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A pioneering new education programme has been launched in Greater London and the Home Counties to raise awareness and address the issue of gambling harm disproportionately affecting young people from ethnic minority populations. The ‘Preventing Gambling Harms in Diverse Communities’ initiative has been developed through a unique collaboration between YGAM, Gambling Harm UK (GHUK), Red Card Gambling Support Project CIC and Clearview Research. The prevention programme will deliver free specialist workshops to young people from ethnic minority populations aged 14–24, as well as free training to community and faith leaders. The programme content centres on an understanding of socio-cultural and religious contexts on shame and stigma relating to gambling harms. YouGov Research published in 2020 shows that 1 in 2 adults from ethnic minority backgrounds have gambled in the UK in the last 12 months, and around 1 in 4 of these past-year gamblers suffer significant gambling-related harm. Moreover, a 2019 study by Clearview Research on the young BAME perspective reported that 90% agreed that gambling is seen differently within their ethnic cultures than within white British cultures, and 95% of participants could not identify how they could access help for gambling harm. The three partner organisations have all been established by individuals who have personal lived experience of the harms and impact of gambling addiction. The partners will channel their lived experience and insight into workshops that equip young people with the knowledge to recognise and prevent gambling harm and the confidence to support themselves and others through recovery. GHUK and Red Card Gambling Support Project CIC will work collaboratively to maximise synergies and combine resources to create young person facing educational content, using insight from the YGAM and Clearview Research content co-creation sessions. The content will include culturally-specific gambling-harm awareness short films that cover different areas in the black and Asian communities as well as self-help information and age-appropriate signposting material. Over the two-year pilot, 16,600 young people will be reached directly. Kishan Patel, 5th Year Medical Student at Imperial College and CEO at GHUK said: “In general, young people today are increasingly growing up with finger-tip access and exposure to gambling products and advertisements online. Despite this, the vast majority are not aware of the sudden or insidious but potentially devastating effects of gambling harm. It’s just not talked about enough, especially in schools or GP surgeries, where it is desperately needed. The situation we have now is one where young people are vulnerable to harms from their gambling or a family member’s gambling, but sadly feel unable to access help and support.” Tony Kelly is a former professional footballer and now CEO of Red Card Gambling Support Project CIC. Welcoming the launch of the programme, he said: “We are pleased to be working with YGAM and GHUK on this project, as I believe we share the same goals and vision. This initiative is very much needed as gambling addiction within these hard-to-reach communities is something that is still a taboo subject so it is important we break down that barrier of stigma. I hope to use my professional football career and my story to engage our young target audience on this topic. Coming from a Caribbean background myself, I hope many young people from the community will hear my voice as one they can listen and relate to.” Lee Willows, CEO of YGAM said “We’re proud to be part of this purposeful collaboration with lived experience and diversity at its heart. The project builds on the recommendations from the Clearview Research; ‘Gambling: The young BAME perspective’, commissioned by GambleAware in 2019. YGAM will take the lead on the training of community and faith leaders who once trained will deliver the programme to young people. Over the two-year pilot, YGAM will aim to train 323 practitioners, who will in turn reach 18,050 young people in their care. With the talent, specialist insight and commitment from all partner organisations, I am confident that collectively we’ll deliver some helpful perspectives on how to engage with minority communities, contributing to the National Strategy to Reduce Gambling Harms.” The programme will seek formal assured status from City & Guilds. Clearview Research have been appointed to lead the creation of a Theory of Change model for the programme and will act as independent evaluation partners. Clearview Research also worked with YGAM in 2020 to undertake a comprehensive BAME Audit, working with the charity to co-create content specifically aimed at minority communities. The initiative has received funding from the Gambling Commission regulatory settlements and will contribute to the National Strategy to Reduce Gambling Harms, specifically within the Prevention and Education priority area. In addition, a prominent Advisory Group will be established to examine the stigma of gambling harms in these communities. The programme will be recruiting members to this group in the coming weeks. If you are interested in finding out more about the programme and the free workshops available then please contact PGHDC@ygam.org.

Gambling Harm UK are proud to work with The Young Consultant to help understand how best to drive our organisation forward in reaching our aim of eliminating gambling-harm. Why did we choose the The Young Consultant to work with us? They are composed of students from the UK's leading universities from all academic fields and disciplines They have completed over 300 projects for clients in a range of markets across the globe They partner with professional consultancy firms who in turn help TYC to deliver excellent strategic advisory to their clients

Osmosis empowers over one million learners around the world with a better understanding of medicine and health topics. Although gambling-harm is increasingly recognised as a public health issue by experts, wider awareness and understanding have been limited for many reasons. One of the most significant issues facing gambling-harm awareness is the lack of education, training, and healthcare professionals' guidelines. Despite gambling-harm having such a profound impact on the quality of life of individuals (both gamblers and non-gamblers who are affected by someone else's gambling) and the burden of gambling-harm, on a population-level, being as significant as the harm that is attributable to alcohol or even tobacco, we've heard many times that Doctors don't have a clue. Gambling Harm UK has been working hard to change this, and we're pleased to say that our first piece of work with Osmosis has reached fruition. We hope that this builds a foundation for more work in this incredibly neglected area of health. To see the article, click here: Osmosis - Gambling Addiction: What Is It, Causes, Signs, Prevention, Support, and More. Additionally, Gambling Harm UK has also worked with Geeky Medics to further understanding of gambling-harm. Geeky Medics is a platform that receives over 2 million views each month from a global community of medical students, doctors, paramedics, nurses, pharmacists, physician associates and educators. Gambling now features as part of the social history for many different medical education articles on the Geeky Medics platform. These include: Alcohol history Cardiovascular history Chest pain history Depression history Gastrointestinal history Respiratory history Gambling also now features on the OSCE checklists for Medical Students: OSCEs or Objective Structured Clinical Exams are the ‘practical’ exam of medical school. It aims to prepare students for the clinical and communication aspects of becoming a doctor. Alcohol history Cardiovascular history Chest Pain history Depression history Gastrointestinal history Respiratory history At the time of writing, NICE has not yet scheduled work on guidelines on Gambling. We hope this changes soon! We'd like to give our thanks to everyone at the Osmosis and Geeky Medics teams who have worked with us in bringing about this step change. And also a special thanks to Shiv Gaglani (CEO of Osmosis) and Dr Lewis Potter (CEO of Geeky Medics) for encouraging the work on gambling-harm education.

It's not often I get invited onto podcasts to discuss my story in great length, and so I jumped at the chance when ALL IN host and good friend Brian Hatch dropped me a message. Brian and Jeff are doing a superb job of raising awareness of gambling-related harm in America, and are right to be deeply concerned at what could transpire over in America now that the online gambling market has well and truly opened-up to consumers. In this programme we talked about the demons from my childhood, how I got into gambling, the formation of the All Bets Are Off podcast and Gambling Harm UK, and much more... Massive thanks to Brian and Jeff for having me on. Click here to listen to the episode.

