Dr May van Schalkwyk – Written evidence (GAM0094)


Public Health Registrar and Academic Clinical Fellow, London School of Hygiene and Tropical Medicine


As a public health researcher, I value the opportunity to contribute to this call for evidence on the social and economic impact of the gambling industry. Rather than focus on individual questions within the call for evidence, my aim is to draw the committee’s attention to certain issues and evidence that have relevance to many of the lines of enquiry pursued by the committee and are likely to impact on all of the overarching themes.


The UK government is committed to reducing the harms of gambling through the Gambling Commission’s three-year National Strategy to Reduce Gambling Harms (2019) and in legislation including the Gambling Act 2005 which requires that children and other vulnerable people are protected from being harmed or exploited by gambling. This is achievable if the right actions are taken, and essential if we are to meet other commitments such as addressing inequalities1 and delivering on the prevention agenda captured in the NHS forward plan.2


However, it is important to acknowledge that despite widespread agreement about the nature of the problem,3 and the necessity of a public health response, the current approach to gambling is unlikely to deliver improvements in the reduction or prevention of gambling harms in the UK. Significant changes are required if we are to deliver an effective and evidence-based public health approach to gambling in the UK.


In other fields it has long been accepted that policymaking needs to be informed by the highest quality scientific evidence, meaning it is underpinned by rigorous and independent research. It may surprise the committee that many academics have concerns that gambling research frequently fails to meet the needs of policy-makers and practitioners in this respect. I therefore wish to bring the committee’s attention to an important area of concern, and one which affects many other aspects of addressing gambling harms in the UK: gambling research and the production of evidence, including the research agenda-setting process (that is, what questions are asked and what methods are chosen to answer these questions) and funding.


Gambling Research
There is growing consensus among academics and policy-makers that the systems and structures for gambling research agenda-setting and funding in the UK are far from optimal. It is important to acknowledge that steps have been taken recently to make these systems more transparent and robust. However, the voluntary nature of the levy, the historically close relationship between GambleAware and the industry, and the preference of GambleAware for a model of collaborative working with the industry creates serious and unavoidable conflicts of interest.


Gambling research does not conform to standard practices and norms in other fields. It does not, for example, follow the practices used for commissioning independent scientific research on the health effects of alcohol, food/diet, or tobacco. These practices are based on clear evidence - produced in the most respected peer-reviewed journals - that industry funding or sponsorship of research has a negative effect on research agendas and outcomes, and therefore on public health.


1. Industry funding causes bias

Much of the gambling research conducted in the UK to date is industry-funded, albeit through a charitable medium. It is well established that research that is conducted and/or funded by industries is systematically different to research that is independent of industry influence, often favouring industry interests and/or undermining effective public health interventions.4–7 The author’s conclusions to the Cochrane Review (recognised as the highest standard of evaluation by the international research community) on industry sponsorship and research outcome states that:

“Sponsorship of drug and device studies by the manufacturing company leads to more favourable efficacy results and conclusions than sponsorship by other sources. Our analyses suggest the existence of an industry bias that cannot be explained by standard 'Risk of bias' assessments.”4


Research funded by tobacco, alcohol and sugar-sweetened beverage industries have all been found to lead to outcomes that are favourable to their interests. A scoping review of studies that explored the influence of industry sponsorship on research agendas in different fields concluded that, “Corporate interests can drive research agendas away from questions that are the most relevant for public health.”8 This has significant implications for addressing all health-related issues, including gambling harms.


We also know from a recent review of the international literature (including from the UK) that the interventions that are most likely to prevent or reduce gambling harm (for example affordability checks and mandatory limit setting through fully identified play) are also the least likely to be introduced due to the influence of the industry.9


2. Risk of no engagement by, or collaboration with, leading academics and their institutions


The UK’s leading institutions and academics are unlikely to accept industry funding as they may see the act of accepting and working with such funds as a threat to (1) their reputation (current and future), (2) the integrity of the research process, and (3) their aim of, and role in, protecting public health. This increases the risk that gambling research continues to be of poor quality, repetitive in nature (addressing the same narrow range of topics over time), and impacted by conflicts of interest and lack of independence.10 Industry funding increases the risk that the quality, breadth and usefulness of gambling research in the UK will be less than optimal and public health goals will not be achieved.


What next?

The recent announcement from GVC regarding the establishment of a committee chaired by Lord Chadlington that will provide ‘recommendations’ to the industry about the distribution of additional voluntary funding for safer gambling initiatives will not, based on the evidence, address the above issues. Indeed, the voluntary structure proposed reproduces all of the weaknesses of the existing system, albeit with a larger pool of funding. The effect of delegating important decisions about new directions in gambling research to an industry-run committee will be to reinforce, rather than address, the existing division between researchers who have chosen to accept the status quo and those who call for reform. The establishment of these two research streams risks creating inefficiency and will not improve the diversity or quality of gambling research in the UK. Nor will they support a shift to a public health approach as has been unanimously called for. Public health approaches are, by their nature, aimed at reducing harmful consumption which is likely to impact operating profits by attempting to prevent harmful gambling, rather than provide treatment for those already suffering, as is the case currently. These and other concerns have been raised by myself and colleagues in a recent editorial in the Lancet.11


In light of the preceding observations, I wish to take this opportunity to make the following recommendations for the committee’s consideration. I believe these will support the long-overdue creation of an effective and evidence-based public health response that focuses on preventing and reducing gambling harms:


  1. Strengthen the independence, transparency and quality of gambling research: the evidence supports an end to gambling research exceptionalism.

Gambling research should be:

(a) funded with money ring-fenced for this purpose from general taxation (or by a mandatory levy if this is not possible),

(b) commissioned through research councils or their equivalents,

(c) undertaken within established academic institutions, and

(d) subject to independent peer review conducted through all of the normal independent academic structures and meeting existing conventions for high quality scientific research.

