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"Harms in affected others challenge the industry in two ways. First, measures to raise awareness and prevent gambling harms in individuals who do not gamble will reduce the appeal of gambling and contribute to its social unacceptability. Second, the 'freedom to gamble' argument is confounded if individuals who do not gamble are harmed." An extract from 'Gambling Explained' (Executive Summary). 'Gambling Explained', among many other things, demonstrates that affected others are significantly harmed and yet often omitted from discussion and consideration, let alone action. We, the authors of this report and submission to the Gambling Act Review, have a combined lived experience of affected other harms of over 25 years. We are particularly pleased to share 'Gambling Explained' as this piece has been written and funded independently. The attached report is a collation of salient scientific evidence and disconcerting comments made by the industry and other stakeholders across ten key topic areas, which are: Chapter 1: Gambling and health Chapter 2: Gambling and addiction Chapter 3: Gambling in children and young people Chapter 4: Gambling and advertising Chapter 5: Gambling research, education, and treatment Chapter 6: Design of gambling products Chapter 7: Gambling and the way it is conducted Chapter 8: Gambling and voluntary bans Chapter 9: Gambling operators as multinational corporations Chapter 10: Gambling and crime In addition to shedding light on critical matters pertaining to the Gambling Act Review, 'Gambling Explained' hopes to validate the significance and role of emerging lived experience voices, particularly those of affected others, in driving change. Charlotte Bradley: "When the opportunity arose for me to be involved in the authorship of this report, I was extremely humbled yet keen to further a rapidly developing evidence base surrounding gambling harms. The overwhelming urge to be involved and seek to uncover the extent of current evidence derives from a personal lived experience of gambling harms. Harms accrued through no direct involvement nor fault of my own. A not too dissimilar set of harms to that experienced by my children, stepchildren, and in-laws, amongst others. All of us harmed, tied by one mutual connection - somebody we love suffering from a gambling disorder. Thankfully, now three years into recovery, our story is one of hope and positivity, yet the past is still a part of us and will be for as long as we live. The extent of harm to which our children have faced is yet to be uncovered. As parents, we try our best to protect our children, the next generation, from being harmed. However, harms that result from gambling disorder are inevitable and can only be prevented by preventing gambling disorder in the first place. We hope 'Gambling Explained' will inspire many others to feel as passionately about this issue as we do. And lastly, to promote and drive positive change, especially for people who are affected by another individual’s gambling disorder." Kishan Patel: "As someone who has experienced gambling-harm continuously from birth, this issue is an extremely pertinent one to me due to its wide-reaching impacts on my life. I have repeatedly struggled with ideas that neither my family members nor I should have existed to suffer in the way that we have. This outlook has been difficult to displace, leading to anxieties such as repeating the same journey as my Dad, who had often described his life as like 'going to hell and back'. Despite the significance of harms on my life and loved ones, my first comprehension of gambling harm only began at the age of 22 while in my 4th year of Medical School under the directive of investigating neglected public health issues. Over the past year, besides learning that my family is not unique in our gambling harm experience, I have also come to realise the extraordinary significance of gambling harm on a population level. Additionally, it has been comforting and yet frustrating to discover public health efforts to combat gambling harm in Canada, Australia, and New Zealand; meaningful change is possible in Great Britain. Inspired by 'Tobacco Explained', 'Gambling Explained' culminates our understanding of what is known and what the industry and other stakeholders have said." Note: We do not believe it to be appropriate to use stigmatising language in this space, especially in the pursuit of a public health approach. Hence, we have avoided the term ‘gambler’ and instead used the phrase ‘individuals who gamble’. We also have avoided the use of 'problem gambler’ and instead used the phrase ‘individuals suffering from a gambler disorder’. Full version of Gambling Explained Gambling Explained as a short PowerPoint Deck

https://kellysredcardconsultancy.co.uk/ On September 30th 2020, Gambling Harm UK worked on their first awareness and education workshop alongside Red Card Consultancy Project

Gambling harm is a growing public health concern affecting individuals, families, and communities across the world. Given their current and future potential roles within healthcare teams, it's essential for medical students to be well-informed about, know how to identify, and be confident in providing treatment and support to patients who may be suffering from gambling harm. This is why our charity recently hosted a medical education course on gambling harm for third-year medical students, which used a simulation-based format with individuals with lived experience acting as real patients. The course was designed to provide medical students with an immersive and interactive learning experience that would help them better understand the complexities of gambling harm and the impact it has on individuals, families, and communities. By using a simulation-based format, the course aimed to create a realistic and engaging learning environment that would help medical students to develop their skills and knowledge in a practical and hands-on way. The course was designed by a team of experts on gambling harm and medical education, who provided an overview of the latest research in gambling harm. This was followed by a series of interactive simulations, in which individuals with lived experience acted as real patients and shared their personal stories and experiences with the medical students. The medical students were first tasked with empathetically and sensitively gathering a history from a patient presenting with a symptom that may seemingly be unrelated to gambling harm. This was then followed by a more thorough assessment of other gambling harms as well as an evaluation of the risks to the patient and others. Lastly, the student doctors worked together to provide support and resources to the patients. Through these simulations, the medical students were able to see first-hand the impact that gambling harm can have on an individual's life and the importance of asking direct questions to promote early identification. Our lived experience delivery was particularly impactful for the medical students, as it provided an authentic perspective on the challenges and complexities of gambling harm. Individuals with lived experience shared their stories and provided insight into what it's like to live with gambling harm either from their own gambling or from another person's gambling, and the impact that it has had on their lives. This helped the medical students to understand the importance of empathy and compassion when working with patients who may be struggling with gambling harm and its stigmas. The simulation-based format of the medical education course was a great success, with the medical students expressing that they found the experience to be incredibly valuable and impactful. They reported increased confidence to identify and treat patients who may be suffering from gambling harm and appreciated the opportunity to put their knowledge and skills into practice in a safe and controlled environment. In conclusion, our charity's medical education course on gambling harm was an important step in preparing medical students to tackle this growing public health concern. By using a simulation-based format with individuals with lived experience, the course provided a hands-on and immersive learning experience that helped the medical students to develop their skills, knowledge and attitudes in a practical and impactful way. We believe that this type of education is crucial for healthcare professionals, and we will continue to advocate for its importance in undergraduate education. What did you like most about the sessions today? "Having real family members affected by gambling made the session much more helpful as I could understand exactly what to do and not to do in a consultation" "Before the session, I was not aware of the [gravity] of the effect gambling has and the severity that it has on QOL. + How many people it affects + How it is not just gambling. But also the emotional/behavioural changes" "The structure of both sessions and how it was split into smaller groups which allowed us not only to learn more effectively but also improve our communication skills on sensitive topics." What did you dislike most about the sessions today? "N/A (10/10 session) I would recommend to other med schools" "There was nothing I would change" "I wouldn't mind if the session was longer." Figure 1. Column chart showing student perceptions on helpfulness of sessions towards gambling harm competencies where 1 = not at all helpful and 5 = very helpful. The mean is plotted with 95% confidence intervals. Figure 2. Column chart showing student perceptions on helpfulness of the lived experience delivery of the sessions where 1 = not at all helpful and 5 = very helpful. The mean is plotted with 95% confidence intervals. Figure 3. A donut chart showing proportions of student preferences for quantity of gambling harm education at the undergraduate level. Abstract report Footnote: "Three years ago, I was a 4th Year Medical Student at Imperial College London realising that: I had experienced gambling harm all my life Gambling harm is one of the most significant modifiable risk factors for health That the issue is extraordinarily neglected relative to other similar issues It bothered me that I had never encountered gambling harm teaching in my medical education and that this would be the norm across undergraduate teaching domestically and internationally. (Now that I'm practising medicine as an FY1 doctor, I come across gambling harm regularly but often only because I have asked.) Therefore, in October 2019, I started my efforts to change this. Since then, we’ve created resources with medical education providers with a vast reach, namely, Geeky Medics and Osmosis – Medical Education. We’ve now gone a step further in making a decisive impact in gambling harm medical education through a successful course designed and delivered by individuals with lived experience course to medical students directly. We're extremely pleased with the feedback that we have received and the impact that this course will have on the students, their loved ones, and patients. We look forward to and strive to see gambling harm being considered and tackled alongside alcohol misuse, tobacco use, and drug misuse in medical education and healthcare practice." Dr Kishan Patel Chair of the Board of Trustees at Gambling Harm UK