New research commissioned by GambleAware and delivered by YouGov has found that ethnic minority communities are disproportionately impacted by gambling harms and have a higher demand for treatment. Link to GambleAware Research published in December 2020 Gambling Harm UK summary Prevalence of gambling-harm In GHUK’s research on Gambling in BAME published in October 2020, we found that disproportionate harms in minority ethnic groups were reported in research from 2007, 2010, and 2012. The results we have from this 2020 study are in line with these older results and reflect an odds ratio for the most severe harm of around 3. Prevalence of gambling-harm due to own gambling among BAME adults: 1 in 5 (20%) Prevalence of gambling-harm due to another person's gambling among BAME adults: 1 in 10 (9%) Co-existing health conditions 50% of individuals suffering PG harm from White Ethnic groups have a co-existing long-term health condition 65% of individuals suffering PG harm from BAME Ethnic groups have a co-existing long-term health condition Prevalence of affected others in children 40% of individuals suffering PG harm from White Ethnic group have a child under 18 in the household 50% of individuals suffering PG harm from BAME Ethnic groups have a child under 18 in the household Sources of treatment, advice, and support Individuals suffering gambling-harm reported accessing support from their GP; however, this contrasts with expectations as there are no guidelines or medical curriculums that cover gambling-harm BAME individuals were more likely to access specialist services. However, these results are in stark contrast with the official statistics published, which reflect that BAME individuals are disproportionately less likely to access services (National Treatment Statistics)

Gambling Harm UK: We're pleased to share ‘Do It For Her’ a first-of-its-kind short drama reflecting on gambling harms in diverse communities experienced by a student and loved ones The short film involved a lived experience inspired and an evidence-based approach specifically throughGambling Harm UK’s research report that was also the first of its type to raise awareness on the disproportionate harms in ethnic minority communities. 'Do It For Her' was produced by Fully Focussed/Million Youth Media, directed by Shehroze Khan, written by Mohammedally Shushtari, and featured Fady Elsayed as the lead actor! The film was co-commissioned as part of the novel ‘Preventing Gambling Harms in Diverse Communities’ alongside YGAM and Red Card Gambling Support Project. The whole team at Gambling Harm UK are extremely proud to have helped bring about a hard-hitting and impactful short film bringing to a life a story that is prevalent but rarely seen or heard about. Kishan Patel (Chair of the Board of Trustees at Gambling Harm UK) first reached out to Fully Focussed on the 13th of February 2021, and following a competitive tender process and some 299 days later, 'Do It For Her' premiered in full for the world to see for free on YouTube on the 9th of December 2021. How did the short film incorporate an evidence-based and lived-experience led approach? A diverse range of topic experts and individuals with lived experience helped guide the film-making process and as a result the film intelligently and creatively reflects a wide range of important discussion points. For example: Factors towards gambling: Industry inducements: Free bets and game design: electronic gaming machines and online casino products have structural characteristics that affect human decision-making and behaviours, and therefore addiction potential, such as free bet offers, high event frequencies, random ratio reinforcement schedules, near misses, losses appearing as wins, multiline betting, and exaggerated audible and visual reinforcements Advertising: the industry spends an estimated £1.6bn on advertising in Great Britain with 80% of that or £1.2bn spent on online advertising, advertising is particularly effective at getting younger individuals to gamble when they otherwise were not going to, 61% of 18-24 year olds spent money on gambling after seeing a gambling ad or marketing when they were otherwise not planning to Association and exposure through sports: Boxing has been estimated to have the highest frequency of gambling sponsorship references in sports per broadcast minute at 4.70 gambling sponsorship references per minute Risk factors: Students/young people (the prevalence of gambling harm is expected to be highest among 16-24 year olds and according to the last gambling prevalence study, BGPS 2010, 17.5% of (or almost 1 in 5) 16-24 year olds suffered significant gambling harm from their gambling in the past year Ethnic minority backgrounds: individuals from ethnic minority backgrounds are less likely to gamble, more likely to live in areas disproportionately concentrated with betting venues, and between 3-5x more likely to suffer gambling disorder than individuals from white ethnic backgrounds Low mental well-being status: individuals with a low Warwick-Edinburgh Mental Wellbeing score have been estimated to be 7.65x more likely to suffer gambling disorder harm Types of gambling harm shown in 'Do It For Her': The film demonstrates the development and escalation of harms across all the known domains of gambling harm (taxonomy of harms) for the individual who gambles and the loved ones around that individual including: financial relationship crime health/psychological education and work cultural The potential for recovery by breaking stigmas and through conversation: 'Do It For Her' also aims to empower young people to talk about their experiences of gambling harm to someone they can trust, whether that be a professional or a trusted loved one. Additionally, the film demonstrates how someone may effectively help someone else if their behaviour worries them. We are extremely grateful to have worked with such a talented and dedicated team - thank you to all those involved! With an extra special thanks to all cast and crew involved and individuals with lived experience who helped guide the creative process.

What are “skins” and “loot boxes?” Understanding loot box gambling requires an explanation of skins, a concept found in many multiplayer video games. Many games contain “skins”, aesthetically different versions of in-game items. These are most common in online multiplayer games, as rare items can be seen by other people playing the game. They can be costumes for a character to wear, weaponry which has a particular visual style, or effects that follow a character such as patterns or colours. These “skins” vary in terms of appeal both between and within games, with some items being particularly appealing to young people, such as brightly coloured guns, unicorn costumes or golden frying pans. Skins may be given to the player for completing a certain part of the game, or “unlocked” from loot boxes. Loot boxes, also known as loot crates, are items that result in a random chance of gaining a certain item from a range of available skins, with rare skins and items having low odds of being “contained” in the box. “Keys” for these loot boxes may be unlocked through play of the game, success, or commonly through purchase of keys with real currency. The items within them may be common, and have little real world value, or rare, with a high value (what we may consider a “win”). The purchase of loot box keys is not directly through real world currency in most cases, as real money must first be turned into in-game currency, and then further into keys for the boxes, before it can be used to open the box. Differences in currency values further obfuscate the true cost of the purchase. Who is playing loot box games? Many of those who play games with loot boxes are young people. The targeting of young people and children for in-app purchases and microtransactions is well-documented, and occurs in many games, particularly mobile games. Loot box or loot box-like mechanics occur in games which are particularly designed to appeal to children and young people, and which utilise popular characters and bright colours to do so. A notable example which is currently culturally relevant is Pokemon: Unite. In games which do not have particular appeal to children, there is often still a large teen or underage player base – for example, many of the people involved in the Counterstrike: Global Offensive community are underage – in one study, of 255 respondents, 46.2% of players said that they played CS:GO and were underage. [1] This, along with the ability to easily bypass age restrictions or a lack of age restrictions at all, means that many young people engage in loot box opening. Dangers of loot box gambling Many of the rarer items which may be acquired from loot boxes have high trade value, being sold on third-party trading sites for thousands of pounds. This kind of money may be especially appealing to a young person, as trading items online can be a rare source of income for a young person who may not be able to find work. Sometimes, in games such as FIFA, the unlockable items confer advantages to playing the game and are not simply cosmetic, offering another incentive to own more of them. This means that loot box opening is psychologically and operationally very similar to gambling, and has been considered as such in some of the literature surrounding it.[2] This gambling exposure has many worrying hallmarks and can have a devastating effect on players, particularly vulnerable youth players. Links have been found with gambling exposure as a youth, and gambling problems as an adult. The constant arousal associated with gambling activities leads participants in loot box gambling to require the same levels of stimulation more frequently, leading to a disordered and excessive pattern of use. Most video games analysed in one study showed most of the characteristics of gambling, and almost half of them fulfilled all criteria In one study of gamers aged 18 and over, [3] there was a strong link between loot box spending and severity of their problem gambling. This link was stronger than other common risk factors for problem gambling, such as drug abuse. In another study of 618 gamers, two thirds of those who gambled had spent money on loot boxes in the past year, and that loot box purchasing was directly related to increased problem gaming and problem gambling. [4] There is an active social network of peers which provides social incentive to gamble on loot boxes, an integration of social media channels, and the use of unrestricted purchase limits and microtransactions. Microtransactions are a particularly concerning area of gambling risk – as each purchase of a loot box is low-cost, it encourages more and more bets, and there is often no way to track how much a person has spent on loot boxes without going through several different purchase records. There are no options for self-exclusion for a player who is experiencing addiction to loot box gambling, and a player may spend far more than they are aware of. [5] Additionally, gamers who spend money on in-game purchases, spend more total money on games than those who do not. This is contrary to the idea that since many games which utilise loot boxes and microtransactions are free-to-play, there will be a balancing between the two factors. [6] Legislation surrounding loot box gambling Loot boxes lie in a grey area legally, as spending of real-world currency on the boxes is not technically “necessary” as keys can be obtained via play, and therefore the gambling is “simulated.” As the prizes are virtual, they are sometimes considered to have no value, despite the trading of items which occurs on third party sites. Another reason that loot boxes are not regulated is the assertion that no player makes a loss – they are guaranteed to contain one item, and it simply differs in rarity. However, according to studies which analysed Steam Marketplace purchases and sales of loot box items, around 93% of sales of items acquired from loot boxes recouped less than purchase price, and a rare few items accumulate immense value due to the demand. The most expensive item to ever sell in Team Fortress 2’s online trading platform, a Burning Flame Team Captain (hat), sold for approximately $14k. Players can cash out their items through third-party sites which facilitate conversion of these items, or profits from their sales, into real-world currency. The market has gone and remains unregulated in many places. The growing gap between regulation of the digital space and the activities which occur in it is visible when we see politicians and legislators state that digital items do not hold real value. This not only poses risks to young people who are engaging in gambling activities for the first time, but presents people affected by gambling harm to a novel and unregulated system which closely approximates gambling. However, there is an increased understanding of loot box gaming as something that can cause harm . in 2018, Belgium ruled that randomised loot boxes constituted illegal gambling, which means that several aspects of games are not available in the country. Some games, such as Fortnite, have removed their loot box aspect in all countries due to class-action lawsuits and campaigning to remove them; with Fortnite repaying in-store credit to anyone who had purchased their loot box-like mechanic and settling further cases with anyone who stated they had experienced harm. We believe there is a need for further review of loot box practices and the way they are implemented in video games, especially those which may have particular appeal to children, such as Pokemon Unite. Responsible gambling practices should be implemented, such as displaying the chances for each item to be acquired individually, implementing self-exclusion strategies, and allowing gamers to check how much they have spent on their gambling. [1]Beneš M. UNDERAGE GAMBLING IN COMPUTER GAMES. Proceedings New trends and research challenges in pedagogy and andragogy NTRCPA18. 2018:81. [2]Zendle D, Bowden-Jones H. Loot boxes and the convergence of video games and gambling. The Lancet Psychiatry. 2019 Sep 1;6(9):724-5. [3]Zendle, D. and Cairns, P., 2018. Video game loot boxes are linked to problem gambling: Results of a large-scale survey. PloS one, 13(11), p.e0206767. [4]Li, W., Mills, D. and Nower, L., 2019. The relationship of loot box purchases to problem video gaming and problem gambling. Addictive behaviors, 97, pp.27-34. [5]King, D.L. and Delfabbro, P.H., 2016. Early exposure to digital simulated gambling: A review and conceptual model. Computers in Human Behavior, 55, pp.198-206. [6]Drummond, A., Sauer, J.D., Hall, L.C., Zendle, D. and Loudon, M.R., 2020. Why loot boxes could be regulated as gambling. Nature Human Behaviour, 4(10), pp.986-988.

