Professor David Forrest – Written evidence (GAM0123)

My name is David Forrest. I am Professor of Economics in the University of Liverpool Management School. For the last twenty years I have pursued research in sports economics and in the economics of gambling behaviour. With my colleague Professor Ian McHale, I have completed and published four research projects funded by GambleAware, related to player behaviour on gaming machines in British casinos, to use of FOB-Ts in licensed betting offices, and to transmission of problem gambling from parents to children. For a fifth and very substantial project, titled Patterns of Play, we are engaged to provide description and analysis of how online gamblers in Great Britain play, based on complete and detailed one year records of 10,000 customers from each of six of the highest impact GB-licenced operators. The data recording the activities of sports bettors (and particularly football bettors) among these 60,000 online gamblers are expected to yield findings highly relevant to the topic of this note. Unfortunately results are unlikely to be available until the Autumn of this year.

I have been approached by the Select Committee (March, 2020) to provide answers or comments to a set of specific questions on the relationship between the sport and betting sectors. However, before responding to the specific questions (in so far as I am able), I think it is appropriate to comment more broadly on the nature and significance of the relationship between sport and betting.

Although long acknowledged for the case of horse (and also dog) racing, the mutual dependence of sport and betting in the case of other sports has been openly and explicitly discussed only relatively recently.[1] From the perspective of sport, there is increasing evidence that it benefits substantially from the existence of associated betting markets, even without considering direct payments from betting companies. Essentially, the sports product becomes more interesting to many potential consumers if they are able to take a stake in the outcome of the event. This was demonstrated in a recent carefully designed laboratory study at Yale University.[2] Nearly 2,000 subjects were invited to view a film of a National Hockey League match. Half were randomly assigned to make a compulsory small bet on which team would win (paid out of their fee for joining the experiment). Afterwards, all were asked to rate their enjoyment of viewing the match. Unsurprisingly the highest average level of enjoyment was in the group which had bet and won; but even those who had bet and lost reported higher mean satisfaction than those who had not bet at all. This is formal evidence supporting the common sense proposition that, for many, betting on the outcome can enhance the experience of viewing sport. If it does, then the demand for viewing sport, live or on television (and consequently the core revenue streams of sport) will benefit from the presence of betting. Research in the USA in the last few years has demonstrated convincingly that media rights values in particular are indeed underpinned to a significant extent by betting interest. In their first paper, Steven Salaga and Scott Tainsky[3] examined in-game variation in tv audience figures across several hundred college football matches. Which matches best retained their audience? They were not matches which turned out to be close in terms of actual score. Rather they were matches where the current score was close to the bookmaker spread, i.e. the matches where the outcome of the most popular bet[4] was still in the balance. Similarly, considering the second most popular bet, the over/ under wager on total points in the game, they found a step drop in viewing figures once the total had gone beyond the betting market’s total point quote, i.e. a significant number of viewers would switch off once the over/under bet had been decided. These stylised findings imply that betting interest was a decisive motivation for viewing the match for a significant part of the audience, and this in a country where, in nearly all states at that time, betting (and advertising related to betting) was illegal. Research on tv ratings for other sports carried out by the same authors, most recently for NBA basketball[5], continues to indicate that a significant proportion of the television audience for an event, and therefore a significant proportion of its value to broadcasters, is related to betting interest.

There are, then, grounds for suspecting that sport has been a principal gainer from the explosion of sports betting since the Millennium whether or not in settings where it is able to collaborate with the betting providers. No one knows exactly how much growth there has been in the Global sports betting market because much of it is illegal or unregulated; but one credible series of guesses made by a French consultancy showed estimated Gross Gaming Yield, GGY (bettor stakes minus bettor winnings), from sports betting[6] of €6b in 2000, €19b in 2010 and €30b in 2016.[7] This remarkable growth was of course powered by technological change: e-commerce offered more accessible betting, its environment was competitive such that value for money improved, and it facilitated the development of a new product, in-play betting. This last innovation accentuated the link between sports and betting because it made watching sport an interactive experience with the viewer able to respond to events on the field as they unfolded. In much of Europe, in-play now accounts for about 70% of sports betting GGY though its market share seems not yet to be quite so large in Great Britain.  [Examination of in-play betting is a priority for the Patterns of Play project.] To the extent that allowing viewers to take a stake in a match through betting (particularly where they feel no allegiance to either team) expands the market for sports viewing, sport as a whole may be presumed to have benefitted indirectly but substantially from the growth in popularity of sports betting through impact on existing revenue streams.