The industry consistently emphasises that gambling addiction affects a small minority of individuals, benefitting from the fact that gold-standard prevalence surveys were stopped after 2010 due to funding cuts. The industry reflects on the estimates generated by data from self-completion forms included in health surveys or telephone surveys. On the other hand, more recent online studies have reported much higher gambling addiction rates, but the industry has dismissed these higher rates. Additionally, the industry fails to reflect that harmful gambling and gambling addiction should be viewed as a continuum. Moreover, more than half of the harm in individuals that gamble is expected to occur at the low-risk and moderate-risk harm levels. Summary The potential for addiction is influenced by intrinsic biological factors, extrinsic factors, and factors related to the addictive agent's ability to activate the brain's risk-reward areas. Like other addictions, dopamine has a crucial and well-documented role in developing and maintaining Gambling Disorder (GD). Gambling addiction is most prevalent among younger people. Other risk factors include a parent who suffered from a gambling disorder, poor mental health status, poor general health status, unemployment, and minority ethnic backgrounds. GD is a behavioural addiction characterised by compulsive involvement in gambling activities, despite severe adverse consequences. GD is defined in the Diagnostic and Statistical Manual of Mental Disorders as "persistent and recurrent problematic gambling behaviour leading to clinically significant impairment or distress". GD has been recently included in the disorder class of "substance-related and addictive disorders". It is essential to recognise that significant harms can occur in individuals who do not meet GD's clinical threshold as the diagnosis represents the most severe end of addiction and harm. According to research from Australia, gambling harm in individuals with GD makes up only 15% of the overall gambling harm suffered by those that gamble. Most of the harms on a population level are accrued by individuals who may be on the spectrum of addiction but not at GD's threshold. These findings are analogous to the scenario for alcohol harm, where harmful drinking in those without severe dependency is responsible for more significant amounts of harm. However, unlike alcohol harm, which is grouped into a single disorder on a continuum with mild, moderate, and severe sub-classifications, gambling-harm at mild and moderate levels are often treated with contempt. Industry lobbyists often comment on prevalence statistics of those suffering the most severe harms from their gambling. Through this narrative, the industry can hide behind the idea that gambling affects only a tiny minority of the overall population, neglecting that more than half of the gambling harm in individuals that gamble is attributable to low-risk harm and moderate-risk harm. Moreover, adult prevalence statistics following 2010 are primarily limited to self-completion forms in health surveys due to a funding cut instead of the gold-standard bespoke gambling prevalence surveys. What is known? Genetics of gambling disorder Twin studies investigating the genetics of pathological gambling have found that: 18 ‘heritability of pathological gambling is estimated to be 50–60%; pathological gambling and subclinical pathological gambling are a continuum of the same disorder; pathological gambling shares genetic vulnerability factors with antisocial behaviours, alcohol dependence and major depressive disorder; genetic factors underlie the association between exposure to traumatic life‐events and pathological gambling’ Risk factors for gambling disorder (Odds Ratio): 19, 20 Parents regularly gambled but did not have a problematic relationship with gambling: 1.58 Current cigarette smoker: 2.46 ‘Other’ ethnic minority groups: 2.86 Unmanaged hypertension: 3.10 Asian/Asian British: 3.55 Black/Black British: 3.80 Unemployed: 4.02 Bad/very bad general health status: 6.17 Parents regularly gambled and had a problematic relationship with gambling: 7.32 A low Warwick-Edinburgh Mental Wellbeing score: 7.65 Prevalence of gambling harm from own gambling in adults across the world (past 12 months) Great Britain British Gambling Prevalence Surveys 2007 and 2010 (Gold-standard) 19, 21 low-risk harm: 5.1 – 5.5%, moderate-risk harm: 1.4% - 1.8%, gambling disorder harm: 0.8% - 1.2% Self-completion forms included in health surveys 2012 – 2018 20, 22-24 low-risk harm: 2.5% - 3.9% moderate-risk harm: 0.8% - 1.1% gambling disorder harm: 0.5% - 0.9% Telephone surveys 2016 -2020 25 low-risk harm: 2.0% - 3.7% moderate-risk harm: 0.9% - 1.9% gambling disorder harm: 0.3% - 0.7% Online surveys 2019 – 2020 26 low-risk harm: 7.0% - 7.2% moderate-risk harm: 2.8% - 3.3% gambling disorder harm: 2.6% - 2.7% Isle of Man 27 Gambling Prevalence Survey 2017 7.0% low-risk harm 1.5% moderate-risk harm 0.8% gambling disorder harm Northern Ireland 28 Gambling Prevalence Survey 2010 8.2% low-risk harm 5.9% moderate-risk harm 2.6% gambling disorder harm 28 Gambling Prevalence Survey 2016 6.7% low-risk harm 4.9% moderate-risk harm 2.3% gambling disorder harm Scandinavia 29 Denmark Gambling Prevalence Survey 2016 3.6% low-risk harm 1.2% moderate-risk harm 0.4% gambling disorder harm Finland Gambling Prevalence Survey 2015 8.7% low-risk harm 2.8% moderate-risk harm 0.5% gambling disorder harm Norway Gambling Prevalence Survey 2015 7.7% low-risk harm 2.3% moderate-risk harm 0.9% gambling disorder harm Sweden Gambling Prevalence Survey 2015 4.2% low-risk harm 1.3% moderate-risk harm 0.4% gambling disorder harm 30 Italy Problem Gambling Survey 2018 4.1% low-risk harm 2.8% moderate-risk harm 3.0% gambling disorder harm 31 Victoria, Australia Gambling Prevalence Study 2014 8.9% low-risk harm 2.8% moderate-risk harm 0.8% gambling disorder harm 7 Gambling Prevalence Study 2019 6.7% low-risk harm 2.4% moderate-risk harm 0.7% gambling disorder harm 32 New Zealand Meta-analysis of survey results 2010 - 2016: 3.1% low-risk harm 1.5% moderate-risk harm 0.5% gambling disorder harm 33 Health Survey 2012: 2.0% low-risk harm 1.0% moderate-risk harm 0.2% gambling disorder harm 34 National Gambling Study 2012: 5.0% low-risk harm 1.8% moderate-risk harm 0.7% gambling disorder harm 35 What the industry said? Betting and Gaming Council 16 “Rates of problem gambling in Great Britain are stable and low by international standards and we are committed to doing more to ensure safer gambling” The BGC omits consideration for the vast majority of individuals who suffer gambling-harm and instead focuses on the smaller population who suffer the most severe forms of harm. Moreover, the BGC states that gambling disorder harm rates are stable despite the absence of a gold-standard prevalence study since 2010 due to a funding cut. Michael Dugher, CEO of the Betting Gaming Council 36 “I recognise the concerns people have when around 0.6 per cent of those who bet are classed as ’problem gamblers’.” Dugher demonstrates a lack of understanding of gambling harm by stating that 0.6% of those who bet suffer from a gambling disorder. Contrastingly, the most recent gold-standard study in 2010 reflected that approximately 1.6% of individuals that gambled in the past year suffer from the most severe form of addiction. After excluding individuals who exclusively play on the lottery and those who do not gamble regularly, this rate would be far higher. Moreover, the harms suffered by non-adults are entirely omitted. Notably, the gambling disorder harm rate is much higher in 11-16 year olds where 5.1% of individuals who gambled in the past year or 1.9% of the overall population affected by gambling disorder. “Of those problem gamblers, a smaller but still significant number are ‘disordered’ or addicted gamblers.” Dugher also demonstrates a confused understanding of addiction, as the most severe form of harm is at the gambling disorder level. As ever and despite the evidence, the industry refuses to embed an understanding of addiction and gambling-harm as being on a continuum and thus ignore the harms suffered by individuals who gamble and experience low-risk harms and moderate-risk harms. “That might be a tiny fraction – and we shouldn’t forget of course that millions of people gamble safely – but the effect of addiction on these individuals and their families can be devastating.” Here the CEO of the BGC, quite unusually, recognises that family members can suffer devastating harms but omits the statistic that between 6% to 7% of adults have reported suffering affected other harms in Great Britain. Michael Dugher, CEO of the Betting Gaming Council 37 “For millions of people, it is a carefree leisure activity, and they do so perfectly safely and perfectly responsibly.” Dugher uses the term “millions of people” to describe the number of individuals who gamble with no significant consequences while neglecting that millions of people suffer significant harm from gambling. “But we recognise, as do the Government, as do campaigners and others that there is a small group of people who can have a problem with this, and in some cases it can be very, very severe.” Dugher suggests that there is only a small group of people who suffer harm from gambling. Furthermore, Dugher and colleagues often implies that campaigners wanting reform are prohibitionists and have an issue with gambling as a leisure activity, despite evidence from lived experience campaigners showing that this claim is not valid. 