Online gambling platforms are often misunderstood by those who do not engage in them, particularly ones which rely on an understanding of existing gaming mechanics. The convergence of gaming and gambling in this manner provides mediums which can be used to gamble using in-game items. eSports Many games, particularly those considered “eSports” (electronic sports) and the communities surrounding them provide an incentive to gamble. The online communities surrounding esports have grown in popularity following the rise of online streaming platforms, such as Twitch, professionally commentated web broadcasts, and a generally more connected and international online community. [1] Matches, and thus bets placed on them, maybe informally between friends or on the outcomes of top-tier competitors from anywhere in the world. Indeed, many recognised wagering operators now host cash betting on the outcome of esports matches. Something which is particularly prevalent with young people and those who are familiar with online games, however, is “skin betting”. Skin betting Skins, cosmetic game items which confer different aesthetics to in-game items, or provide different unlockable outfits for a character, are often acquired from in-game loot boxes, which provide different odds of acquiring different items. (see previous articles on simulated gambling and loot boxes). This means that on a consumer-led market, such as online “skin trading” platforms, (websites which allow the sale and purchase of other players’ unlocked items) some item prices are driven up due to a combination of their rarity, appeal, and desirability. Some gaming platforms, such as Steam, allow for the legitimate trade of items within the same platform games are published. Some items on marketplaces go for prices in the thousands, and some are very low-value. Skin betting occurs when people stake skins, typically relatively high-value skins, on the outcome of an event. These bets may be placed informally between friends, but more high-stakes skin betting tends to occur via third-party platforms that “hold” the staked items, and “payout” the skins to the winner of the bet. Skins act in this way as a form of virtual currency, and indeed, the purchase and sale of skins have their own economy. Skins can also be considered as “tokens” for real-life currency. [2] Though Steam does not allow direct conversion of skins back into currency and has limitations on purchasing in some instances, third-party programs may be used to “cash-out” of bets or purchases, allowing items to be traded for incredibly high amounts of real-world currency. These are transferred between players via a “bot”, or puppet Steam account, an automatic process coded by those who run the gambling website. eSports betting and gambling harm eSports bettors are a group which is vulnerable to harm. eSports bettors were found by one study to be far more likely to meet “problem gambler” criteria (64.8% of bettors) than those who engage in sports betting (17.3% of bettors). They were also significantly more likely than sports bettors to experience at least one instance of gambling harm. This may be due to the uniquely unregulated world of skin betting and eSports betting. There is an observable rise in those self-reporting their involvement in skin betting. Engagement of youth with in-game purchases and online gambling is high. The frequency of online gambling generally has increased in 2019, with 7% of 11-16 year-olds in the UK reporting having gambled online. There is also a gender bias in these statistics, with adolescent boys being significantly more likely to gamble in this way. According to Ipsos MORI data, 44% of young people aged 11-16 who had heard of in-game items have used the money to pay for them, and 6% had said that they engaged in betting with them. [3] In more recent studies, rates of adolescents who had engaged in skin betting were 11% in the UK, and in one Australian study, one in seven adolescents engaged in skin betting in the past year. Adolescents are 2.5x more likely to engage in betting with skins than with cash, and there is a robust association between skin gambling, overall gambling problems, and factors such as low wellbeing. The subcultures that youth engage in often actively encourage skin gambling with content creators and streamers advertising gambling on their media platforms, and other users in-game advertising the sites on their profile descriptions. Little research into the effects of this constant exposure has been conducted. Regulation of eSports and online skin betting Despite the harm caused, this method of gambling is currently exempt from many regulations, and even if regulation were to be put into place, it would be difficult to enact due to the nature of the industry. The market is largely consumer-led, and the third-party sites which facilitate the transactions can allow people to evade legislation in a particular country, which allows one to access the internet as if from a different country. [4] The introduction of age verification checks on these gambling websites, if made mandatory, may help with the issue of underage gambling, but there are ways for children and young people to circumvent current methods of age checks by using the identification of an older relative or friend. Meaningful legislation and regulation may be the most effective methods of harm reduction to implicate; in several areas. First is legislation regarding gambling advertising in online spheres and on a platform level; gambling is promoted to children via social media and by game influencers. A blanket ban on advertising for skin betting in user profiles would be an achievable goal, and would likely have support from a proportion of the user base, as many are tired of seeing these adverts. Second is the requirement for online skin gambling platforms to be licensed as online gambling operators and for video game gambling to be considered a form of gambling under UK law. [5] Overall, it is clear that gambling in video games and gaming communities is a growing industry, and steps must be taken to further understand, prevent, and ameliorate the harms experienced. [1]Edge, N., 2013. Evolution of the gaming experience: live video streaming and the emergence of a new web community. Elon Journal of Undergraduate Research in Communications, 4(2). [2]Thorhauge, A.M. and Nielsen, R.K., 2021. Epic, Steam, and the role of skin-betting in game (platform) economies. Journal of Consumer Culture, 21(1), pp.52-67. [3] Ipsos MORI via Gambling Commission. Gambling Commission publishes the 2019 Young People and Gambling report. (Oct 23, 2019) https://www.gamblingcommission.gov.uk/news/article/gambling-commission-publishes-the-2019-young-people-and-gambling-report [4]McLeod, C., 2017. More Than Skin Deep: Why It's Time to Go'All-In'on Skin Gambling Regulation. Available at SSRN 3159661. [5]Greer, N., Rockloff, M.J., Russell, A.M. and Lole, L., 2021. Are esports bettors a new generation of harmed gamblers? A comparison with sports bettors on gambling involvement, problems, and harm. Journal of Behavioral Addictions, 10(3), pp.435-446.