But the explosion of interest in sports betting has also generated possibilities, where betting is legal, for new or enhanced revenue streams which flow directly from the betting to the sports sector. One of these revenue streams originates with sponsorship of clubs and competitions and other marketing opportunities in the stadium. This is the most visible manifestation of the increasingly close relationship between the two sectors. But it is not the most significant in financial terms. Worldwide, the most important way in which sport extracts revenue from the betting sector is by selling it data, which has proven very lucrative given the emergence of in-play betting. The importance of data to in-play betting is obvious. In-play betting is only possible at all if the bettor is able to watch or follow the game simultaneously with engagement in betting. This requires very fast communication of live data from the sports event both to the bookmaker and to the bettor’s computer (or, increasingly, to his or her mobile ’phone). Data here may refer just to play-by-play information on the event (presented to the bettor in a scoreboard widget or even with stylised animation) or it might include the streaming of pictures to bettors via the bookmaker website. Sports organisers have a unique ability to provide such data reliably since they control the stadium and can impede the activities of self-employed data scouts who may otherwise be engaged by betting companies. Consequently, over the last couple of years, sports organisers, from the most powerful (such as the NBA and Formula One) to the more niche (such as Gaelic Sports in Ireland), have sought to exploit their hold over data by contracting with, or forming their own, specialist firms which purchase their data rights and then sell live coverage and up-to-date scores and game information directly from the stadium to operators’ betting platforms. For example: in 2019, Formula One signed its first data distribution agreement  and the NBA signed a $250m contract to supply new legal bookmakers in the USA;  650 European handball fixtures per season are streamed to bookmaker websites; and even local sports like Gaelic Football in Ireland have international contracts. Naturally the highest profile leagues, such as the NBA, achieve the highest absolute values for their data rights; but these income streams are still small relative to their income from broadcasting rights. However, for less high profile competitions, data rights have already become a key part of their business models. For example, the Scottish Football Association until recently sold data for only £3m per annum but this accounted for 8% of its revenue (indeed all betting-related income streams together represented fully 20% of its revenue). Data sales to bookmakers for English and Scottish football are managed through Football DataCo, which has from next season granted its new partner, Betgenius, exclusive rights for supplying hundreds of bookmakers around the World.

Sponsorship of clubs and competitions by betting companies represents the most visible means by which sport derives revenue directly from the gambling industry. But the dependence of the most glamorous sports and clubs on gambling sponsorship tends to be low because they can attract higher funding from other sectors. This may be illustrated by reformatting the English Premier League table, substituting club names with the name of the industry from which they draw their principal sponsor. In many weeks “gambling” occupies every place in the bottom half of the table; but at the top the industries represented tend to be luxury goods or financial services. Presumably such brands are interested only in associating with success and their interest is in the club rather than the competition. Further down the league, betting companies are likely buying into the television exposure that the competition automatically gives either in the UK or (more relevant to most of them as operators with little or no presence in the GB market) in their overseas core markets where Premier League broadcasts are widely viewed. In each case, the television audience will be weighted towards groups disproportionately represented among bettors (sports fans, young males). In the Championship, the second tier of English football, betting companies are even more commonly represented on shirt fronts than in the Premier League- again they are buying television exposure (less in volume but purchased at a lower price) and perhaps making a “gamble” on the club being promoted to the Premier League during their contract period.

