cards and online instant wins?

10. Britain has the only regulated gambling market that allows under-18s to participate in commercial gambling. Meanwhile, according to some estimates, 55,000 children and young people are already problem gamblers, with a further 70,000 at risk of harm. We believe that this makes the current arrangements deeply problematic.
     
11. Access to commercial gambling gives young people the impression that gambling is normal and harmless. It also associates gambling with positive early memories. Alongside ever-increasing exposure to gambling-related advertising (as in question 13), this creates a climate in which gambling is seen as less risky than it actually is.
     
12. In addition, we know that gambling addiction has a disproportionate impact on young people because of the disruption it causes to their education and relationships. And research suggests that gambling addiction which arises among young people is more severe.[4]
     
13. The current position on young people and gambling is also out of step with increasing caution in other areas (such as online) when it comes to the risk and impact of addiction and other problems for young people. In a world in which child safeguarding is – rightly – being taken much more seriously, such anomalies are increasingly hard to justify. For all these reasons, we believe that under 18’s should not have access to commercial gambling.

Q17: Should children be allowed to play Category D games machines (which include fruit machines, pushers and cranes)?

14. We do not believe that children should be allowed to play Category D games machines. For the reasons given in answer to question 16, we do not believe that under 18’s should have access to commercial gambling.

6 September 2019