The PSHE curriculum was updated in September 2020 to include education surrounding gambling harm for the first time. [1, 2] Despite this change, compared to drugs, alcohol and tobacco education in Relationships and Sex Education (RSE) and Health Education, education on gambling harm is neglected. [3] There is no mention of gambling education in the PSHE primary education curriculum (Table 1) despite the increasing convergence of gambling and gaming. In secondary education, pupils are only required to learn about the risks of online gambling and debt accumulation (Table 2). There is no mention of addiction to gambling and the physical and psychological risks and consequences on the individual who gambles and those around the individual who gambles. Unlike what is seen in the curriculum for drug, alcohol, and tobacco education, there is also no mention of links to other mental health conditions. The difference in the amount of coverage on the PSHE curriculum shows gambling harm is not taken as seriously as alcohol and substance addiction despite the WHO reporting that "the gambling-related burden of harm appears to be of similar magnitude to harm attributed to major depressive disorder and alcohol misuse and dependence. It is substantially higher than harm attributed to drug dependence disorder." [4] It is also important to note that gambling harm is only included in the curriculum within 'internet safety and harms' in spite of a significant amount of gambling harm arising from land-based venues. Moreover, the inclusion of gambling disorder in the DSM-V in the ‘Addictions and Related Disorders’ category alongside substance addictions suggests the need for a holistic and overarching view of addiction in meaningful education and awareness. [4] Table 1 – Primary By the end of primary school: Note. Taken from gov.uk website (3) Table 2 – Secondary Schools should continue to develop knowledge on topics specified for primary as required and in addition, cover the following content by the end of secondary: Note. Taken from gov.uk website (3) References 1) PSHE Association and GambleAware launch gambling education handbook. Available from: https://pshe-association.org.uk/news/pshe-association-and-gambleaware-launch-gambling 2) T Menmuir. UK Schools to introduce Gambling curriculum for September 2020. SBC News. 16 March 2020. Available from: https://sbcnews.co.uk/sportsbook/2020/03/16/uk-schools-to-introduce-gambling-curriculum-for-september-2020/ 3) Government curriculum. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1019542/Relationships_Education__Relationships_and_Sex_Education__RSE__and_Health_Education.pdf 4) Professor M Abbott. The epidemiology and impact of gambling disorder and other gambling-related harm. World Health Organisation. 26 June 2017 https://www.who.int/docs/default-source/substance-use/the-epidemiology-and-impact-of-gambling-disorder-and-other-gambling-relate-harm.pdf?sfvrsn=5901c849_2

Introduction The Betting and Gaming Council (BGC) was formed in 2019 as a merger of three different ‘industry associations’; the Remote Gambling Association (RGA), the Association of British Bookmakers (ABB) and the National Casino Forum (NCF).[i] These associations represented various sectors of the UK’s gambling industry whose interests had not always been aligned.[ii] With the formation of the BGC, however, the industry has created a unified body to advocate on its behalf.[iii] This advocacy, however, is not the aspect of the organisation that it stresses to the press or the public. Instead, the BGC, since its creation, has styled itself as a ‘standards body’ first and foremost, as CEO Michael Dugher is quoted in bold on their website ‘Our number one priority remains to raise standards and drive big changes’.[1] And whilst the BGC has championed several initiatives to promote safer gambling, their effectiveness has been questioned; the Guardian’s Rob Davies refers to much of the work as ‘cosmetic rather than profound’.[1] The BGC’s role as representatives and advocates of the industry is not immediately apparent and is always couched in the language of promoting industry standards; below Dughers’ quote (and in a much smaller font), the BGC’s stated mission is: “To champion the betting and gaming industry and set world class standards to ensure an enjoyable, fair and safe betting and gaming experience for all our customers.”[1] And its purpose: “To provide a forum to facilitate collaboration, sharing of best practice, drive and champion standards, and create a single voice for the industry.”[1] Despite this downplaying of its role as an industry-founded and industry-funded organisation, the BGC, like its forebears, is first and foremost a lobbying group for the gambling industry. Below we examine how and why the BGC was formed, the influence and connections it exerts, to what extent its claims of industry self-regulation can be taken seriously and finally, we will look at some of its strategies and tactics. FOBTs, the industry’s lost battle and the formation of the BGC Before their maximum bet was reduced by law from £100 to £2 in 2019, ‘fixed-odds betting terminals’ (FOBTs) were out of control. They represented over £1 billion lost a year by people who gambled, a disproportionate proportion of their players were ‘problem gamblers’ (13.6%, rising to over a quarter when including those at ‘moderate risk’), and they were primarily responsible for overcrowding high streets with betting shops.[2] By 2017, these problems, combined with the heart-rending stories of victims, coalesced into a media storm, with FOBTs dubbed the ‘crack cocaine of gambling.’[3]Unsurprisingly, the same year, the government launched a ‘consultation on a range of options on cutting maximum stakes.’[4] With each machine bringing in more than £50,000 a year and generating a total of £1.2 billion in income, the industry launched a defensive action. [3] This action would be spearheaded by the Association of British Bookmakers (ABB) and its CEO Malcolm George. Much of their effort was unsophisticated, with Malcolm George often railing against a ‘media panic’ induced by ‘those with their own commercial interests at heart’.[5] George was not entirely incorrect; the industry was divided on FOBTs, with some organisations backing reform and the ABB’s counterpart, the Remote Gambling Association, ‘content to stay out of the matter’. [3] Such heavy-handed attacks, however, did the ABB no favours. As with much lobbying, however, the primary battle was not in the press but in parliament. Here the ABB acted with much more sophistication and in a manner still emulated by its successor, the BGC: Firstly, the ABB commissioned KPMG (an accounting firm) to write a report on the impact of cutting FOBT’s maximum stake to £2; the report found that this would cost the industry a staggering £639 million and cause 15-21,000 job losses. It was, however, deeply misleading as the ABB had dictated the parameters of KPMG’s report in such a way to ensure a beneficial outcome. As KPMG notes, the report was ‘performed to meet specific terms of reference’, with certain estimates’ agreed with the industry’ and ‘should not be regarded as suitable to be used or relied on by any other person or for any other purpose’.[6] Despite this, the report was circulated among MPs and Civil Servants; it was used in ‘Treasury modelling’ and even cited by the Chancellor of the Exchequer, Philip Hammond.[3] Secondly, it would seem that the industry’s allies in parliament attempted to delay or axe the incoming £2 stake limit proposed by then Sports Minister Tracy Crouch. As Crouch would report, Philip Davies lobbied the Culture Secretary Jeremy Wright against the policy; after that, the Treasury and chancellor Philip Hammond (who cited the erroneous report) took over. Crouch then resigned in protest, triggering outroar and a rebellion which forced the Treasury to backtrack. Crouch has stated that without her resignation, she does not believe the policy would have gone ahead, given the Treasury’s and Hammonds’s ‘scepticism’, no doubt influenced by the misleading KGMP report and lobbying by pro-industry MPs.[3] With these late dramatics, the ABB had been defeated, and the industry’s reputation damaged. It was clear to gambling firms that if they wanted to weather public outrage and growing calls for reform, they would need a modern and sophisticated organisation to “champion” their interests. Thus, in 2018 the Betting and Gaming Council was formed. The BGC: buying influence At its formation, the BGC was already a formidable beast. It appointed a veteran lobbyist Brigid Simmonds as chairman. More importantly, it hired Michael Dugher, a former Shadow Secretary and Labour MP as chief executive and Kevin Schofield, a veteran journalist and former editor of PoliticsHome, to run the organisation’s communication strategy.[3] All the contacts and experience in this core team have undoubtedly been useful to the BGC in various ways, some of which we trace below. With the appointment of Kevin Schofield, the BGC had hired an experienced journalist and a man fully capable of running the organisation’s communications strategy. Perhaps it was this canny understanding of communications that caused PoliticsHome (a news source read by MPs and political advisors) to go from publishing articles broadly sympathetic to gambling reform to publishing no less than eleven articles written by the BGC or its staff in the eighteen months since they hired Schofield.[3] Or perhaps Schofield retains friends and influence at PoliticsHome, for which he was an editor for five years. Similarly, since his appointment, niche BGC reports have received favourable coverage by Schofield’s former colleagues in both the Sun and the Sun on Sunday.[3] Somewhat more challenging to map is the influence of former shadow minister Michael Dugher. Dugher is a man with numerous contacts from his time at the forefront of political activity; he has undoubtedly helped the BGC meet with and influence officials, ministers and MPs. The nature of such lobbying means that we can only speculate on the extent of his work. What we can note, however, is the apparent influence and reach of the BGC, whose staff met with DCMS officials seven times between October and December of 2020 (the period immediately before the Government’s Gambling Act Review was announced).