Although the Premier League has the highest value sponsorships, its dependence on this source of income is nevertheless low. For example the typical value of a betting shirt sponsorship in an English Premier League club is only £5m-10m per year (whereas even the weakest club in the division will receive revenue greater than £125m thanks mainly to broadcasting rights income).  On the other hand, in the English Football League and in Scottish football, and in less high profile sports and competitions, such as rugby league and snooker, and even in events such as the Netball World Cup held in Liverpool last year, sponsorship is more important and there is little incentive for brands from other sectors to invest: they do not pick up enough exposure to potential customers, in contrast to the betting industry, which has an unusual proportion of customers for its product concentrated in the viewing audience for a sports event. Many of these clubs and competitions would face difficulty in replacing their betting sponsors, compromising the scale at which they could operate and the quality of talent they could attract.

It is striking that in jurisdictions which have moved against sponsorship and advertising by the betting sector- Australia and Italy- opposition from the betting industry has been muted but that from sports leagues and broadcasters strong. This may reveal that betting houses themselves perceive their marketing as about brand share rather than extending the market and there would be some advantage to them from the state doing what competition law prevents them from doing for themselves- negotiating away heavy marketing budgets which just cancel each other out. However, sports leagues will typically fight against restrictions because their finances are precarious and they suspect that their next-best sponsors would have significantly lower willingness to pay than betting operators. They will recognise that loss of revenue from betting will tend to reduce pay for athletes and threaten the scale at which they currently operate. For example, English football has the largest structure of professional clubs in the World and shrinkage would likely take the form of fewer towns being served by a professional club.

The following questions have been put to me by the Select Committee:

1.              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?

2.              We understand you have carried out research on the link between gambling-related harm and sports sponsorship, could you provide us with your findings from this work? Countries such as Italy have banned gambling company sponsorship (with France banning sponsorship from alcohol brands), do you believe a ban such as this would make a difference in the gambling-related harm occurring in the UK?

3.              Have you undertaken any work on the impact of a partial or full ban on gambling sponsorship in sport on sports clubs and leagues, particularly football?

4.              The American approach to sports betting is different to that of the UK, as people bet on the spread, is this approach less likely to result in harm? Similarly, in Australia some states have the power to prevent certain bets, do you believe this power would benefit the UK system as it stands?

5.              We have heard oral and written evidence from the gambling industry suggesting more regulation could lead to gamblers using offshore, unregulated operators. What are your views?

6.              What do you believe needs to change in order to limit the harm to gamblers resulting from the relationship between gambling and sports?

I am not able to comment in detail on all of these but will address each in turn.

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?

There is a theoretical integrity risk. For example, a betting operator closely engaged with a club may have access to inside information which it could exploit to its advantage in trading on a match. However, I do not suspect that this has been a problem in practice in GB sports.

The Committee will be more interested in the possibility that there will be risks of increased gambling-related harm; and indeed critics of the ‘gamblification’ of sport emphasise the possibility that it will stimulate demand for and interest in sports betting where it may not have existed before, particularly among young people, creating more problem gamblers on the way.[8] The channels for this hypothesised effect range from the intangible (e.g. the positive attributes which make sport attractive are transferred to gambling through association, making it seem a socially desirable activity) to the specific (e.g. repeated exposure to gambling during a televised match through sight of shirt front and pitchside advertising will create a desire to participate in betting).

There is a lack of reliable evidence to support or refute these hypotheses. However, it would be fair to say that the impact on the size of the pool of problem gamblers from the increased prominence of betting in the world of sport cannot have been dramatic. In Great Britain and worldwide, prevalence of problem gambling has been stable or declining through the period during which sports betting has become much more accessible and visible to the general population (and other online gaming has also become more accessible). In the case of Great Britain, a number of observation points are provided by the (statistically) ‘gold standard’ British Gambling Prevalence Survey, now discontinued, and latterly by gambling sections included periodically in the Health Surveys for England and Scotland. Because of possible methodological differences between the BGPS and the Health Surveys, I will restrict my illustration of trends to Health Surveys in 2012, 2015, 2016 and 2018.