38 “What we're saying is you've got to get the regulation right because what we don't want is to drive customers away from safer gambling on the regulated high standard sites to the illegal black market offshore companies.” Paradoxically, Dugher highlights the concern of black market offshore companies while failing to recognise that before 2014, a large number of remote operators were not regulated, and the vast majority of companies continue to base offshore to avoid the UK’s corporation tax. Moreover, remote operators are global by nature and thus have customers in the black market in other countries. Brigid Simmonds, Chair of the Betting and Gaming Council 39 “Just as we intervene with our customers so banks should as well:” Simmonds deflects responsibility for safer gambling to banks, such that just like operators, banks should intervene to prevent gambling-harm. However, operator interventions are often limited to safer gambling messages as operators seldom close accounts that are profit-making for the industry. “We take our responsibility to our customers incredibly seriously and we are determined to raise standards and improve safer gambling,” Simmonds then repeats vague commitments to raising standards and improving safer gambling. Brigid Simmonds, Chair of the Betting and Gaming Council 40 … "we have worked together on BetRegret"… Simmonds comments on her role in developing the “BetRegret” campaign, which has been widely criticised for furthering stigma by placing responsibility on customers, potentially increasing self-blame, and for being drowned out by the sheer volume of contradictory betting advertisements. Michael Dugher, CEO of the Betting Gaming Council 41 “Place you bets now please… #RouletteBoy” "I thought you liked casinos, young Matt?" Dugher uses social media to mock someone who is now abstinent; in doing so, he demonstrates his contempt for those who have suffered gambling-harm, the legacy effects of those harms, and the chronic nature of addiction. References 7. Browne M, Langham E, Rawat V, Greer N, Li E, Rose J. Assessing gambling-related harm in Victoria: a public health perspective. Victorian Responsible Gambling Foundation. 2016. 16. UK Parliament – Betting and Gaming Council. Betting and Gaming Council – Written evidence (GAM0068). 2019. Available from: https://committees.parliament.uk/writtenevidence/154/html/ [Accessed: 29th March 2021] 17. Davies R. 25,000 children in Britain are problem gamblers, report finds. The Guardian. 12 December 2017. Available from: https://www.theguardian.com/society/2017/dec/12/children-britain-problem-gamblers-report [Accessed: 29th March 2021] 18. Lobo DSS, Kennedy JL. Genetic aspects of pathological gambling: a complex disorder with shared genetic vulnerabilities. Addiction. 2009;104(9): 1454–1465. Available from: doi:10.1111/j.1360-0443.2009.02671.x 19. Wardle H, Moody A, Spence S, Orford J, Volberg R, Jotangia D, et al. British Gambling Prevalence Survey 2010. The Gambling Commission. 2011. 20. Seabury C, Wardle H. Gambling behaviour in England & Scotland Headline findings from the Health Survey for England 2012 and Scottish Health Survey 2012. NatCen. 2014. 21. Wardle H, Sproston K, Orford J, Erens B, Griffiths M, Constantine R, et al. British Gambling Prevalence Survey 2007. NatCen. 2007 22. Gambling Commission. Participation in gambling and rates of problem gambling - England 2016 - Statistical report. Gambling Commission. 2016. 23. Barnfield-Tubb J, Francis C. Gambling participation in 2019: behaviour, awareness and attitudes. 2020. Available from: https://www.gamblingcommission.gov.uk/PDF/survey-data/Gambling-participation-in-2019-behaviour-awareness-and-attitudes.pdf [Accessed: 29th March 2020] 24. Conolly A, Fuller E, Jones H, Maplethorpe N, Sondaal A, Wardle H. Gambling behaviour in Great Britain in 2015: Evidence from England, Scotland and Wales. NatCen. 2017. 25. Gunstone B, Gosschalk K, Joyner O, Diaconu A, Sheikh M. The impact of the COVID-19 lockdown on gambling behaviour, harms and demand for treatment and support. Gambling Research Exchange Ontario. 2020. 26. Gambling Commission. Gambling behaviour in 2020: Findings from the quarterly telephone survey. Gambling Commission; 2021. Available from: https://beta.gamblingcommission.gov.uk/statistics-and-research/publication/year-to-december-2020 [Accessed: 30th March 2021] 27. Butler N, Quigg Z, Bates R, Sayle M, Ewart H. Isle of Man Gambling Survey 2017: Prevalence, methods, attitudes. Public Health Institute, Liverpool John Moores University. 2018. 28. Dunne S, Flynn C, Sholdis J. 2016 Northern Ireland Gambling Prevalence Survey. Northern Ireland Statistics and Research Agency. 2017. 29. Pallesen S. PREVALENCE OF GAMBLING PROBLEMS IN THE NORDIC COUNTRIES. [Presentation] University of Bergen. 30th May 2017. 30. Folkhälsomyndigheten. Published Material. Available from: www.folkhalsomyndigheten.se/publicerat-material [Accessed: 10th January 2021] 31. Stradbrooke S. Italy gambling survey casts doubt on effectiveness of advert ban. CalvinAyre.com. 19 October 2018. Available from: https://calvinayre.com/2018/10/19/business/italy-gambling-survey-advertising-effectiveness/ [Accessed: 28th February 2021] 32. Victorian Responsible Gambling Foundation. FACT SHEET 3: PROBLEM GAMBLING SEVERITY INDEX (PGSI) Victorian Population Gambling and Health Study (2018-2019). 2020. Available from: https://responsiblegambling.vic.gov.au/resources/publications/fact-sheet-3-problem-gambling-severity-index-pgsi-762/ [Accessed: 30th March 2021] 33. Ministry of Health New Zealand. Health and Lifestyle Survey – Monitoring gambling harm and knowledge. Available from: https://www.health.govt.nz/our-work/mental-health-and-addiction/addiction/gambling/gambling-research-and-evaluation/key-information-sources-gambling-harm-and-service-utilisation/health-and-lifestyle-survey-monitoring-gambling-harm-and-knowledge [Accessed: 28th February 2021] 34. Rossen F. Gambling And Problem Gambling: Results Of The 2011/12 New Zealand Health Survey Final Report. Ministry of Health New Zealand. 2015. 35. Bellringer M. New Zealand 2012 National Gambling Study: Gambling Harm And Problem Gambling. Ministry of Health New Zealand. Report number: 2, 2014. 36. Dugher M. We Need Big Changes And A Race To The Top On Standards In Gambling. Available from: https://bettingandgamingcouncil.com/news/michael-dugher [Accessed: 29th March 2021] 37. Hirst I. Government must tackle rates of gambling addiction which is a ‘crisis waiting to happen’, according to MP. Dewsbury Reporter. 7 January 2021. Available from: https://www.dewsburyreporter.co.uk/news/opinion/government-must-tackle-rates-gambling-addiction-which-crisis-waiting-happen-according-mp-3087969 [Accessed: 30th March 2021] 38. Gambling Harm UK. Lived Experience Community Respond to Remote Customer Interaction Call for Evidence. Available from: https://www.gamblingharm.com/post/lived-experience-community-respond-to-remote-customer-interaction-call-for-evidence [Accessed: 31st March 2021] 39. Hancock A. Betting industry body hits out at role of banks and tech in addiction. Financial Times. 3 February 2020. Available from: https://www.ft.com/content/4cc7cfa2-4692-11ea-aeb3-955839e06441 [Accessed: 30th March 2021] 40. @BrigidSimmonds. ‘Many congratulations Zoe, we have worked together on BetRegret & your knowledge & expertise in advertising, marketing & how charities can work with other partners & industry will be vital to your new role @GambleAware’. [cited 14 January 2021] Available from: https://twitter.com/BrigidSimmonds/status/1349755154640347137 [Accessed: 30th March 2021] ] 41. Boycott-Owen M. Gambling industry chief accused of mocking recovering addict on Twitter. The Telegraph. 5 February 2021. Available from: https://www.telegraph.co.uk/news/2021/02/05/gambling-industry-chief-accused-mocking-recovering-addict-twitter/ [Accessed: 30th March 2021]