[3] Perhaps the most well-publicised (alleged) exertion of Dugher’s influence was the hiring of former Labour Deputy Leader Tom Watson by Flutter Entertainment. Of course, Flutter is not the BGC, and there is no evidence that Dugher directly or indirectly influenced that decision. What is known is that Dugher and Watson are close friends, and despite Watson’s former vocally anti-gambling stance, he took a job for the industry, lending it both his expertise and reputation. Further, Watson has taken to using a favourite phrase of Dughers (and not many others) to describe activists in favour of gambling reform, that is, to call them ‘prohibitionists’ (despite the rarity of calls for an outright ban).[3] It is not just former MP’s the BGC has ties with (nor is the Dugher-Watson connection the height of the industry’s incestuous dealings). In November 2020, the BGC began paying current Conservative MP Laurence Robertson £2,000 monthly for 10 hours work advising ‘on sports and safer gambling’ (an hourly rate of £200).[3] Similarly, Philip Davies (the MP who lobbied to delay FOTB reform) got paid £50,000 for 124 hours of work advising Entain chief executive Kenny Alexander.[3] Alongside this, Davies has several former staff employed in the industry. Two of Entains senior officials previously worked in his office (head of safer gambling and external affairs Sophie Dean and chief of corporate affairs Grainne Hurst); the BGC also employs his former aide Camilla Toogood as its ‘government relations manager’.[3] Whilst there is nothing technically wrong with hiring a host of Davies acolytes, it shows how the BGC and, indeed, the industry maintains a deep connection with those politicians it deems friendly to their cause. The BGC: self-regulation? Unlike the old Association of British Bookmakers or the Remote Gambling Association, the BGC’s purpose as a pro-industry lobbying group is not immediately apparent to the casual observer. In a rather successful PR stunt, the industry dropped the standard ‘association’ moniker in its creation of the BGC and has focused on messaging concerning the groups role as a ‘standards body’. The BGC stresses this role at every opportunity and indeed, the organisation has championed several voluntary initiatives aimed at the protection of consumers. This has led many commentators to attribute a genuine concern for those affected by gambling harm. However, such exercises by the industry are best viewed as thinly veiled publicity stunts, primarily tokenistic and driven by the desire for self-preservation, which attempts to mask the actions of an industry desperately trying to fend off outside regulation. Take, for example, two instances of BGC “championed” reform. Firstly, the much-publicised whistle-to-whistle ban on gambling advertisements during live sporting broadcasts. The ban, agreed on in 2018, was labelled a ‘huge success’ in the BGC’s annual review and has been held up as something of a crowning achievement for the organisation and as proof that effective self-regulation is possible.[7] Indeed, the BGC claimed that the initiative had reduced the number of gambling ads seen by 4-17-year-olds by a staggering 97%.[8] The reality is substantially different; over the first year of the ban, gambling ads across all TV channels fell by about 11.3%.[9] Whilst this might seem substantial, two factors undermine the BGCs narrative. Firstly, despite a ban on tv advertisements during broadcasts, the broadcasts themselves contained numerous gambling logos and advertisements; 9 of 20 premier league clubs and 17 of 24 championship clubs had shirt sponsorships, to say nothing of the numerous advertisements on pitch-side boards.[10] Secondly, the ban only served to accelerate the move to online advertising, which the industry was already in the process of making. Indeed, the 97% reduction in gambling ads seen by children boasted by the BGC is achieved through not only excluding all media except broadcast tv but also by examining only the number of tv ads seen over the span of televised football matches, not the overall number of televisions ads seen at other times.[3] In short, the ban is unlikely to have reduced gambling harm due to the omnipresent nature of gambling ads both online and through sponsorships during broadcast; similarly, it was almost certainly harmless to the industry, which already had a large amount of exposure through those sponsorships and online marketing. The main purpose for the ban seems to have been the positive news coverage it generated for the industry. Secondly, and of more minor importance, is the BGCs supposed support for gambling reforms. Notably, when the Gambling Commission introduced a ban on gambling on credit - a ban on gambling on debt (and thus likely creating more debt) - Dugher claimed the BGC had always ‘fully and publicly’ supported the ban.[3] Despite this, the Commission's own report indicated that ‘none of the remote gambling operators who responded supported the ban’.[3] The BGCs backers had opposed the reform, and the BGC had only thrown its weight in once it was already decided; rather than championing reform, the organisation appears to have attempted to gain credit for a reform its backers opposed. What these examples illustrate and what must be kept in mind is that the BGC is, first and foremost, a pro-industry body; its responsibility is not to those affected by gambling harms but to the various gambling companies that make up its membership. As such, the regulatory initiatives it has championed have been aggrandised and have only been incidentally helpful in reducing gambling harm (if they have at all). The BGC commits to such initiatives with the dual aims of improving the industry’s public image and of fending off government intervention – the alternative is that profit-driven private enterprises are funding an organisation whose goal is to reduce their profits through self-regulation. The BGC: bogus fear of a black market One of the BGC’s primary methods of pushing back against the prospect of greater regulation is to raise concerns over growth in the gambling ‘black market’ (unlicensed gambling operations). The argument being that much like the American prohibition, a draconian crackdown on the industry could lead to an explosion of an unregulated (and more dangerous) form of gambling. Whilst the prospect of growth in the black market should perhaps not be dismissed outright, the industry’s predictions are certainly exaggerated and cynically leveraged; as Paddy Power co-founder Stewart Kenny has noted, industry heads always ‘used the threat of the black market’ and ‘always knew it was a bit of a bogus argument’.[3] Despite Mr Kenny’s admission and others like it, the BGC has focused much of its efforts on framing its opposition to regulation as civic-minded warnings. Whilst the ABB of old might have railed against the prospect of regulation (and the APPG on Betting and Gaming certainly has), the BGC’s well-oiled PR machine has taken a conciliatory tone, offering notional support to ‘the Gambling Review’ whilst raising the spectre of the black market if regulation is taken too far, warning that it may lead to ‘regulated industry being smaller and the illegal black market growing substantially’.[11] Dugher and the BGC then call for the government not to limit regulation or roll back its gambling review but rather to ‘take an evidence-based approach’.[11] Whilst this may seem an uncontroversial and eminently reasonable approach, one must recall the KGMP report on FOBTs that was declared unfit for outside use by its authors yet still found its way into Treasury modelling, onto the desks of civil servants, MPs and even the Chancellor’s. The industry can and has created ‘evidence’ which suits their financial interests; the BGC’s network of influence means that often this evidence makes its way to decision-makers even when it is woefully inaccurate and unusable. It is unsurprising then that in 2019 the industry commissioned PwC to write a report on the size of the UK black market.[3] The report estimated that 200,000 Britons wagered 1.4 billion on black market operators every year; this eye-catching figure was dutifully spread around the press (with Schofield’s old colleagues in the Murdoch Press doing much of the heavy lifting).[3] The report was deeply flawed and had failed to distinguish between real website visits and ones generated by bots; it drew widespread criticism and a surprisingly strong statement from the usually reticent Gambling Commission, with executive Niel McArthur calling the report ‘exaggerated’ and ‘not consistent with the intelligence picture’.[3] Furthermore, it should be noted whilst the report was completed in August of 2019, the BGC, a self-described ‘standards body’, did not choose to publish it until 2020, just as the Gambling Review was initiated. Not deterred by this criticism, the BGC quickly published a follow-up alleging that wagers on black market sites had doubled during the pandemic and now equalled around 2% of those placed on legitimate sites.[3] As Davies notes with some scepticism, during the same period, wagers on legitimate sites increased by a comparatively modest 13%; the PwC report would suggest that during lockdown, people were drawn not towards the licenced operators whose adverts they saw daily but towards much riskier black market sites.[3] To refer back again to Paddy power co-founder Stewart Kenny this seems incredibly unlikely as most people are ‘not going to lend [their] credit card details to black market operators’.