The Problem Gambling Severity Index (PGSI) is an instrument used in the Health Surveys which classifies individuals according to the likelihood that they are currently experiencing harm from gambling. ‘Problem gambling’ describes those whose screen score indicates a very strong probability that they are being harmed by their gambling and that their gambling is out of control. ‘Moderate risk’ does not refer to the risk that an individual will progress to problem gambling but rather to the (moderate) probability that he or she “experiences some negative consequences” from their gambling.[9]

From the four Health Surveys, PGSI problem gambling prevalence was estimated consecutively as 0.4%, 0.6%, 0.5%, 0.4%. PGSI moderate risk prevalence was estimated consecutively as 1.0%, 1.1%, 1.1% and 0.8%. The fall in moderate risk gambling in the most recent (2018) survey is encouraging but, broadly, it is hard to detect trends and the variation from year to year may just be statistical noise. But certainly one could not conclude that the increase in sports betting has coincided with an ‘epidemic’ of problem gambling.

However, measurement of problem gambling prevalence cannot tell the whole story. It is possible for the number of problem gamblers to be unchanged but for many of them to experience even greater harm than before because the link between sports events and wagering supplies more occasions when affected individuals feel the urge to gamble; and such triggers to gamble may make it more difficult for a problem gambler to cut down. This is a plausible scenario and indeed a study which gave a voice to 43 sports bettors who were in treatment for gambling disorder  (in Spain) reported that several felt they had to leave  the room during breaks in play in televised matches to avoid the betting advertisements which they knew would appear.[10]

While Per Binde’s survey (for the Responsible Gambling Trust, now Gamble Aware)[11] correctly summarised the literature as suggesting that advertising had only a marginal impact on problem gambling, there has been an Australian study[12] claiming that existing problem gamblers had high response rates to marketing of betting products embedded within sports broadcasts. There is a problem here in attributing direction of causation but there is nevertheless a risk which it might be prudent to address by regulation and changes of practice. For example, sellers of many online services of all sorts seek to convey urgency and a need for swift action (“three seats left at this price”) but, in the case of gambling, this may be not just exploitative but also dangerous. The language used in in-match marketing therefore needs to be measured and calls to immediate action avoided. Likewise promotions sent to customers during a match might be restricted. Although the Spanish-sports-bettors did not feel at all that advertising and marketing had led them to their present situation, they generally felt that some methods adopted by operators were particularly damaging in respect of their risk of relapse. Based on their experience, personalised messaging online and promotions based on bonuses (such as odds enhancement) were viewed as particularly dangerous.

It may be of interest, given that the Committee is interested in the role of sports betting, to reflect on how important this particular activity is in the total amount of harm associated with gambling in Great Britain.

Worldwide, nearly all prevalence survey reports present tables showing the proportion of participants in each gambling activity who are classified as problem gamblers. These results are typically used by industry representatives as a basis for claiming that their particular product is relatively safe or by anti-gambling groups to call out particular activities as too dangerous to be permitted to continue. On the basis of this metric, sports betting appears to be at the ‘safe’ end of the spectrum of gambling products. These activity-specific prevalence rates are, however, problematic to use in the context of focusing on minimisation of gambling harm. For example, an activity, such as scratchcards, may have a very high attraction to problem gamblers (and contribute to the harm they experience). The count of problem gamblers is the numerator in the estimated activity-specific prevalence rate. But the denominator includes also the count of non-problem gamblers, who may be so numerous as to dilute the measured prevalence rate to the point where the activity is made to seem innocuous even though many problem gamblers are present in the market and experiencing harm.

I would recommend that the Health Surveys and other prevalence surveys worldwide report for each activity not only ‘the probability that a player is a problem gambler’ (prevalence rates by activity) but also ‘the probability that a problem gambler is a player’. For some types of gambling, these two metrics present very different impressions of likely product harm.