Donations to gambling-harm research, education, and treatment efforts are made voluntarily. RET funding targets are currently based on an arbitrary percentage of net losses, and minimum funding targets have been consistently missed. Some operators have maintained their status as voluntary contributors in reducing and preventing gambling harm by donating as little as £5 across a year. Therefore, unsurprisingly, UK RET funding is also drastically lower than countries, including Canada, New Zealand, and Australia, that hold a public health approach to preventing gambling harm. Chronic underfunding and a lack of independence from the industry have meant that steps to tackle and prevent gambling harm have been woefully limited. Firstly, there is a lack of understanding of the significance of gambling harms on the population's health. Additionally, there is an absence of dedicated studies, education, and treatment efforts to prevent and tackle disproportionate gambling harm in ethnic minority communities. At the time of writing, gambling-harm is also poorly recognised in health and social care, with gambling absent from guidelines and curriculums for health care professionals. Lastly, current safer gambling initiatives place the onus on the customer and are widely criticised as thin-veiled attempts to advertise brands. Summary Investment into gambling-harm research, education, and treatment (RET) is currently made voluntarily. At present, minimum funding targets are not set on need and are based on an arbitrary percentage of net losses. However, due to donations' voluntary nature, the minimum funding targets have been missed for the past two consecutive years. Meanwhile, operators have maintained their status as voluntary contributors to RET efforts by donating as little as £5 across a period of 12 months. RET funding in the UK is significantly lower than in other countries where a public health approach to gambling harm has been enacted. Notably, RET funding shortfalls reflect a disparity between the industry’s purported commitments to reducing gambling harm and their lack of actions in delivering meaningful change. Moreover, some of the more substantially funded RET initiatives have been criticised for industry ties and a lack of independent and critical evaluations evidencing their effectiveness. The UK is relatively far behind in terms of research into gambling-related harms relative to some other countries. Research evaluating the significance of harm to health on the UK population through measurements of disability-adjusted life years, and studies measuring the costs of impact, are desperately needed as part of a public-health approach. Despite being the primary funding source of research, the industry has created an atmosphere of doubt and regularly calls for more research. For over a decade now, research has consistently reflected that individuals from ethnic minority backgrounds are several times more likely to be affected by gambling harm. However, dedicated studies to explore this phenomenon further have been limited and largely absent. Furthermore, treatment statistics reflect that individuals from ethnic minority backgrounds are far less likely to receive specialist help and support. Similarly, despite significant evidence of the effect of gambling-harm on health, gambling is yet to feature in medical education curriculums for medical students, speciality curriculums for Psychiatry and General Practice, or NICE guidelines for health care practitioners. Instead, gambling-harm specialist services reach a fraction of the harmed population, which is relatively far fewer than the results achieved by substance use treatment services. Gambling education was recently introduced into the PSHE statutory guidance; however, the framework does not apply to independent schools and is only statutory for years 10 and 11. Additionally, gambling features as one of the learning objectives in "internet safety and harms" contrastingly, "drugs, alcohol, and tobacco" are covered as a separate topic with their distinct learning objectives. Safer gambling initiatives and awareness campaigns organised or funded by the industry place the onus for safe gambling on the consumer. Such campaigns are in stark contrast to the evidence, which reflects a significant genetic component to addiction. Thus, responsible gambling messages have been widely criticised as being thinly veiled advertisements. What is known? Research, Education, and Treatment spending and investment Research, Education, and Treatment (RET) spending in Great Britain is comparable to that of some states in the US, and is relatively a fraction of what is spent in Canada, Australia, and New Zealand GambleAware (the charity responsible for managing and distributing RET efforts and funding in Great Britain) asks all those who profit from the gambling industry in Great Britain to donate a minimum of 0.1% of their annual Gross Gambling Yield (GGY) directly to GambleAware 2017 - 2018: 0.07% (£9.5m/£14.4bn) 73 2018 - 2019: 0.07% (£9.6m/£14.3bn) 74 2019 - 2020: 0.07% (£10.1m/£14.2bn) 75 A review by the Gambling Commission in 2018, which drew on input from GambleAware and the Advisory Board for Safer Gambling (RSGB), reported that hypothetical RET scenarios could cost between £21.5m to £67.0m 76 The Gambling Commission compared RET spending in Great Britain with other countries in 2018 76 Specialist treatment services Source of referrals into treatment services Gambling 77 Self, family, and friends: 92% Health services and social care: 3% Criminal justice: 1% Substance misuse services: 0% Other: 3% Alcohol only 78 Self, family, and friends: 66% Health services and social care: 22% Criminal justice: 6% Substance misuse services: 3% Other: 4% Non-opiate and alcohol 78 Self, family, and friends: 64% Health services and social care: 17% Criminal justice: 10% Substance misuse services: 3% Other: 6% Non-opiate only 78 Self, family, and friends: 66% Health services and social care: 15% Criminal justice: 10 Substance misuse services: 2% Other: 7% Opiate only 78 Self, family, and friends: 56% Health services and social care: 9% Criminal justice: 25% Substance misuse services: 7% Other: 3% Percentage of populations reached by National Gambling Treatment Services 77 0.02% of individuals who gamble and suffer low-risk harm 0.03% of affected others completed treatment 0.30% of individuals who gamble and suffer moderate-risk harm 1.00% of individuals who gamble and suffer gambling disorder harm in Great Britain completed treatment Disproportionately affected population groups 79 Observed = % of population receiving treatment in 2019/20, Expected = % of population affected by gambling disorder harms from the last British Gambling Prevalence Study) Age 16-24 year olds: Observed: 11% & Expected: 30% 25-34 year olds: Observed: 42% & Expected: 26% Ethnicity White: Observed: 89% & Expected: 66% Asian or Asian British: Observed: 5% & Expected: 19% Black or Black British: Observed: 3% & Expected: 9% Other: Observed: 3% & Expected: 7% Research Research gaps in the literature Population health measures of loss of healthy life have never been conducted in the GB population (discussed in more detail in chapter 1: gambling and health) Prevalence of affected other harms were not measured at all prior to 2019 Great Britain has only had one cost of impact studies, and this has been limited to some of the direct costs to the government. Cost of impact studies for gambling disorder gambling in Sweden and Czech Republic have reported that costs are approximately twice the amount of tax revenue generated 80, 81 The last gold-standard prevalence study was conducted in 2010 The only dedicated quantitative study of gambling-harm in ethnic minority communities was published in 2020 using secondary data following a consistent picture of disproportionate harms in ethnic minority communities across prevalence studies since 2007 82, 83 Out of 116 registered clinical studies, only one is in the UK 84 Funding gaps The Adult Psychiatry Morbidity Survey (APMS) 2014 omitted gambling despite finding a significant relationship between gambling and suicidal harm in 2007 Gambling Commission spending on prevalence studies research 86–94 2009/10: < £446,000 2010/11: < £368,000 2011/12: £192,000 2012/13: £51,000 2013/14: £169,000 2014/15: £275,000 2015/16: £652,389 2016/17: £651,634 2017/18: £778,357 2018/19: £795,143 Issues with education PSHE Curriculum (updated September 2020 to include gambling) 94 Internet safety and harms the similarities and differences between the online world and the physical world, including: the impact of unhealthy or obsessive comparison with others online (including through setting unrealistic expectations for body image), how people may curate a specific image of their life online, over-reliance on online relationships including social media, the risks related to online gambling including the accumulation of debt, how advertising and information is targeted at them and how to be a discerning consumer of information online. how to identify harmful behaviours online (including bullying, abuse or harassment) and how to report, or find support, if they have been affected by those behaviours. Drugs, alcohol and tobacco the facts about legal and illegal drugs and their associated risks, including the link between drug use, and the associated risks, including the link to serious mental health conditions. the law relating to the supply and possession of illegal substances. the physical and psychological risks associated with alcohol consumption and what constitutes low risk alcohol consumption in adulthood. the physical and psychological consequences of addiction, including alcohol dependency. awareness of the dangers of drugs which are prescribed but still present serious health risks. the facts about the harms from smoking tobacco (particularly the link to lung cancer), the benefits of quitting and how to access support to do so. What the industry said? Betting and Gaming Council 36 “Importantly, the largest BGC members are committing an additional £100 million to research, education and treatment (RET) over the next four years.” The BGC announced a voluntary commitment to increase RET funding following calls for a statutory levy that would mean independence between the industry and prevention and treatment efforts. At the end of the four years, funding will increase ten-fold, demonstrated the industry’s ability to fund RET despite it chronically underfunding it for several years. This voluntary commitment also signals the industry’s acceptance that existing RET measures are insufficient. Initially, the funds were to be allocated to Action Against Gambling Harms. However, with little notice, the BGC revoked this and instead changed the recipient to GambleAware. Researchers have stressed their concerns to decision-makers and highlighted the need for a levy that funds prevention and treatment while being free from real or perceived industry influence. The researchers also reflected that the unilateral decision-making in funding allocations is one way of the industry exerting influence. 