[3] [i] An industry association is founded and funded by businesses operating in the sector. Its purpose is to promote the interests of the businesses it represents. [ii] Most notably on the issue of FOBTs [iii] Since the absorption of the Senet Group in 2020, the BGC now represents approximately 90% of the UK's licensed operators. [1] Betting & Gaming Council. Our Purpose [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/about-us/our-purpose [2] Channel 4. Gambling act was a ‘mistake’ confesses senior Labour politician [Internet]. [cited 2023 Jan 6]. Available from: https://www.channel4.com/press/news/gambling-act-was-mistake-confesses-senior-labour-politician [3] Davies R. Jackpot: How Gambling Conquered Britain. London: Guardian Faber; 2022. [4] GOV.UK. Government to take action on Fixed Odds Betting Terminals [Internet]. [cited 2023 Jan 6]. Available from: https://www.gov.uk/government/news/government-to-take-action-on-fixed-odds-betting-terminals [5] Financial Times. Why criticism of FOBTs needs to be played down [Internet]. [cited 2023 Jan 6]. Available from: https://www.ft.com/content/3304187a-7ff1-11e6-8e50-8ec15fb462f4 [6] Davies R. Government’s FOBT decision influenced by ‘discredited’ report. The Guardian [Internet]. 2018 Nov 12 [cited 2023 Jan 6]; Available from: https://www.theguardian.com/uk-news/2018/nov/12/government-fobt-decision-discredited-report [7] Betting & Gaming Council. ‘Whistle to whistle’ ban a huge success [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/annual-review/responsible-advertising-2 [8] Betting & Gaming Council. ‘Whistle to whistle’ ban success [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/news/whistle-to-whistle-ban-dramatically-reduces-number-of-betting-adverts-seen-by-children [9] Patel K. Gambling and voluntary bans [Internet]. 2021 [cited 2023 Jan 6]. Available from: https://www.gamblingharm.com/post/gambling-and-voluntary-bans [10] Association P. Number of clubs sponsored by betting firms is ‘disturbing’, say campaigners. The Guardian [Internet]. 2018 Jul 30 [cited 2023 Jan 6]; Available from: https://www.theguardian.com/football/2018/jul/30/campaigners-concerned-championship-efl-clubs-sponsored-betting [11] Betting & Gaming Council. New research reveals shocking size of Black Market gambling across… [Internet]. [cited 2023 Jan 6]. Available from: https://bettingandgamingcouncil.com/news/new-research-reveals

The industry maintains that advertising has no effect on consumption but instead helps operators differentiate product offerings and for customers to identify which brands are regulated and therefore can be trusted. Evidence from the Gambling Commission reflects the contrary. Younger adults, in particular, were more likely to be affected by advertising to spend money on gambling when they were not otherwise planning to. Worryingly, this phenomenon has been reported even among 11-16 year olds. The industry is keen to prevent meaningful reform on gambling advertising nationally and internationally because of its importance in driving gambling in the short-term and the long-term through a normalisation effect. The importance of advertising to the industry is highlighted by their lobbying against change and their expenditure. Summary Over the past decade, gambling advertising has grown exponentially. In the present day, gambling advertising is ubiquitous, with a distinct presence across various mediums, including online advertising, social media, affiliates, television, radio, newspapers, sponsorships, and physical ads in stores. The widespread nature of gambling advertising has meant inevitable exposure to vulnerable groups, such as young people and individuals with special educational needs and disabilities. Moreover, the volume of ads has led to a normalisation effect, such that young people are growing up in an era where gambling is seen as a normal part of everyday life. This phenomenon is particularly noticeable in sport. Advertising is vital to the gambling industry for one encompassing reason: increasing consumption and increasing yields. Increased gambling can be broken down into activity among new customers and returning customers. The importance of advertising to the industry is demonstrated by the sheer size of investments made and its fierce opposition to meaningful regulation in Great Britain and abroad. Like the tobacco industry, the gambling industry maintains the notion that advertising does not affect consumption but merely helps promote safer gambling by directing customers to regulated brands and helps customers differentiate offerings between brands. However, the industry would not spend as much on advertisements if it did not increase customers' gambling losses and increase industry profits. Online advertising is particularly significant for the gambling industry as it benefits from targeting and the accessibility of online gambling, where ads facilitate a more direct link to the product. According to the Advertising Standards Authority, there are several themes to the concerns around gambling advertising and these are: Links to problem gambling Children's exposure Online media Societal expectations Aggressive advertising Misleading advertising Some of the industry has recognised that there are significant issues with advertising, including the sheer volume of ads, their presence in sports, and ads' ability to reach young people in sports and online. However, despite these well-grounded concerns, little meaningful action has been taken. Instead, industry efforts have been self-heralded as successes demonstrating the industry's ability to self-regulate. Recent industry measures, which have been criticised for include the 'whistle-to-whistle’ advertising ban and the use of safer gambling messages during the pandemic, are discussed in more detail in the voluntary bans chapter. What is known? Advertising spend by the UK Gambling Industry According to the Advertising Association, the UK’s gambling industry advertising spend grew from £0.17bn to £0.24bn between 2010 and 2013 (after adjusting for inflation) at an increase of 40% or a year on year increase of 13.3% 56 2010 = £0.15bn (0.95% of total spend) TV: £0.07bn Press: £0.04bn Internet: £0.01bn 2011 = £0.17bn (1.07% of total spend) TV: £0.08bn Press: £0.04bn Internet: £0.03bn 2012 = £0.21bn (1.27% of total spend) TV: £0.12bn Press: £0.05bn Internet: £0.03bn 2013 = £0.24bn (1.36% of total spend) TV: £0.14bn Press: £0.05bn Internet: £0.02bn According to Regulus Partners, the UK’s gambling industry advertising spend grew from £1.07bn to £1.56bn between 2014 and 2017 (after adjusting for inflation) at an increase of 46% or a year on year increase of 15.3% 57 Prior to 2014, remote operators were not required to have a GB gambling license (discussed in more detail in chapter 9: gambling operators as multinational corporations) 2014 = £1.00bn (5.4% of total spend) 58 Internet: £0.72bn (9.9% of all online advertising spend) Online Marketing: £0.40bn Affiliates: £0.28bn Social Media: £0.04bn TV: £0.16bn (3.2% of all TV advertising spend) Sponsorship: £0.03bn Other Offline: £0.09bn 2017 = £1.56bn (7.0% of total spend) 59 Internet: £1.20bn (10.4% of all online advertising spend) Online Marketing: £0.75bn Affiliates: £0.30bn (54.3% of all affiliate advertising spend) 60 Social Media: £0.15bn (5.9% of all social media spend) TV: £0.23bn (4.6% of all TV advertising spend) Sponsorship: £0.06bn Other Offline: £0.07bn Gambling advertising exposure In young people 11-24 year olds in the past month 61 85% reported seeing gambling advertising on TV (including national lottery adverts) 70% noticed gambling adverts in betting shops on the high street, window displays as well as promotions on shop floors and near tills 66% reported seeing gambling promotions on their social media channels 11-16 year olds exposed at all in the past year (exposed at least once a week) 46 70% were exposed to gambling advertising or sponsorship at all in the past year 59% (33%) were exposed to ads on TV 52% (24%) were exposed to ads linked to sports events 50% (24%) were exposed to social media websites 45% (20%) were exposed to other websites (excluding social media) 43% (21%) were exposed to sponsorships on TV or radio 40% (18%) were exposed to sponsorships in sports venues 37% (13%) were exposed to ads on posters/billboards 31% (11%) were exposed to ads in newspapers 12% follow gambling companies on social media platforms like Facebook, YouTube and Instagram 11% had ever received direct marketing from gambling companies about gambling Mails: 4% Messages via Youtube: 3% Texts: 3% Messages via Instagram: 3% Messages on Facebook: 2% Messages via Snapchat: 2% Messages via Twitter: 2% Messages on another social media website: 1% In adults (16+ year olds) exposed at all in the past year (exposed at least once a week) 87% of adults (16+) has seen or heard gambling advertisements or sponsorships in the past year 23 79% (50%) were exposed to ads on TV 72% (45%) were exposed to gambling sponsorships on TV or radio 65% (33%) were exposed to gambling sponsorships on sports merchandise 64% (33%) were exposed to gambling sponsorships in sports venue 63% (31%) were exposed to gambling advertisements online (non-social media sites) 62% (23%) were exposed to gambling advertisements on posters/billboards 61% 27%) were exposed to gambling associations with sporting competitions 58% (31%) were exposed to gambling advertisements on social media 51% (23%) were exposed to gambling advertisements in newspapers 45% (18%) were exposed to gambling advertisements on the radio Online affiliates ODDSbible, an emerging affiliate brand that is part of the LADbible Group, boasts over 1m followers in under 1 year of operation, with 79% of these followers being between 18 and 34 years old and 96% being male 62 Significance of targeting and data analytics 63 A case-study of Sky Bet and companies used by Sky Bet and an individual with Gambling Disorder (Flutter Entertainment) What data? TransUnion: a large credit scoring agency that owns CallCredit, Signal, and Iovation CallCredit 34 page breakdown of financial history including information on: bank accounts, loan defaults, debts, mortgages and monthly payments Iovation A spreadsheet containing 19, 000 fields of data including device identification numbers network information about Signal A document containing personal characteristics including: history of playing slots favourite sports to bet on Interpretation of data