My colleague, Professor Ian McHale, and I have calculated this new proposed metric for each activity in each prevalence survey in Great Britain between 1999 and 2016. We were unable to perform detailed calculations for the Health Survey, 2018, because the raw data have not yet been deposited in the National Data Archive; but we have no reason to suppose that the figures for 2018 will prove to be very different from those I will now quote from the 2016 Health Survey.

Unfortunately, the questionnaire used asks specifically about participation in offline sports betting (and also, separately, about offline horse betting and about offline dog betting) but all online betting activity is grouped together as “betting with an online bookmaker”. This makes it impossible to quote one figure for sports betting (the count of online bettors may include, for example, horse-only customers).

The proportion of problem gamblers (so classified by either or both screens administered in the survey) who had participated in offline sports betting was 38.6% and the proportion of problem gamblers who had bet (on anything) at an online bookmaker was 27.3%. Both these figures are appreciably lower than those for some other prominent gambling activities. For example, more than 60% of problem gamblers had played slot machine games and just over half had purchased scratchcards. 46.5% of problem gamblers had bet offline on horse racing.

A high figure for this metric implies that the particular gambling activity is played by a large proportion of those who are experiencing harm, presenting both an imperative not to add to their harm by over-stimulating marketing and an opportunity for that sector to reach out to a significant part of the population of problem gamblers through safer gambling messaging. Sports betting appears to have a ‘moderate’ score on this metric and only a minority of problem gamblers participate in this activity.

Among problem gamblers who do gamble on sport, it is not yet known how much contribution to the harm they are experiencing stems from their sports betting. Problem gamblers typically engage in a number of different gambling activities and it would be interesting to know whether problem gamblers who bet incur a disproportionate part of their gambling losses from betting (rather than at, say, the casino). In the case of online gambling, some insight into this question is likely to emerge from the Patterns of Play project. For now, the data illustrate that it would be a mistake for any recommendations about regulatory reform to be over-focused on sports betting to the neglect of discussion of other sectors of the gambling industry which appear to appeal to a wider section of the population of problem gamblers, the target group to be protected by any new measures to be introduced.

Further, it may be noted that aggregate online/ remote player losses by GB players are greater in other sectors than in football/ sports betting. For example, the latest Industry Statistics from the Gambling Commission indicate losses on football betting of just under £1b whereas online slots accounted for a player losses in excess of £2b. While it cannot be inferred that greater harm is generated by slots play, these data indicate that there is a need to consider the full range of gambling activities regulated in GB rather than focus on one particular sector. This argument is reinforced when one considers that, as one Finnish researcher put it, problem gamblers tend to be ‘omnivores’, i.e. most engage in multiple activities. In turn, this suggests that measures which apply across all sectors, such as the recent ban on use of credit cards to gamble, may yield more results than measures to control only one form of gambling.

We understand you have carried out research on the link between gambling-related harm and sports sponsorship, could you provide us with your findings from this work? Countries such as Italy have banned gambling company sponsorship (with France banning sponsorship from alcohol brands), do you believe a ban such as this would make a difference in the gambling-related harm occurring in the UK?

I have not in fact carried out primary research on this topic. However, I am familiar with relevant literature. Most studies have been carried out in Australia though there is a recent paper[13] applying similar techniques in Great Britain. The papers show for both adults and adolescents widespread awareness of gambling brands which sponsor sports teams, particularly, as is to be expected, among sports fans. The Australian papers report a correlation between awareness of betting brands and intention of adolescents to gamble when they reach the legal age for betting. Authors of these papers refer to the ‘normalisation’ of betting among audiences exposed to betting promotions during sports events and draw the conclusion that such sponsorship should be prohibited.