95 Peter Jackson, CEO of Flutter Entertainment PLC 96 “GambleAware has a long track record in commissioning treatment services and working with providers for the benefit of problem gamblers. Through the provision of this unprecedented level of financial support, we aim to achieve a step-change in the treatment and counselling available to those experiencing gambling-related harm. Through the provision of this unprecedented level of financial support, we aim to achieve a step-change in the treatment and counselling available to those experiencing gambling-related harm.” Jackson focusses on the need for a step-change in treatment services, implying that most of the incoming funds for RET will be spend on treatment. Worryingly, public health monitoring of gambling-harm is still limited to counting the numbers of individuals affected in the past-year. To allow gambling-harm to be considered in the context of other issues and for efforts to tackle gambling-harm to be monitored appropriately, there is a desperate need for research that evaluates the significance of harms instead of simply the numbers affected. Nigel Huddleston, Minister for Sport, Tourism and Heritage 97 “We have been clear that the gambling industry has a responsibility to protect people from gambling-related harm and support those who have been affected. I welcome the Betting and Gaming Council now outlining how it will deliver on leading operators’ pledges to bolster research, education and treatment. We will monitor closely the progress of these new measures and continue to encourage the wider industry to step up” Huddleston reports on the industry's need to keep up with the Gambling Commission’s licensing objectives and reflects trust that the industry will now tackle and prevent gambling-harm voluntarily. Betting and Gaming Council 16 “The vast majority of gambling activity in Great Britain is carried out in a fair and transparent fashion”…”most people who gamble in this country do so with companies licensed by the regulator.” The BGC take the minority view as only about a third of the population agree that gambling is carried out in a fair and transparent fashion. Ian Proctor, Chairman of Flutter UK & Ireland 98 “We believe the way forward is taking a risk-based approach founded on evidence. This means not considering affordability in isolation, but in the context of many other data points including frequency of bets and deposits, personal circumstances, time, products used and, crucially, changes in usual patterns of behaviour for each customer. When all these inputs are considered together, we can take an impactful approach to player protection.” Proctor identifies the need to be evidence-led and for affordability to be judged alongside other data points, implying that such basic measures are not utilised already in player protection. Responsible Gambling Fund 99 “RGF said the funding partnership with the Great Foundation was unworkable thanks to increasing interference from gambling industry stakeholders pressuring the Great Foundation as to how to spend the money. A spokesman for the RGF said the gambling industry “has much stronger interest in funding treatment than it does in funding research”. The RGF reported that the industry had a substantial interest to interfere and disrupt RET efforts. Martin Lycka, Senior VP of US Regulatory Affairs & Responsible Gambling at Entain Group 100 “Our approach, Advanced Responsibility and Care (ARC), will combine the best academic research and life experience with industry-leading data science and AI to create what we believe is the first pro and personalised approach to player protection. And we'll be trialling this in the UK this summer.” Lycka associates the ARC with academic research and other technologies to suggest that emerging player protections efforts will be more meaningful. References 73. GambleAware. Annual Review 2016/17. 2017. Available from: https://about.gambleaware.org/media/1628/gambleaware-annual-review-2016-17.pdf [Accessed: 9th November 2019] 74. BeGambleAware. 2018/19 supporters. Available from: https://www.begambleaware.org/201819-supporters [Accessed: 30th March 2021] 75. BeGambleAware. 2019/20 supporters. Available from: https://www.begambleaware.org/201920-supporters [Accessed: 30th March 2021] 76. Gambling Commission. Reviewing the research, education and treatment (RET) arrangements. Gambling Commission; 2018. Available from: https://www.gamblingcommission.gov.uk/PDF/Review-of-RET-arrangements-February-2018.pdf [Accessed 31st March 2021] 77. GambleAware. Annual Statistics from the National Gambling Treatment Service (Great Britain). GambleAware. 2020. 78. Public Health England. Adult substance misuse treatment statistics 2019 to 2020: report. GOV.UK; 2020. 79. Gambling Harm UK. Treatment Statistics from 2018-2020 in context. Available from: https://www.gamblingharm.com/post/treatment-statistics-in-context [Accessed: 31st March 2021] 80. Hofmarcher T, Romild U, Spångberg J, Persson U, Håkansson A. The societal costs of problem gambling in Sweden. BMC Public Health. 2020;20(1): 1921. Available from: doi:10.1186/s12889-020-10008-9 81. Winkler P, Bejdová M, Csémy L, Weissová A. Social Costs of Gambling in the Czech Republic 2012. Journal of Gambling Studies. 2017;33(4): 1293–1310. Available from: doi:10.1007/s10899-016-9660-4 82. Gunstone B, Gosschalk K. Gambling among adults from Black, Asian and Minority Ethnic communities: a secondary data analysis of the Gambling Treatment and Support study. GambleAware; 2019. 83. Gambling Harm UK. Gambling in BAME & Risk Factors. Available from: https://www.gamblingharm.com/post/gambling-in-bame-and-other-risk-factors [Accessed: 31st March 2021] 84. ClinicalTrials.gov. Search of: Gambling - List Results - ClinicalTrials.gov. Available from: https://clinicaltrials.gov/ct2/results?recrs=&cond=Gambling&term=&cntry=&state=&city=&dist= [Accessed: 31st March 2021] 85. Gambling Commission. Annual report and accounts 2009/10: keeping gambling fair and safe for all. 2010. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/247697/0199.pdf [Accessed: 25th March 2020] 86. Gambling Commission. Annual report and accounts 2010/11: keeping gambling fair and safe for all. 2011. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/247408/1115.pdf [Accessed: 25th March 2020] 87. Gambling Commission. Annual report and accounts 2011/12: keeping gambling fair and safe for all. 2012. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/247021/0253.pdf [Accessed: 25th March 2020] 88. Gambling Commission. Annual report and accounts 2012/13: keeping gambling fair and safe for all. 2013. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/246662/0344.pdf [Accessed: 25th March 2020] 89. Gambling Commission. Annual report and accounts 2013/14: keeping gambling fair and safe for all. 2014. Available from: https://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2013-14.pdf [Accessed: 25th March 2020] 90. Gambling Commission. Annual report and accounts 2014/15: keeping gambling fair and safe for all. 2015. Available from: http://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2014-15.pdf [Accessed: 25th March 2020] 91. Gambling Commission. Annual report and accounts 2015/16: keeping gambling fair and safe for all. 2016. Available from: http://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2015-16.pdf [Accessed: 25th March 2020] 92. Gambling Commission. Annual report and accounts 2016/17: keeping gambling fair and safe for all. 2017. Available from: https://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2016-2017.pdf [Accessed: 25th March 2020] 93. Gambling Commission. Annual report and accounts 2017/18: keeping gambling fair and safe for all. 2018. Available from: https://www.gamblingcommission.gov.uk/PDF/Annual-report-and-accounts-2017-2018.pdf [Accessed: 25th March 2020] 94. Department for Education. Relationships Education, Relationships and Sex Education and Health Education. Department for Education. 2019. 95. Wardle H, Banks J, Bebbington P, Blank L, Bowden Jones Obe H, Bramley S, et al. Open letter from UK based academic scientists to the secretaries of state for digital, culture, media and sport and for health and social care regarding the need for independent funding for the prevention and treatment of gambling harms. [Online] The BMJ. BMJ Publishing Group; 2020. Available from: doi:10.1136/bmj.m2613 96. Betting & Gaming Council. Support for the Treatment of Gambling Harm. Available from: https://bettingandgamingcouncil.com/commitments/safer-gambling-increasing-support-for-the-treatment-of-gambling-harm [Accessed: 29th March 2021] 97. Betting & Gaming Council. COMMITMENT 2: Increasing support for the treatment of gambling harm. Available from: https://bettingandgamingcouncil.com/safer-gambling-initiatives/research-education-treatment [Accessed: 29th March 2021] 98. Proctor I. Flutter: Gambling industry is listening, and responding, to addiction concerns. CityAM. 12 February 2021. Available from: https://www.cityam.com/flutter-gambling-industry-is-listening-and-responding-to-addiction-concerns/ [Accessed: 29th March 2021] 99. Mason T. Gambling charities solve dispute by merging. Civil Society News. 15 December 2011. Available from: https://www.civilsociety.co.uk/news/gambling-charities-solve-dispute-by-merging.html [Accessed: 29th March 2021] 100. Lycka M. Martin Lycka: The age of responsible gambling. SBC Americas. 11 March 2021. Available from: https://sbcamericas.com/2021/03/11/martin-lycka-the-age-of-responsible-gambling/ [Accessed: 30th March 2021]