by Sky Bet “win back” customer worth about $1, 500 if he started gambling again customer would be receptive to gambling promotions that featured Las Vegas Actions by Sky Bet sent emails to customer promoting a chance to win more than $40,000 by playing slot Effects of gambling advertising Spent money on gambling after seeing a gambling ad or marketing when they were otherwise not planning to 11-16 year olds: 5% (1 in 20) 46 16+ year olds who gamble online: 44% (1 in 2) 23 By age 18-24: 61% 25-34: 56% 35-44: 49% 45-54: 45% 55-64: 31% 65+: 26% By type Free bets and bonuses: 29% TV: 20% Online: 16% Social Media: 16% Newspaper: 11% Billboards: 9% What the industry said? William Hill PLC Annual Report and Accounts 2015 64 "[Gambling has] increased over time, with the National Lottery and TV advertising making gambling more socially acceptable as a leisure activity while mobile devices are making the product more accessible" William Hill recognises the role of advertising over the long-term in normalising gambling and the growing role of mobile devices in increasing accessibility of gambling products. Stephen van Rooyen, CEO of Sky in the UK and Ireland 65 "Yet again, the gambling industry are ignoring the fact they spend five times more on online marketing than they do on TV," van Rooyen said. "By cutting TV ads, they'll simply spend more online, bombarding people's smartphones, tablets and social media feeds with even more gambling ads." Van Rooyen recognises that the industry is keen to avoid meaningful change with online advertising as this is the most effective form of advertising. GVC Holdings PLC Annual Report 2019 66 “The Group also unilaterally ended all UK football shirt sponsorship and perimeter board advertising and has encouraged others in the industry to follow suit.” GVC Holdings recognises an issue with football sponsorships and takes steps to address it, leaving space for other operators to take their place. Betting and Gaming Council 16 "The fact that only companies licensed by the Gambling Commission may advertise in the UK provides an important means for customers to identify legal from illegal operators. It is also provides a means for companies to inform gambling consumers about the products that they enjoy." Like the Tobacco Industry in the past, the Betting and Gaming Council publicly denies or omits the role of advertising in increasing gambling-harm. In this statement, the BGC paraphrases Philip Morris, who in 1987 said that advertising ‘may influence the choice of one brand over another’. 67 Philip Bowcock CEO of William Hill, Annual Report 2018 68 "This issue is one I have been speaking about for some time. I was on the record in 2016 saying I had concerns about the level of gambling advertising, for example, at 4 pm on a Sunday afternoon. The tone of the adverts, the number of them and the potential impact on young people have all been raised as concerns." Unusually for the industry, Bowcock recognises issues with advertising including the tone of the content, the volume, and the potential for impact on young people. Philip Bowcock CEO of William Hill, Annual Report 2018 68 "Most of our advertising is during live sport and it's then that we find young people are most likely to see gambling advertisements. The average under-18 audience of a Premier League match on Sky Sports is 96,000. Major events like the World Cup attract hundreds of thousands more young viewers. That is far too many young people seeing a product that isn’t appropriate for them." Hypocritically, Bowcock highlights an issue with advertising during live sports, while William Hill is the Scottish Cup's official sponsors. Moreover, William Hill also sponsored England and the FA Cup in 2014, through the FIFA World Cup in 2014, and secured the boxer Anthony Joshua as a brand ambassador in 2018. Bet365 69 "The business said it spent more in marketing as it tried to entice betters with offers linked to the 2018 World Cup, which was part of this period." Bet365 look to benefit from the exposure of events like the World Cup. Mr Green Annual Report 2017 70 "Digital communication gives us useful data for us to analyse which messages and channels are effective. In this way, we are constantly expanding our knowledge about what is relevant to the customer." Mr Green, a subsidiary of William Hill, recognise that digital targeted advertising can benefit from data analytics. William Hill PLC Annual Report and Accounts 2015 64 "Historically, affiliates drove a lot of traffic to our sites. Now, as we have increasingly focused on our core, regulated markets, TV advertising, search engine optimisation and PPC [pay-per-click] account are much more important. These channels accounted for [circa] 73% of our marketing spend and all drive a lower cost per acquisition." William Hill recognises the increasingly important role of digital advertising in lowering costs and increasing ad effectiveness to shareholders. Ladbrokes PLC Annual Report 2015 71 "We have helped to run a high impact TV and advertising campaign to educate people about the risks of gambling and how to stay in control. We are fully aligned with the GB Gambling Commission's objectives to ensure that gambling is crime free, fair and open and children and vulnerable people are protected and indeed commit to these objectives across the whole of our business wherever we operate" Ladbrokes reports their role in educating people about gambling-risks and their commitment to being fully aligned with the Gambling Commission’s objectives. Despite this commitment, Ladbrokes failed multiple customers between November 2014 and October 2017 and was fined £5.9m in 2019. Michael Dugher, CEO of Betting Gaming Council 72 “We welcome the Committee’s understanding of the role of advertising and the lack of real evidence of any link between gambling advertising and problem gambling.” Like the tobacco industry in the past, Dugher’s statement reflects the idea that advertising does not affect consumption. Moreover, Dugher fails to recognise evidence from the Gambling Commission that reflects approximately 1 in 20 11-16 years old go on to gamble when they were not otherwise planning to because of gambling advertising. Stewart Kenny - Founder of Paddy Power "That is dangerous, because it is promoted by well-known people, it's a constant barrage of advertising they see it before, during and after the match… It's become normal for children to think gambling and soccer are the same thing." Stewart Kenny, the Paddy Power founder who resigned in 2016 over what he saw as the failure to tackle problem gambling, says advertising is "normalising" gambling for children, and that it has become "nearly part of the game" when watching football. References 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] 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] 46. The Gambling Commission. Young People and Gambling Survey 2019. The Gambling Commission. 2019. 56. Community of Advertising Practice. CAP and BCAP Gambling Review: An assessment of the regulatory implications of new and emerging evidence for the UK Advertising Codes. Community of Advertising Practice. 57. REGULUS PARTNERS. Industry Advertising spend 2014-2017. Available from: https://www.begambleaware.org/media/1853/2018-11-24-rp-ga-gb-marketing-spend-infographic-final.pdf [Accessed: 28th February 2021] 58. IAB UK. UK advertising spend passes £20bn as growth hits five-year high. Available from: https://www.iabuk.com/press-release/uk-advertising-spend-passes-ps20bn-growth-hits-five-year-high [Accessed: 28th February 2021] 59. IAB UK. Full Year 2017 Digital Adspend Results. IAB UK. 2017. 60. IAB UK. IAB / PwC Affiliate Marketing Study 2017. Available from: https://www.iabuk.com/adspend/iab-pwc-affiliate-marketing-study-2017 [Accessed: 28th February 2021] 61. Ipsos Moir. Terms & Conditions. 2021. Available from: http://www.ipsos-mori.com/terms [Accessed: 31st March 2021] 62. LADbible Group. ODDSbible. Available from: https://ladbiblegroup.com/OurBrands/oddsbible/ [Accessed: 21st March 2021] 63. Satariano A. What Sky Bet, The Gambling App, Knows About You. The New York Times. 24 March 2021. Available from: https://www.nytimes.com/2021/03/24/technology/gambling-apps-tracking-sky-bet.html [Accessed: 28th March 2021] 64. William Hill. THE SCALE TO DELIVER OUTSTANDING CUSTOMER EXPERIENCES. 2015. Available from: http://files.williamhillplc.com/media/3612/williamhill_ar15.pdf [Accessed: 31st March 2021] 65. BBC Sport. Gambling chiefs confirm ‘whistle-to-whistle’ television sport advertising ban. BBC Sport. 13 December 2018. Available from: https://www.bbc.co.uk/sport/46550118 [Accessed: 29th March 2021] 66. GCV Holdings. FOR THE GOOD OF ENTERTAINMENT. 2019. Available from: https://www.annualreports.com/HostedData/AnnualReports/PDF/LSE_GVC_2019.pdf [Accessed 31st March 2021] 67. Bates C, Rowell A. Tobacco Explained: The truth about the tobacco industry …in its own words. World Health Organization. Available from: https://www.who.int/tobacco/media/en/TobaccoExplained.pdf [Accessed: 31st March 2021] 68. William Hill. Towards a digitally led, internationally diverse business. 2018. Available from: https://www.williamhillplc.com/media/12906/williamhill_ar18-01032019.pdf [Accessed 31st March 2021] 69. Andrews J. Bet365 chief exec takes home £58million pay rise as Britain’s top earning boss. Mirror Online. 18 December 2019. Available from: https://www.mirror.co.uk/money/denise-coates-handed-astonishing-320m-21119736 [Accessed: 29th March 2021] 70. MrGreen & Co AB. 