Sky Betting & Gaming – Written evidence (GAM0085)




  1. Sky Betting & Gaming (SBG) is a UK-based provider of online-only betting and gaming products, owned by The Stars Group Inc. It operates six main brands: Sky Bet – Britain’s most popular online bookmaker; Sky Vegas – the UK’s most popular online casino; Sky Bingo; Sky Casino; Sky Poker; and Sky Lotto.  Launched in a small office in Harrogate in 2000, SBG remains a Yorkshire-based company, now headquartered in Leeds (with a large hub in Sheffield), employing around 1,500 people in a broad variety of roles34% of the current workforce are in technology-related positions, and the average age of our staff is 31 years old.


  1. We are very much part of our local community and we are proud of the positive, inclusive culture we have created within our organisation.  Our positive working environment is fundamental to ensuring the enjoyment and wellbeing of our customers.  Our business is built on the sustainable enjoyment of customers over the long—term, by ensuring that they are all treated fairly and have a safe and enjoyable experience that is at the core of everything we do. 


  1. We have deliberately positioned ourselves as the leading bookmaker for the leisure player, with customer average weekly expenditure on betting being less than £9, and on gaming less than £20.  As a consequence it is a very high-volume business - for example last year we took in excess of 100 million deposits from 3 million customers. That is why, in our view, data is the most important part of the equation.


  1. While the vast majority of our customers are able to enjoy gambling safely, we are acutely aware that there is a small, but important number who suffer from varying degrees of problems related to their gambling. As an online-only operator, with all activity being account-based, we have access to technology and data which enables us to identify customers we think might be at risk of developing problems.


  1. We can then interact with them in different ways. Each week we review thousands of accounts, intervening where necessary - applying deposit limits or blocks, suppressing marketing or encouraging customers to choose self-exclusion and to seek support. This is a very substantial operation which requires a dedicated team of around 100 people within our business to undertake.


  1. We are continuously evolving our approach to customer welfare in order to raise standards (and we accept that we do not always get everything right). We will continue to make improvements to our approach, working with our fellow operators and a wide group of other stakeholders to ensure we can be as effective as possible in preventing harm and ensuring our customers have safe and enjoyable experiences.


  1. SBG is currently a member of the Remote Gambling Association, and intends to join the Betting and Gaming Council (BGC) as a member when that organisation is fully operational in November 2019.  As such, SBG was involved in the drafting of the BGC response to the call for evidence, and supports the points made in that submission.  To supplement the BGC submission, we do not intend to respond to every question and we will try to avoid repeating points made in that submission.  However, we would like to provide some additional responses on points which relate more specifically to SBG’s business.


Responses to questions


Q.7. Is the money raised by the levy adequate? How effective is the voluntary levy? ...


  1. SBG is committed to providing funding for research, education and treatment under the voluntary levy system.  During the three years of the recently concluded National Responsible Gambling Strategy, SBG spent in excess of £10m on industry-level and internal safer gambling initiatives. This includes providing approximately £3m of funding to organisations such as GambleAware, Gordon Moody, EPIC Risk Management, The Senet Group, YGAM, gamban, and GAMSTOP. We have also invested significantly in our own harm prevention initiatives, which include customer education and dedicated safer gambling advertising campaigns.


  1. In July 2019, SBG was one of five organisations which announced a collective commitment to increase funding for safer gambling initiatives. This will see our annual contribution of gross gambling yield increase to 1% by 2023 – which will amount to an aggregate of approximately £60m per annum being contributed by the five operators.  We have since asked Lord Chadlington to establish and chair a committee to define the most appropriate mechanism for receiving and administering funds and for monitoring their deployment.  We believe this significantly increased funding commitment is a major step in the right direction and we should be prepared to give it a chance, and evaluate its impact properly.


Q. 8. How might we improve the quality and timeliness of research in the UK?...


  1. SBG recognises the importance of research to guiding operational, regulatory, prevention, and treatment policies at an industry, and individual operator, level.  Further, we acknowledge and agree that independence is important.  However, if done appropriately, we believe that operators can have an important role to play given our expertise, access to data, and our understanding of that data and its contextSBG is very much a customer-focussed business, and we place great importance on the opinions of our customers, which drive many of the decisions we make with regard to our products and our approach to customer protection.  Our in-house research analysts frequently conduct surveys across our customer base, to ensure we are providing the best possible experience for our customers.


