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Trigger warning: This article contains images of gambling ads that may be distressing or triggering to some individuals. If you may be adversely affected by viewing gambling ads, please proceed with caution or refrain from reading this article.
Gambling-harm has been increasingly recognised as a public health issue globally, with the WHO reporting that the amount of years of healthy life lost from gambling-harm is on a similar level to the healthy life lost from alcohol misuse disorder or major depressive disorder.
One key tenant of UK regulations on the gambling industry includes the protection of children. Notably, children are at-risk of suffering severe harms from their own gambling and from another’s gambling such as a parent’s. It is important to highlight that gambling harm in young people is not a rare occurrence, in fact, the Gambling Commission (GC) reported in 2020 that among 11-16 year olds in England and Scotland, 4.6% have experienced gambling harm from their own gambling and 5.5% were harmed from a family members’ gambling in the past year.
There is a growing evidence-base that demonstrates how gambling products and industry practices maximise yields by manipulating cognitive biases and by framing gambling as a widely popular low-risk or no-risk source of entertainment; with such messaging engineered and delivered through a £1.5 billion annual advertising spend.
Game design and related advertisements are recognised as being likely to contribute to appeal of gambling and therefore gambling consumption in younger people. As such, following the introduction of the Gambling Act in 2007, the Advertising Standards Agency (ASA) set rules and advice for gambling ads which must adhere to the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) and the law.
In 2017, the GC and the ASA were among the signatories of a letter that ordered 450 online gambling operators to remove games such as “Jack and the Beanstalk” and “Pirate Princess” as ads for these games were deemed to be likely to appeal particularly to people under the age of 18 and were freely accessible. Five years later, in April 2022, The Committee for Advertising Practice (CAP) announced new rules set to come into force on 1st October 2022 that replaces “particular appeal” with a “strong appeal test”.
Within the guidance, there are themes to help guide operators towards compliant gambling ads so that they are not of particular and more recently strong appeal to children, and these include:
Use of licensed characters must be responsible,
Cartoon animals, fairy tales and colourful, exaggerated graphics are likely to appeal
Names may also appeal particularly to children
In our study, a selected sample of fifteen slot-game advertisement images, that were freely available online on platforms belonging to ten of the most popular gambling platforms, were explored in relation to the ASA CAP Code which sought to prevent advertising that is of a particular appeal to children and young people.
Our survey results composed of ninety participants who engaged with our charity’s social media and website, show that the majority of participants found each of the images as having a particular appeal to children and young people and so in breach of ASA guidance.
In conclusion, whilst the survey was limited in scope and the participants were non-representative of the national population, its results indicate that the gambling games in this survey have a particular appeal to children. Indeed, across eleven of the fifteen ads in our survey, a majority of respondents identified at least two of the three ASA’s themes as being causative towards particular appeal to children and young people.
While Gambling Harm UK welcomes the strengthening of ASA guidelines which took place in October of 2022, the guidance based on a ‘strong appeal’ rather than a ‘particular appeal’ does not appear to have yielded a marked reduction in the availability of games selected in our survey.
Note: While Big Bad Wolf was no longer available on 888Casino on 25/02/23, it was found on Unibet’s website. Similarly, while Frozen Gems was no longer available on Bet365 on 25/02/23, it was found on Genting Casino’s website.
Gambling Harm UK urges the ASA to investigate the games included in our survey. Further, due to the significant nature of gambling harm and the vulnerability of children and young people, the ASA should take a more active role in examining gambling products for breaches of its guidelines. The ASA should also consider whether current guidance is sufficient in protecting against normalisation and trivialisation of risk.
Full report:
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