I regard these papers as a group as offering weak evidence, first because they are based on intention to bet rather than actual behaviour and second because there is ambiguity about causation. Those with a pre-existing interest in any product or activity might be expected to notice and remember brands more readily than those with no interest at all. Therefore causation might well run from aspiration to bet to brand awareness rather than predominantly in the other direction.

The very strong regulatory action taken in Italy (and Belgium) should provide an opportunity for researchers to test for any effects from such a change in regime. At present it can only be speculated whether there will be positive effects. I tend towards pessimism, partly on the basis of American experience. Until the Supreme Court decision which permitted states to authorise sports betting, this particular gambling product could not be advertised in any way because, except in Nevada, it was supplied entirely by the illegal sector. Nevertheless a credible estimate[14] of the (adult) past-year participation rate in sports betting in the USA in 2016 (10%) showed that the activity was at least, if not more. widespread than in Great Britain. Looking back further, in British history, all betting away from racecourses was illegal at the time, and so not advertised, but a 1951 survey for the Royal Commission on Betting, Lotteries and Gaming reported that 11% of respondents had nevertheless placed a bet with a bookmaker in the preceding week, a far higher participation rate than today. One cannot say how much harm was associated with this betting but certainly suppression of marketing appears not to suppress the activity itself. It does, however, prevent access by sport to a share of the economic surplus sports betting generates.[15]

The American approach to sports betting is different to that of the UK, as people bet on the spread, is this approach less likely to result in harm? Similarly, in Australia some states have the power to prevent certain bets, do you believe this power would benefit the UK system as it stands?

In principle, bets on the margin of victory (above or below the bookmaker quote), known in Britain as ‘handicap betting’, may be less risky than betting on actual outcomes to the extent that returns are less volatile. Traditionally Americans bet against the spread at odds of 10/11, i.e. close to evens, so that a long run of losses was unlikely. At the same time, handicap betting is undoubtedly highly dangerous for sports integrity. Regular scandals have appeared in American sport because of the temptation of athletes to agree to ‘point shaving’- they are willing to accept bribes to ease up so as to win by less than the spread because they do not actually have to lose the match for the corrupt bet to be won.

However, it is a dated view to think that Americans mostly bet on the spread. The network of local illegal bookmakers has tended to evolve in the direction of an agent model where agents of offshore operators provide channels whereby American residents can access international markets: agents’ primary role is not to bear risk but to recruit clients and collect the revenue. This change in the model of illegal betting reflects Americans’ increasing desire to engage in the sorts of betting available elsewhere, including in-play betting. This is a worldwide trend in betting demand and imposition of old-style betting on the GB market would likely lead to an increasing trend for bettors to resort to unregulated offshore operators, where they would be less protected from harm.

In Australia and France, sports have a betting right and may prevent certain bets being offered. Typically this is exercised to try to suppress bet types with high risk to sport integrity. In terms of gambling-related harm, it might be considered to remove ‘micro bets’, for example bets on what will happen next (e.g. which team will receive the next yellow card). Such bets have been demonstrated in an Australian paper to be particularly attractive to problem gamblers, preying on their tendency to impulsivity.[16] It is plausible that they lead to unplanned expenditure in situations where there is an urgency to bet before events move on. However, the market for such bets is relatively very small and the potential benefit of prohibition consequently limited.

We have heard oral and written evidence from the gambling industry suggesting more regulation could lead to gamblers using offshore, unregulated operators. What are your views?

This is a real and important danger. Throughout the World, legalised sports betting which offers a limited range of bets or poor value for money falls well short of capturing the whole of the market. For example, France was obligated under pressure from the European Union to issue licences to sports betting operators from other member states but its regime dictated low pay-back rates and a restrictive range of bets. The model has been perhaps surprisingly successful in terms of keeping the mass market within its regulated system but there is reported to be significant leakage of the most engaged bettors to international markets.

An interesting development in the past year has been a trend in North European jurisdictions to introduce loss or else deposit limits on bettors, defined monthly or annually. This is intended to reduce harm by making extreme losses impossible. How this works out should be studied because it should give an indication of how consumers respond to increased regulation when it is realistic for them to find ways of placing extra-territorial bets to evade the restrictions.