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In this article, we illustrate two issues with the funding for efforts to prevent, research, and treat gambling harm. 1) Chronic underfunding of RET 2) Issues with the distribution of RET funding Gambling operator director remunerations vs RET funding From 2016 to 2020, the total director remunerations across ten top gambling companies were £2.19 billion. Bet365 makes up a considerable amount of this, with £1.91 billion in key management personnel remunerations. In comparison, totalled, all other companies’ remunerations were £278 million. In contrast, total funding for gambling harm research, education, and treatment received £77.19 million between 2016 and 2020. Total funding for gambling harm RET equates to 3.5% of the spending on director remunerations for ten top gambling companies. Focusing solely on 2020 alone, total remunerations across the ten companies were £654 million. Again, Bet365 makes up a significant amount with £607 million in key management personnel remunerations with all other companies’ remunerations together standing at £46.4 million. In contrast, funding given to gambling harm research, education, and treatment totalled £27.3 million in 2020 (4.2% compared to the remunerations). Figure 1. A comparison of remunerations of gambling operators and RET funding between 2016 and 2020. Note: Our figures reflect on ten of the top leading gambling companies: Bet365, Camelot Group, Entain (Coral, Ladbrokes), Flutter Entertainment (Paddy Power, Betfair), Gamesys, Kindred Group (Unibet, 32Red), Rank Group, Playtech, William Hill and 888. Remunerations include the base salary and all other forms of financial compensation (e.g., bonuses) paid to directors or key management personnel. Statistics were calculated from Companies House (1), the Gambling Commission (4, 5) and the Charity Commission (6). Funding for charities can be received in two different ways: Gambling operators must donate an annual financial contribution (RET contribution) to a charity that focuses on research, education and treatment of gambling harm, as a condition of holding a Gambling Commission Licence. No amount is specified in the Licence Conditions and Codes of Practice (2). Funding from regulatory settlements. A payment to a charity that addresses gambling-related harm can be made as part of a settlement with the Gambling Commission when regulatory action is taken against a gambling operator. The gambling operator cannot receive positive publicity, and the money needs to be separate from RET contributions and should be given for socially responsible purposes (3). Distribution of funding In 2020, charities received £27.26 million, with £17.57 million in RET contributions from industry and £9.68 million in regulatory settlements. In 2021, charities received £60.46 million, with £37.05 million in RET contributions from industry and £23.41 million in regulatory settlements. Funding for charities has increased, comparing 2020 to 2021. However, the distribution is uneven across organisations. In 2020, GambleAware’s income was £16.88 million, with £15.59 million in donations from industry and £1.29 million in regulatory settlements. In comparison, the total from other RET organisations was £10.38 million, with £1.99 million in RET donations from industry and £8.39 million in regulatory settlements. Funding has started to be given over a broader range of charities during 2021. However, GambleAware still receives the majority of the income with £33.63 million; of which £24.83 million is from voluntary donations from the gambling industry and £8.8 million in regulatory settlements. In comparison, in 2021, £26.83 million was given towards all other RET efforts with £12.22 million in voluntary donations from the gambling industry and £14.61 million in regulatory settlements. Figure 2. Voluntary RET Donations between 2016 to 2021. Note: RET contributions shown of organisations which have been published by the Gambling Commission with additional analysis conducted for GambleAware, GamCare, YGAM, and Gambling with Lives using the Charity Commission service. Organisations shown include Action Against Gambling Harms, ARA, Betblocker, Bet Know More, EPIC Risk Management, Gambling with Lives, GambleAware, GamCare, Gordon Moody Association, Leon House Health and Wellbeing, Red Card Gambling, Sport in Mind and YGAM. Statistics were calculated from the Gambling Commission (4) and annual returns from the Charity Commission (6). May include public donations for YGAM and GamCare as it was not possible to separate. Figure 3. Regulatory settlements between 2018 to 2021. Note: Regulatory settlements, including part-funded projects. Statistics were calculated from the Gambling Commission (5) and annual returns from the Charity Commission (6). Figure 4. Overall Income (Voluntary RET donations and Regulatory Settlements) between 2016 and 2021. Conclusion The comparison between remunerations and RET funding reflects a chronic issue of insufficient funding and illustrates industry priorities towards profits over meaningful harm reduction. The voluntary system does not help organisations develop effective long-term strategic planning to reduce harms created by gambling, due to the uncertainty and lack of consistency over funding (7). “Increases in funding first promised by five of the largest gambling operators nearly one year ago have yet to materialise, and industry has now demonstrated its ability and willingness to change the direction of funding at short notice” - Wardle et al., 2020 (7). This demonstrates the unstable environment and is further shown by the gambling commission review into RET arrangements in 2018, where the industry had “consistently failed to meet GambleAware’s modest funding aspiration (0.1% of GGY), by a significant margin” (8) and that “there is a strong case for implementing a statutory levy if the industry cannot provide what is needed voluntarily” (8). Another issue caused by the voluntary RET contributions is the uneven funding distribution. Most donations go to GambleAware, rather than across a range of charities, and focus on treatment rather than prevention (7). “The task was hopeless, as the industry worked to undermine all the evidence and deny their responsibility, blocking use of their funding for education and research into how gambling causes addiction” - Robin Burgess, Former CEO of the Responsibility in Gambling Trust, 2021 (9). Researchers have reflected that unilateral decision-making in funding allocations is one way the industry exerts influence (7). To counteract this, researchers are calling for the primary aim of the new government white paper to focus on the prevention of harm (10). The gambling commission stated in 2018 that there should be “Demonstrable independence and rigour of the research process” (8); this has not been achieved due to the industry's influence in the voluntary system. Researchers and health experts have stressed their concerns to decision-makers and highlighted the need for a levy that funds prevention and treatment free from real or perceived industry influence. (7, 10, 11). New Zealand has a statutory levy (12). Independent funding for research and treatment should be under the Department of Health and Social Care and the NHS (10) or by an organisation such as UK Research and Innovation (7). This would follow the NHS, which has announced they are cutting ties with voluntary funding from the Gambling Industry via GambleAware (13, 14). Overall, with the approaching gambling act review, the government should recognise gambling harm as a significant public health issue, like smoking, and that it needs similar funding (9). Public health experts are calling for three criteria that need to be met by the government, 1) The scale of gambling harm to be recognised with due attention given to affected others. 2) The gambling industry should not be involved in how to prevent gambling harm, as it is a conflict of interest. 3) The legislation should assume a precautionary principle; lack of definitive evidence cannot be a licence for inaction(11). References 1) Companies House. Available from: https://find-and-update.company-information.service.gov.uk 2) LCCP 3.1.1 Combating problem gambling. Available from: https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-1-1-combating-problem-gambling 3) Payments in lieu of financial penalties 2.14. Available from: https://www.gamblingcommission.gov.uk/policy/statement-of-principles-for-determining-financial-penalties/statement-of-principles-for-determining-financial-penalties-applicable 4) LCCP RET contributions data – January 2020 to March 2021. Available from: https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions#lccp-ret-contributions-data-january-2020-to-march-2021 5) Information about destinations of regulatory settlements to be applied for socially responsible purposes. Available from: https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/regulatory-settlements-applied-for-socially-responsible-purposes 6) Charity Commission Register. Available from: https://register-of-charities.charitycommission.gov.uk 7) 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. BMJ 2020; 370:m2613. Available from: DOI: https://doi.org/10.1136/bmj.m2613 8) Gambling Commission. Reviewing the research, education and treatment (RET) arrangements. 2018. Available from: https://consult.gamblingcommission.gov.uk/author/copy-of-national-strategy-to-reduce-gambling-harms/user_uploads/review-of-ret-arrangements-february-2018.pdf 9) R Burgess. Gambling firms will never take responsibility for addiction. The Guardian. 13 April 2021. Available from: https://www.theguardian.com/society/2021/apr/13/gambling-firms-will-never-take-responsibility-for-addiction 10) M Gaskell. Gambling addiction treatment should be led by health experts. The Times. 2 February 2022. Available from: https://www.thetimes.co.uk/article/gambling-addiction-treatment-should-be-led-by-health-experts-nnvpqfzxq 11) van Schalkwyk, M C I, Blythe, J, McKee, M, Petticrew, M. Gambling Act Review. BMJ 2022; 376:o248. Available from: DOI: https://doi.org/10.1136/bmj.o248 12) Gambling (Problem Gambling Levy) Regulations 2019. Available from: https://www.legislation.govt.nz/regulation/public/2019/0134/10.0/whole.html 13) E Dugan. NHS cuts ties to gambling cash. The Times. 30 January 2022. Available from: https://www.thetimes.co.uk/article/nhs-cuts-ties-to-gambling-cash-3kskx6b6n 14) T Menmuir. GambleAware faces RET rethink as NHS cuts gambling funding ties. SBC News. 31 January 2022. Available from: https://www.sbcnews.co.uk/social-responsibility/2022/01/31/gambleaware-faces-ret-rethink-as-nhs-cuts-gambling-funding-ties/