Public opinion of gambling has deteriorated significantly over the past decade; there are well-grounded concerns regarding industry exploitation of individuals on the addictive spectrum. Estimates suggest that half of the online industry's profits are generated from harmful gambling, where players are more likely to gamble, lose more money, and gamble at unsociable hours. The Gambling Commission has increasingly fined operators for regulatory failings, yet operators continue to profit substantially from failures and harmful gambling. Summary Over the past decade, public opinion of gambling and the way it's conducted in Great Britain has consistently and significantly deteriorated. There are well-grounded concerns of the regulated industry's exploitative nature towards individuals on the addiction spectrum. Ultimately, there is no requirement for operators to prevent harm in those showing signs of addiction, and evidently, the industry's bottom-line benefits from these high-value customers. There is significant analysis reflecting that individuals on the addiction spectrum: wager larger amounts, lose more money, gamble more frequently, and gamble at less social hours relative to individuals who gamble but do not suffer gambling harm. By utilising this understanding, estimates indicate that more than half of the industry’s profits are derived from players who are on the addiction spectrum. In line with this analysis, the Gambling Commission's evidence using data from nine different operators reflects that significant percentages of deposits are universally derived from a small minority of VIP scheme customers. Over the past few years, the Gambling Commission has increasingly fined operators who are found to have exploited customers or for other failings through regulatory settlements. Moreover, operators have been reported to coerce individuals into settlements that repay victims of thefts related to gambling on the condition of non-disclosure agreements or confidentiality provisions that may, in turn, discourage the Gambling Commission from being informed by incidents of failings. Lastly, there are concerns that gambling-harm disproportionately affects ethnic minority communities and individuals in areas of deprivation, which may be in part due to the agglomeration of betting shops in these areas. What is known? Public opinion of how gambling is conducted Percentage of adults agreeing that gambling is conducted fairly and can be trusted 25 2010: 48% 2011: 49% 2012: 49% 2013: 42% 2014: 41% 2015: 39% 2016: 34% 2017: 33% 2018: 30% 2019: 29% Gambling industry profits from harmful gambling Research of bank data reflects that the top 1% of individuals that gamble surveyed spent 58% of their income on gambling 8 Online gambling VIP Schemes and Deposits comparison (online) 117 Respublica estimates 58.6% of online gambling profits are from individuals who gamble and who suffer significant amounts of harm 118 Individuals suffering low-risk harm: 17.0% Individuals suffering moderate-risk harm: 17.1% Individuals suffering gambling disorder harm: 24.5% Kindred’s self-reported data reflects that approximately 33.6% of the company’s revenue was accrued by individuals with probable gambling disorder in 2020 119 Geography of betting shops Betting shops in Great Britain are overwhelmingly in areas of deprivation by multiple deprivation 19% of betting shops are in the top 10% most deprived postcodes by multiple deprivation 16%, 2nd decile 16%, 3rd decile 13%, 4th decile 10%, 5th decile 8%, 6th decile 6%, 7th decile 5%, 8th decile 4%, 9th decile 2% of betting shops are in the bottom 10% of most deprived postcodes by multiple deprivation (least deprived postcodes) By ethnicity 83 Relative difference between ethnic distribution of populations around betting shops and national averages (2011 census) All betting shops White: -6.7% Mixed: 22.1% Asian: 40.6% Black: 49.8% Other: 56.5% Betting shops in postal districts with 10 or more betting shops White: -27.7% Mixed: 88.6% Asian: 160.5% Black: 231.5% Other: 222.6% Gambling industry fines by UK Gambling Commission 120,121 2015: £1.88M 2016: £2.01M 2017: £10.74M 2018: £27.20M 2019: £15.77M 2020: £33.93M What the industry said? Brigid Simmonds, Chair of the Betting and Gaming Council 122 “But you are right in that if people start asking them for their tax return, as somebody as suggested, people will start walking away - I mean, I wouldn't share my tax return with anybody. We will be driving people to a black market. We will be doing what they've done in Sweden, where the numbers are up to about 40% of people, because they've been too tight. We've got to be balanced. We believe the way forward is taking a risk-based approach founded on evidence. This means not considering affordability in isolation, but in the context of many other data points including frequency of bets and deposits, personal circumstances, time, products used and, crucially, changes in usual patterns of behaviour for each customer. When all these inputs are considered together, we can take an impactful approach to player protection. The vast majority of gambling activity in Great Britain is carried out in a fair and transparent fashion.” Simmonds utilises a strawman argument by failing to recognise that gambling companies already have access to financial data through credit check companies. Still, instead of using data analytics to protect customers, operators use data analytics for profit. Ian Proctor, Chairman of Flutter UK and Ireland 98 “At Flutter we believe it is important to ask ourselves the big questions and that the Government’s review of the Act represents a chance for real change. Gambling has gone through a technical transformation over the last 15 years, and the rules have not kept pace.” Proctor states that Flutter believes in self-reflection and that the review of the Act represents a chance for real change. Notably, Proctor points out that the need for gambling reform is due to a technical transformation instead of concerns for gambling-harm as a public health issue with evidence that emerged as early as 2007. Proctor also reflects a sentiment that there is a need for rules with this industry, which suggests that the industry cannot self-regulate. Brigid Simmonds, Chair of the Betting and Gaming Council 123 “Just as pubs, in my former incarnation, are important to high streets so are betting shops. Betting shops and their managers really care about their customers, and they want to make sure that they have the right experience but they also stay safe” Simmonds states that betting shops are important to the high-street and compares them to pubs. The Chair of the BGC also states that betting shops and managers care about their customers and that they want to make sure that they stay safe. Neil Goulden, Chair of the Responsible Gambling Trust and the Association of British Bookmakers 124 [Issue of problem gambling] “dwarfed by problems with drug use, alcohol abuse and obesity” “[Bookmakers] would not have released data or have taken the actions it continues to take in prevention of harm without my personal influence and urging,” [urging] “the industry to take consumer product protection more seriously or face more bad press and a loss of government and consumer confidence”. Goulden mendaciously diminishes the significance of gambling-harm relative to other public health issues such as drug use, alcohol abuse, and obesity. Scientific evidence and commentary from the World Health Organisation, directly contrasts with these statements. Goulden states that his ties and influence with the industry, combined with his role within safer gambling efforts have caused the industry to be more open and prevent harm. Goulden reflects that he could push the industry to take matters more seriously with the warning of public relation repercussions and a loss of government and consumer confidence. Through this, it is clear that the action against gambling-harm by the industry would still be motivated by profits and factors relating to profit-making, instead of a desire to be principled in not causing harm. Ulrik Bengtsson, CEO of William Hill 125 “Claiming the black market doesn’t exist is like saying the Earth is flat” “I do realise we have a huge obligation to make sure our customers play within their means. We should do a reasonable amount of affordability checks, but it can’t be to the extent where it is so intrusive that we force these people out. So it’s all about finding the right balance to keep the customers in the UK ecosystem; to keep them safe, to secure the tax base and to secure the industry” Bengtsson implies that individuals with lived experience and other campaigners for reform deny the existence of the black market. Spokesperson for Ladbrokes 126 “we recognise that (name removed) has problems with his gambling and have therefore shared the details of our multi-operator self-exclusion scheme with him” Ladbrokes reflects that their process for preventing gambling-harm in individuals with a loss of control is to send these individuals a message referring them to self-exclusion schemes. References 8. Muggleton N, Parpart P, Newall P, Leake D, Gathergood J, Stewart N. The association between gambling and financial, social and health outcomes in big financial data. Nature Human Behaviour. 2021;5(3): 319–326. Available from: doi:10.1038/s41562-020-01045-w [Accessed: 22nd March 2021] 25. Gunstone B, Gosschalk K, Joyner O, Diaconu A, Sheikh M. The impact of the COVID-19 lockdown on gambling behaviour, harms and demand for treatment and support. Gambling Research Exchange Ontario. 2020. 83. Gambling Harm UK. Gambling in BAME & Risk Factors. Available from: https://www.gamblingharm.com/post/gambling-in-bame-and-other-risk-factors [Accessed: 31st March 2021] 98. Proctor I. Flutter: Gambling industry is listening, and responding, to addiction concerns. CityAM. 12 February 2021. Available from: https://www.cityam.com/flutter-gambling-industry-is-listening-and-responding-to-addiction-concerns/ [Accessed: 29th March 2021] 117. Gambling Commission. What is a VIP. [Presentation] Gambling Commission. 118. UK Parliament. Chapter 5: Gambling-related harm. Available from: https://publications.parliament.uk/pa/ld5801/ldselect/ldgamb/79/7908.htm [Accessed: 20th September 2020] 119. Kindred Group plc. Our journey towards zero. Available from: https://www.kindredgroup.com/sustainability/our-journey-towards-zero/ [Accessed: 27th March 2021] 120. Gambling Business Group. FOI Request: Info Reg Settlements 070220. Available from: https://gamblingbusinessgroup.co.uk/wp-content/uploads/2020/03/FOI-Request-Info-Reg-Settlements-070220.pdf [Accessed: 27th March 2021] 121. Gambling Industry Fines. Gambling Industry Fines. Available from: https://gamblingindustryfines.com/ [Accessed: 27th March 2021] 122. Racing TV. ‘Racing must stand alongside betting industry’ in Gambling Act review: Simmonds. Racing TV. 13 December 2020. Available from: https://www.racingtv.com/news/racing-must-stand-alongside-betting-industry-in-gambling-act-review-simmonds [Accessed: 29th March 2021] 123. Burley Hannah. ‘Sponsorship in sport should be allowed’ - The Big Interview with Brigid Simmonds, chair of the Betting and Gaming Council. The Scotsman. 10 February 2020. Available from: https://www.scotsman.com/business/sponsorship-sport-should-be-allowed-big-interview-brigid-simmonds-chair-betting-and-gaming-council-1555471 [Accessed: 30th March 2021] 124. Ramesh R. Gambling charity chair lobbied for bookmakers, documents show. The Guardian. 6 January 2016. Available from: https://www.theguardian.com/society/2016/jan/06/documents-reveal-gambling-charity-chair-conflict-of-interest [Accessed: 30th March 2021] 125. Racing TV. ‘Racing must stand alongside betting industry’ in Gambling Act review: Simmonds. Racing TV. 13 December 2020. Available from: https://www.racingtv.com/news/racing-must-stand-alongside-betting-industry-in-gambling-act-review-simmonds [Accessed: 29th March 2021] 126. UK Rehab. Gambling Addict Says Betting Companies Are Not Doing Enough to Help. Available from: https://www.uk-rehab.com/behavioural-addictions/problem-gambling/gambling-addict-says-betting-companies-are-not-doing-enough-to-help/ [Accessed: 30th March 2021]