  1. Shift to evidence-based and independently-evaluated population- and policy-level interventions: such an approach has been shown to be most effective in addressing other public health issues such as smoking, alcohol and unhealthy food consumption in the UK and globally. Based on all available evidence and supported by the precautionary principle, this shift is crucial if we are to effectively prevent and reduce gambling harms.11



Other urgent and immediate interventions which flow from this transition to a public health approach to gambling harms include:


a.     An increase in the amount of funding available for the prevention, as well as the treatment of gambling harms.

b.    The UK, led by the Safer Gambling Board, should host clean conferences, and explicitly end the collaborative / partnership model of working, currently endorsed by GambleAware. In line with the Public Health Association of Australia,12 industry should not be involved in the commissioning, creation or dissemination of academic research, including through conferences. As described by Livingstone: “Industry influence operates at multiple levels within the gambling research field. There is increasing awareness of this, and of the effects it may have on the development and deployment of effective harm prevention and minimisation efforts.13 He suggests key reforms including: “(i) the elimination of industry participation and sponsorship of gambling research associations and forums; and (ii) the establishment where necessary of new research forums and international scholarly associations.”13

c.     The withdrawal of industry funding from treatment and education initiatives. International research (including in the UK) shows that industry supported initiatives are either ineffective or counterproductive.14–16 The gambling industry should not be involved, directly or indirectly, in prevention, education or treatment services. Treatment should be provided by the NHS and subject to all of the normal forms of evaluation and oversight. Education should be provided by accountable, recognised independent experts, paid for out of general taxation or, failing that, out of a mandatory levy.

d.    Industry partnership in research is often justified on the basis that it is the only way to gain access to natural data. There is no foundation to this logic. Data should be available to answer any policy question, as a condition of licensing. The data should be held in a hub overseen by the Gambling Commission, and accessible to all independent researchers, a cost effective move which will rapidly improve the quality and diversity of research in the UK.

e.     Immediate action should be taken to include experts with experience in all gambling research. First steps should include exploring how they would like their role, and expertise, to be valued and effectively integrated into the research process.



The actions advocated for herein are all urgent and necessary: the field of gambling research requires comprehensive reform. If gambling policy is to be effective and equitable it must be based on high quality, independent evidence. Defending science and the research process is the first step towards an effective public health response to gambling harms.




1.               NHS England. Reducing health inequalities resources. https://www.england.nhs.uk/about/equality/equality-hub/resources/. Accessed September 24, 2019.

2.               Public Health England. The NHS Long Term Plan: 10 key public health points - Public health matters. https://publichealthmatters.blog.gov.uk/2019/01/08/the-nhs-long-term-plan-10-key-public-health-points/. Published 2019. Accessed September 24, 2019.

3.               Wardle H, Reith G, Langham E, Rogers RD. Gambling and public health: we need policy action to prevent harm. BMJ. 2019;365:l1807.

4.               Lundh A, Lexchin J, Mintzes B, Schroll JB, Bero L. Industry sponsorship and research outcome. Cochrane Database Syst Rev. February 2017. doi:10.1002/14651858.MR000033.pub3

5.               Mahase E. Coca-Cola contracts could allow it to “quash” unfavourable research findings. BMJ. 2019;365:l2102.

6.               Steele S, Ruskin G, McKee M, Stuckler D. “Always read the small print”: a case study of commercial research funding, disclosure and agreements with Coca-Cola. J Public Health Policy. May 2019. doi:10.1057/s41271-019-00170-9

7.               Saban A. Alcohol industry funding for university research: a conflict of interest. Eur J Public Health. 2018;28(suppl_4).

8.               Fabbri A, Lai A, Grundy Q, Bero LA. The Influence of Industry Sponsorship on the Research Agenda: A Scoping Review. Am J Public Health. 2018;108(11):e9-e16.

9.               Livingstone C, Rintoul A, de Lacy-Vawdon C, et al. Identifying Effective Policy Interventions to Prevent Gambling-Related Harm. Melbourne; 2019. https://responsiblegambling.vic.gov.au/resources/publications/identifying-effective-policy-interventions-to-prevent-gambling-related-harm-640/. Accessed September 24, 2019.

10.               Cassidy R, Loussouarn C, Pisac A. Fair Game: Producing Gambling Research.; 2013. https://www.gold.ac.uk/media/documents-by-section/departments/anthropology/Fair-Game-Web-Final.pdf. Accessed September 5, 2019.

11.               van Schalkwyk MCI, Cassidy R, McKee M, Petticrew M. Gambling control: in support of a public health response to gambling. Lancet. 2019;393(10182):1680-1681.

12.               Public Health Association of Australia. Public Health Association of Australia: Policy-at-a-Glance - Gambling Industry Funding Policy.; 2014. https://www.phaa.net.au/documents/item/249. Accessed September 23, 2019.

13.               Livingstone C. A case for clean conferences in gambling research. Drug Alcohol Rev. 2018;37(5):683-686.

14.               Smith SW, Atkin CK, Roznowski J. Are “Drink Responsibly”Alcohol Campaigns Strategically Ambiguous? Health Commun. 2006;20(1):1-11.

15.               Wakefield M, Terry-McElrath Y, Emery S, et al. Effect of televised, tobacco company-funded smoking prevention advertising on youth smoking-related beliefs, intentions, and behavior. Am J Public Health. 2006;96(12):2154-2160.

16.               Landman A, Ling PM, Glantz SA. Tobacco industry youth smoking prevention programs: protecting the industry and hurting tobacco control. Am J Public Health. 2002;92(6):917-930.

24 September 2019