  1. One of the major pieces of research we have been working on over the past year has been the trialling of the Positive Play Scale (Wood, 2017) with our total customer base. The scale, which was devised and tested in Canada, aims to measure the extent to which a given population has positive beliefs and behaviours, thereby providing a more nuanced understanding of what it means to gamble responsibly for a specific customer base.  Having carried out this research, we are now pursuing a number of initiatives to improve customers’ levels of knowledge around key gambling terminology and rules of play, to ensure they are making well-informed decisions when using our productsThis includes new educational content, including videos, for use in various channels such as CRM, onsite notifications, customer contact queues, and in-product infographics.


  1. The application of insights from external research to the work we are doing with our own customers has been an area of focus for us, and will continue to be so.  We are aware that there is much for us to learn from academic studies, either retrospectively or through our own direct involvement.  For example, recently we (and a fellow UK licensee) have worked with the Behavioural Insights Team on a project to test safer gambling message variations, and anchoring effects in relation to deposit limit values.


  1. More broadly, we are actively engaging with charities, people with lived experience, other operators, and businesses in different industries – to learn from them and help inform and improve our approach to customer protection.


Q. 10. Is enough being done to provide effective public education about gambling? If not, what more

should be done?


  1. Only gambling operators licensed by the Gambling Commission are able to advertise in this country, and we believe that is an important privilege for a licence holder offering a highly regulated product.  SBG has identified the opportunity to use advertising as a medium for the promotion of safer gambling.  We have run dedicated safer gambling campaigns through broadcast media, including our high-profile “Three Simple Tools” television campaign, featuring popular television football pundits. This raised both awareness and the usage of our safer gambling tools among our customers.  That campaign, along with other promotion of our safer gambling tools, led to: a 69% increase in the use of cool-off periods; a 10% rise in customers setting their own deposit limits; and 83% of our betting customers using our profit & loss tool. We are gathering feedback to improve these tools, raise awareness of them, and establish them as part of the normal betting and gaming experience for all of our customers.


Q. 13. The RGSB “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?...


  1. The ASA has reported that exposure of children to TV advertisements for gambling has been in decline since 2013, and this is likely to fall further as a result of the recently implemented whistle-to-whistle ban (see BGC submission). At SBG we follow very rigorous marketing compliance processes, with particular regard to management of our digital marketing, which includes doing everything we can to prevent exposure to children.  We have worked with the major social media platforms to ensure rigorous age-gating (and even stopped marketing on one platform altogether while we helped it improve its age-gating systems to a level we could be comfortable with).  We do not permit any in-app advertising by third parties unless they can demonstrate robust age-gating (such as the use of interest based factors to identify whether a consumer’s self-certified age is likely to be accurate).


  1. We use the tools currently offered by platforms, as well as a third party service to continuously monitor apps and websites which may be of particular appeal to children, to ensure our advertisements do not appear there. Collaboration between the social media platforms and gambling operators is essential to ensure a rigorous and joined-up approach.


Q. 14. Gambling is becoming an integral part of a growing number of sportsWhat are the risks attached to this?


  1. The relationship between gambling and sports has existed in various formats for centuries, and this continues to be the case.  Gambling companies provide significant and vital financial resources to professional and grass roots sport in the UK.


  1. SBG strongly believes that there is a place for partnerships between the gambling and sports industries, provided they are conceived and conducted in a responsible way.  Since 2013, we have been proud partners of the English Football league (EFL), as title sponsor of their league competitions. Through this partnership we have invested many millions of pounds in the league (and are committed to do so until 2024) which funds a range of benefits for clubs and their supporters.. With our safer gambling messaging on in-stadia advertising and the shirt sleeves of all clubs, we believe that the EFL and SBG are demonstrating how sports and betting operators can work together responsibly to promote safer gambling. We note that in June 2019 the EFL conducted a survey of over 27,000 of their supporters, 71% of whom said that the level of involvement in the game by gambling companies is acceptable.


  1. Also within our EFL partnership, we have invested £1m into a five-year safer gambling education programme for players and staff at all EFL clubs. We work with EPIC Risk Management – a leading provider of education around problem gambling - to provide workshops on gambling-related harm for each EFL club, as well as any follow-up counselling and support where required.


  1. Sports betting integrity is an area in which there has been an increase in collaboration between the gambling and sports industries over recent years.  It is a subject that SBG takes very seriously – we have a shared interest with sports governing bodies to prevent betting-related corruption.  As such, SBG is a member of, and provides one of the co-chairs to, the Sports Betting Integrity Forum.  We are also a member of the International Betting Integrity Association. We have agreed more than a dozen information sharing MOUs with sports governing bodies and we have robust internal processes designed to identify, escalate and report (where necessary) suspicious or unusual betting activity, supported by internal policies and e-learning packages on sports betting integrity. As a result of those systems and processes, we have supported a number of sports governing bodies in investigations and prosecutions of breaches of their rules.



13 September 2019