Although the Gambling Act 2005 clearly states gambling should be prevented as a source of crime or disorder, it has been linked to opportunity, duress, violence, and negligence crimes. Moreover, international and national studies have shown a disproportionate number of individuals suffering from gambling addiction in the prison population. Furthermore, gambling-related harm is omitted from screening as first-stage health assessment in correctional services dictated by NICE guidelines includes substance abuse but omits gambling. The industry has drastically downplayed the magnitude of crimes linked to gambling via blame deflection on the black market. Summary The Gambling Act 2005 sets out three licensing objectives 42 preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime ensuring that gambling is conducted in a fair and open way protecting children and other vulnerable persons from being harmed or exploited by gambling. Gambling has been linked to crimes of: opportunity such as theft, duress such as drug trafficking to pay debt, & negligence such as leaving children unsupervised As well as crimes to facilitate gambling, gambling can conversely be used to facilitate crime by offering a means for money laundering. Moreover, crimes of abuse, intimidation, and violence can be related to gambling and may be induced by the psychologically taxing effects of harms on individuals that gamble. Familicide, which is at the extreme end of family violence harms, has seldom been measured or reported in research. Moreover, as well as potentially being victims of gambling-related crime, affected others have also been reported to commit crimes such as petty theft and illegal drug use. Studies worldwide have identified that prison populations contain disproportionate numbers of individuals who have suffered gambling harm. Furthermore, a significant percentage of the crime committed by individuals suffering from gambling disorder is directly gambling-related. NICE guidelines on "Mental health of adults in contact with the criminal justice" at first-stage health assessment include alcohol and substance misuse but omits gambling. The industry downplays the significance of gambling-related crime in Great Britain, primarily by suggesting that Great Britain's situation is somehow better than in other countries and by deflecting blame for crime to black market operators. What is known? Public perception of gambling related crime Agree that gambling in this country is associated with criminal activity 25 2010: 37% 2011: 37% 2012: 40% 2013: 40% 2014: 41% 2015: 40% 2016: 39% 2017: 41% 2018: 38% 2019: 43% Prevalence of gambling related crime Prevalence of gambling-related crime in individuals that gamble A review found that approximately 50% of the crime committed by individuals with gambling disorder was gambling-related; this is in line with studies (presented in the same review) that reflect between 4%-9% of all crime is gambling-related crime committed by individuals with gambling disorder. 156 A study in Hong Kong reported the prevalence of suicidal ideation and familicidal-suicidal ideation among individuals presenting to gambling disorder treatments services of 20.0% and 0.6%, respectively 157 In 2010, 1 in 500 or 0.2% of adults in Great Britain reported committing crimes to finance their own gambling in the past year such as forgery, fraud, theft, and embezzlement 19 (1 in 1000 or 0.1% of adults in 2007) 21 Prevalence of gambling-related crime in affected others 3 18% reported not fully attending to needs of children 7% reported engaging in petty theft or dishonesty as a consequence of their family member's gambling 5% reported leaving children unsupervised 4% reported taking money or items from friends or family without asking first 3% reported feeling compelled or forced to commit crime or steal to fund family member’s gambling or pay debts Prevalence of gambling-harm among prison populations Multi-centre studies of gambling harm in Great Britain's prisons have reported significantly elevated rates of prevalence compared to the general population In a 2017 study, 34.3% of those surveyed in English and Scottish prisons suffered gambling harm due to their gambling in the past year 158 11.2% suffered low-risk gambling harm 11.0% suffered moderate-risk gambling harm 12.1% suffered gambling disorder harm A study in two English prisons (one male and one female) reported that 13.4% of males and 7.2% of females admitted to committing a crime to finance gambling or pay off debts 159 Cost of gambling related crime Estimated cost of crime According to the IPPR, between £40m (0.9% of the overall spend on prisons) and £190m (4.3%) are spent on gambling disorder related incarcerations in Great Britain 160 Czech Republic (population: 10.7m) 81 Total: £61.1m - £69.6m Police (4.7 – 6.5% of all major cases, and 0.6 – 0.8% of all minor cases were related to gambling): £22.3m to £30.8m Courts: £1.8m Prisons (15.8% of prisoners were in jail because of crimes related to gambling): £37.0m Sweden (population: 10.2m) 80 Total: £10.1m Police: £7.4m Courts: £0.9m Prisons: £1.8m Geography of gambling related crime Location of betting shops and deprivation by crime decile Betting shops in Great Britain are overwhelmingly in areas of deprivation by crime 161 29% of betting shops are in the top 10% most deprived postcodes by crime 16%, 2nd decile 13%, 3rd decile 11%, 4th decile 10%, 5th decile 8%, 6th decile 6%, 7th decile 4%, 8th decile 2%, 9th decile 1% of betting shops are in the bottom 10% of most deprived postcodes by crime (least deprived postcodes) What the industry said? The Betting and Gaming Council 16 “By international standards, Great Britain has a well-regulated and well-functioning gambling market with high levels of consumer choice and low levels of crime and problem gambling.” Firstly, the BGC argues in relation to international standards to deflect responsibility, despite there being no reliable evidence to support this claim. Great Britain has low levels of gambling-related crime, demonstrating the industry’s refusal to accept evidence and scientific consensus. “On the basis of data available, licensed gambling in Great Britain is almost entirely free from criminal involvement from an operational or ownership perspective.” The following statement offers a favourable view that, crucially, focuses on criminal involvement on owners and operators. In doing so, the BGC omits consideration of crime committed to fund gambling or gambling used to facilitate crime such as money laundering. “…the percentage of respondents who bet more than they could afford has fallen. The same is true of those borrowing money, selling items or committing a crime in order to gamble.” The last statement contrasts with the last series of gold-standard gambling prevalence studies, which reflect an increase in gambling-harm and gambling-related crime. Denise Coates, Joint-CEO of Bet365 162 “[Bet365] recognises its responsibility to minimise gambling-related harm and to keep crime out of gambling. The group is committed to developing an evidence-based approach to responsible gambling. To this end, the group continues to work with research partners on a number of projects to improve its methods of identifying harmful play and deliver more effective harm-minimisation interventions.” Coates, CEO of Bet365, acknowledges gambling-related harm and the risks of crime associated with gambling. While donating millions to the Denise Coates Foundation, which now has a burgeoning balance sheet of over £300m funds and yet no donations had been made to either gambling or addiction charities. 163 Ulrik Bengtsson, CEO of William Hill 164 "[The black market] is a problem we must keep pace with and confront. Not doing so, risks an increase in crime and problem gambling." Bengtsson conflates crime with the black-market industry despite evidence reflecting significant issues with gambling-related crime in Great Britain despite the unregulated market making up approximately 1.2% of total stakes. References 3. Banks J, Andersson C, Best D, Edwards M, Waters J. Families Living with Problem Gambling: Impacts, Coping Strategies and Help-Seeking. 2018. Available from: https://www.begambleaware.org/sites/default/files/2020-12/families-living-with-problem-gambling.pdf [Accessed: 13th March 2021] 16. Gambling Commission. Gambling Commission and industry collaboration makes progress on safer gambling. Gambling Commission. 01 April 2020. Available from: https://www.gamblingcommission.gov.uk/news-action-and-statistics/news/2020/Gambling-Commission-and-industry-collaboration-makes-progress-on-safer-gambling.aspx [Accessed: 30th March 2021] 21. Wardle H, Sproston K, Orford J, Erens B, Griffiths M, Constantine R, et al. British Gambling Prevalence Survey 2007. NatCen. 2007 25. Gunstone B, Gosschalk K, Joyner O, Diaconu A, Sheikh M. The impact of the COVID-19 lockdown on gambling behaviour, harms and demand for treatment and support. Gambling Research Exchange Ontario. 