In my view, the greatest strength of the 2005 Gambling Act is that it has allowed Great Britain to be more successful than all other countries in avoiding a drift to illegal suppliers. I would caution against the risk of introducing regulatory provisions which would drive bettors offshore. They would then have no protection from the provisions for safer gambling mandated by the LCCP. Further, risks to sport integrity where liquidity shifts from a highly regulated market to an unregulated market are considerably elevated. The ideal betting market for match fixers is one with high liquidity and no effective supervision.

What do you believe needs to change in order to limit the harm to gamblers resulting from the relationship between gambling and sports?

i) Sports betting is an activity from which sport itself can benefit but, like many other forms of gambling, it carries risk of harm; a significant proportion of problem gamblers bet on sport and there has been growth in participation in the demographic group (young-ish males) which is always and everywhere found to be at highest risk of gambling-related harm. That much of the activity is online presents the opportunity to address harm by close monitoring of individual bettor accounts. The effectiveness of such monitoring is, however, compromised in various ways. First, while I am convinced by the ability of algorithms to detect problematic behaviour, the industry has lost confidence that it is serious about applying them rigorously; in the many regulatory settlement cases involving betting, it is inconceivable that the algorithms failed to flag a cause for concern, so some individuals must have decided not to act; a strong signal to the industry would be sent if the managers involved were identified and deprived of their personal licences. Second, problem bettors tend to use multiple accounts, so the need for ‘a single customer view’, prioritised by the Commission, is obvious if problems are to be detected successfully. Third, while the potential to identify problems is strong, evidence is still needed on what interventions would be effective in modifying behaviour; to date evaluation of industry practices in this regard has been inadequate.

ii) Thresholds for triggering intervention should be lower for young bettors. The study of longitudinal data I conducted with Prof. Ian McHale[17] found that most 17 year olds who showed signs of gambling harm had ‘recovered’ by age 20 but that problem gambling prevalence nevertheless tripled between these ages: there was a worryingly high incidence of new onset problem gambling after the age when commercial gambling became legally accessible to the young people. Operators should take the greatest care when dealing with this age group. The case for stronger monitoring of this group is similar to that justifying additional regulations imposed on young drivers.

iii) The Ipsos Mori Report for GambleAware[18] demonstrated that advertising around sports events is not necessarily the principal source for young people of exposure to promotion of gambling. Lottery and scratchcard advertising is likely encountered more often and the example of parents is probably more important.[19] However, it is still the case that the audience for sports events includes a significant number of young people and vulnerable adults and codes for promoting sports betting should be strengthened to protect them from exploitation as well as from more general gambling harm. Examples of marketing which may need greater restraint include offering of complex bonuses and emphasis on the need for urgency (and sometimes the two together- bonus on tonight’s match). Ongoing scrutiny in this area needs to cover not only television but also advertising on social media and in shop windows (where displays are often very specific, showing odds for a particular score in a particular match or odds for a particular accumulator where value for money is hard to assess).    

iv) Sports themselves are not in a position to address gambling harm directly but must still be regarded as having a duty to protect their fans and, if they are to be permitted to continue to benefit fully from association with betting, they should be proactive in assuring themselves, supported by securing appropriate contractual commitments, that betting partners can demonstrate strong compliance with provisions for safer gambling. Sports should also commit themselves to protecting their own employees from gambling harm; even controlling for the peculiar demography of professional athletes (overwhelmingly young men), this occupational group has problem gambling prevalence very substantially above the population average; the risks inherent in their tendency towards heavy engagement with gambling may be aggravated by working in an environment strongly associated with gambling. Sports federations should insist that member clubs and leagues have specific protocols for addressing gambling-related harm among their players and should support player unions in their efforts to deal with the problem. On a positive note, Britain already seems ahead of other European countries on this front.

24 March 2020