2020. 42. European Union Agency for Fundamental Rights. Age of majority. Available from: https://fra.europa.eu/en/publication/2017/mapping-minimum-age-requirements/age-majority [Accessed: 22nd March 2021] 80. Hofmarcher T, Romild U, Spångberg J, Persson U, Håkansson A. The societal costs of problem gambling in Sweden. BMC Public Health. 2020;20(1): 1921. Available from: doi:10.1186/s12889-020-10008-9 81. Winkler P, Bejdová M, Csémy L, Weissová A. Social Costs of Gambling in the Czech Republic 2012. Journal of Gambling Studies. 2017;33(4): 1293–1310. Available from: doi:10.1007/s10899-016-9660-4 156. Williams RJ, Royston J, Hagen BF. Gambling and Problem Gambling Within Forensic Population: A Review of the Literature. Criminal Justice and Behaviour. 2005;32(6). Available from:doi: 10.1177/0093854805279947 157. Wong PWC, Blaszczynski A, Tse S, Kwok N, Tang J. Suicidal Ideation and Familicidal-Suicidal Ideation Among Individuals Presenting to Problem Gambling Services: A Retrospective Data Analysis. Crisis. 2014;35:219-232. Available from: doi:10.1027/0227-5910/a000256 158. May-Chahal C, Humphreys L, Clifton A, Francis B, Reith G. Gambling Harm and Crime Careers. Journal of Gambling Studies. 2017;33(1): 65–84. Available from: doi:10.1007/s10899-016-9612-z 159. May-Chahal C, Wilson A, Humphreys L, Anderson J. Promoting an Evidence-Informed Approach to Addressing Problem Gambling in UK Prison Populations. The Howard Journal of Criminal Justice. 2012;51(4): 372–386. Available from: doi:10.1111/j.1468-2311.2012.00723.x 160. Thorley C, Stirling A, Huyuh E. Cards on the table: The cost to government associated with people who are problem gamblers in Britain. IPPR. 2016. 161. Gambling Harm UK. Gambling-harm and crime. Available from: https://www.gamblingharm.com/post/gambling-harm-and-crime [Accessed: 31st March 2021] 162. Neate R. Bet365 chief Denise Coates paid herself £217m last year. The Guardian. 12 November 2017. Available from: https://www.theguardian.com/business/2017/nov/12/bet365-chief-denise-coates-paid-217m-last-year [Accessed: 29th March 2021] 163. Denise Coates Foundation. REPORT AND FINANCIAL STATEMENTS. Denise Coates Foundation; 2019.Available from: https://register-of-charities.charitycommission.gov.uk/charity-search?p_p_id=uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet&p_p_lifecycle=2&p_p_state=maximized&p_p_mode=view&p_p_resource_id=%2Faccounts-resource&p_p_cacheability=cacheLevelPage&_uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet_objectiveId=A9993065&_uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet_priv_r_p_mvcRenderCommandName=%2Faccounts-and-annual-returns&_uk_gov_ccew_onereg_charitydetails_web_portlet_CharityDetailsPortlet_priv_r_p_organisationNumber=5031042 [Accessed: 30th March 2021] 164. @UlrikBengtsson. ‘p2. ....this is a problem we must keep pace with and confront. Not doing so, risks an increase in crime and problem gambling. https://t.co/4RXR5iRki8’. [cited 4 February 2021] Available from: https://twitter.com/UlrikBengtsson/status/1357277446450642944 [Accessed: 30th March 2021]

Gambling Harm UK is pleased to release an early report of findings from an ongoing retrospective case-series study of loan-takers (N=29) and guarantors (N=9). To access the early report, please click below: If you'd like to take part in future analyses around gambling and guarantor loans, please click here.

Pupils at Fairfield Church were the beneficiaries of the 'Preventing Gambling Harm in Diverse Communities' initiative on Wednesday 20th April 2022. A small but engaging workshop where another 11 students learnt about gambling harm. Jack Baker, the organiser of the delivery, was delighted to get Gambling Harm UK in to teach the attendees about gambling harm, and we were excited to do so. It is essential to bring this message across to places of worship, and we took a step in doing so today. Thank you, Fairfield Church, for having us.

Our long-awaited delivery to Bishop Ramsey Church of England School was successfully completed on Friday 4th March 2022. Dani Williams who organised the programme and delivery of the 'Preventing Gambling Harm in Diverse Communities' initiative, was one of our earliest bookings. When we were new to this area, I was thrilled to find that Dani was willing to learn more about gambling harm, and she showed a keen interest in enlightening students at the school she teaches. This allowed us to arrange this school booking six months in advance. Despite some technical difficulties on the day, each of the 150 students took away vital solutions to preventing gambling harm and gained in-depth knowledge on the subject. I was pleased to be at the forefront of this, and I hope to have a more significant impact on the rest of the school. Thank you, Bishop Ramsey, for believing in Gambling Harm UK and our work.

One of our priorities at Gambling Harm UK is to see gambling harm appropriately considered and prioritised within the health context. Consequently, as well as Gambling Harm UK's Medical Education efforts, Gambling Harm UK have been one of the earliest and most committed campaigners that wish to see NICE guidelines for gambling. In April 2020, a UK Parliament committee launched a call for evidence for gambling-harm with an inquiry: "Gambling can have significant adverse effects on people which can include addiction, mental health problems, financial loss, and in some cases crime or suicide. Excluding the National Lottery, gambling operators earned £11.3bn in 2018-19. All gambling in Britain is regulated by the Gambling Commission with the aim to “ensure gambling is fair and safe”. It is funded by licence fees from industry, which amounted to £19 million in the same period. Overall responsibility for the policy and regulatory framework lies the Department for Digital, Culture, Media & Sport (DCMS), which has an objective to ensure gambling is socially responsible. The industry is increasingly complex, with new risks emerging from online and mobile gambling and games that share features with gambling but are not regulated as such. The NAO’s report ‘Gambling regulation: problem gambling and protecting vulnerable people’ examines how well gambling regulation protects people from gambling-related harms and addresses new risks from social and technological developments. The report finds that there are an estimated 395,000 problem gamblers in Great Britain, with 1.8 million more gamblers at risk who may also be experiencing harm. The report finds that the Gambling Commission is improving its regulation but has more to do including taking a more strategic approach to influencing gambling operators to raise standards. The NAO concludes that even with improvements, the Commission’s ability to protect gamblers faces constraints in the regulatory framework, including inflexible funding and gaps in redress arrangements, and that the Commission is unlikely to be fully effective in addressing risks and harms to consumers within the current arrangements. This will be the first time the Committee has examined gambling regulation in recent years. The Committee will question officials from the Department for Digital, Culture, Media and Sport and the Gambling Commission, on how well the current regulatory framework protects gamblers. The Committee will also ask officials about how current restrictions imposed in response to the COVID-19 pandemic could affect those susceptible to the negative impacts of gambling. The Committee is inviting views from any interested parties on the issues raised by the NAO report – please submit your evidence by Wednesday 22 April." In May 2020, Gambling Harm UK's Kishan Patel responded to this call for evidence with a short synthesis of salient points which included the lack of guidelines on gambling-harm: "There are currently no NICE guidelines on gambling. As of 24th July 2018, gambling has been referred to NICE, but it has not yet been scheduled into the work programme." The timeline for NICE guidelines on gambling has now been updated which also signifies a significant watershed moment from inaction to action. 20 October 2021 - Scoping workshop 12 July 2021 - Stakeholder list updated 01 June 2021 - 15 June 2021 - Topic expert committee member recruitment 01 June 2021 - 15 June 2021 - Committee chair recruitment 16 November 2021 - 14 December 2021 - Committee member recruitment 16 November 2021 - 14 December 2021 - Draft scope consultation 07 February 2024 - Expected publication We would like to encourage individuals with lived experience to join us, to engage and support efforts towards a robust, appropriate, and impactful set of NICE guidelines. For more information, see here.

As news broke yesterday of our new education programme in collaboration with YGAM, Red Card Gambling Support Project CIC and Clearview Research (click here for news item), the Gambling Harm UK team was delivering a remote workshop centering around gambling and gaming harm to young people from Slough-based charity Aik Saath. Who are Aik Saath? The words "Aik Saath" mean "Together As One" in Hindi, Punjabi and Urdu. They also embody the ethos of the charity. Aik Saath believes in working together for positive social change. Their mission is to work with people from all communities, faiths and backgrounds to promote and encourage conflict resolution and community cohesion through training, campaigns and projects. Purpose The two-hour delivery, inclusive of in-built focus groups, was separate to our collaborative rollout which is due to begin in the coming months. The primary purpose of this session was to both raise awareness and address the issue of gambling harm and to greater understand the service provision gaps from a young ethnic minority persons perspective to help us shape future content, talks and overarching projects. We would like to thank all of the young people for their input into this session. They appeared to be engaged and impassioned on the subject and their consultation and feedback will play a key role for GHUK moving forward.