GoodCorporation response to the Government consultation for changes to gaming machines and social responsibility measures

GoodCorporation has worked for a number of Europe’s leading gambling organisations assessing the effectiveness of their responsible gambling controls. This has involved corporate responsibility reviews, code of conduct audits and mystery shopper exercises.  

We recognise that the majority of gamblers do so safely and that many in the industry are working hard to implement a range of measures to protect the vulnerable. There are nonetheless growing concerns that problem gambling is increasing. The Gambling Commission estimates that there are more than two million people in the UK who are either problem gamblers or at risk of addiction. Their latest research has shown that some 430,000 people in the UK suffer from a serious habit, up by one third in recent years. We therefore welcome the Government’s proposals to introduce a range of initiatives that will help address the damaging negative impacts of problem gambling, particularly among society’s most vulnerable. 

In response to the Government’s consultation on the maximum stake on B2 machines, we agree that the stake should be reduced and would favour a reduction to a maximum of £2. Of the options put forward in the consultation, this is the only one that sees a significant reduction in the percentage of players identified as problem gamblers, down from over 40 per cent to 19 per cent. However, even at this much reduced stake, 49 per cent of players of B2 machines were still identified as ‘at risk’. These figures are significantly higher than the national picture. According to the Gambling Commission, 1.4% of gamblers are classed as problem gamblers (0.8% of the population) with 4.6% at risk. This data supports the concerns that Fixed Odds Betting Terminals (FOBTs) attract a higher proportion of problem gamblers and that player protection measures need to be enhanced. 

It is also worth noting that players of FOBTs are more likely to come from vulnerable groups than those participating in other gambling activities. According to the Cards on the Table Report published by the Institute for Public Policy Research in 2016, FOBT use is highest among 16-24-year-olds, the unemployed and low-earners. 

Evidence from problem gamblers themselves also suggests that a reduction to a maximum stake of £2 would be a welcome and responsible move to protect individuals from incurring substantial losses that they can ill afford, with five-figure sums often quoted. The government should also consider reducing the frequency with which bets can be placed at machines, otherwise reducing the maximum stake will only have a limited effect. 

In response to questions 2-10, we agree with the government’s proposals. In our response to the consultation however, we have focussed our attention on the proposals regarding social responsibility measures outlined in Section 5. A reduction in the maximum stake alone will not adequately address the issues around problem gambling and more must be done to protect problem gamblers and those at risk.  

There is a strong business argument for protecting these individuals, it is also a condition of the licence to operate. Last year, industry regulator, the Gambling Commission, fined an online operator £7.8 million for serious failings in the handling of vulnerable customers. If the number of problem gamblers continues to rise, societal concern will also increase, and more operators could find themselves facing similar penalties or losing their licence to operate.  

The measures outlined in questions 11 and 12 to improve player protection are welcome, in particular the use of algorithms to identify problematic play on gaming machines. More needs to be done both online and in betting premises to identify patterns and behaviours associated with gambling harm and facilitate the necessary interventions to divert those at risk both from unaffordable heavy losses and becoming problem gamblers.  

The Featurespace report Predicting Problem Gambling outlines a methodology that can be used to identify problem gambling behaviours. This enables players to be screened for problem gambling and concludes that it is possible to distinguish between harmful and non-harmful machine play. This technology should be utilised across the industry to improve player protection and reduce the negative and costly social consequences of gambling addiction. 

Tracked play should also be explored in more detail, particularly some form of anonymised player registration that would allow information to be shared between operators without compromising the personal data of individuals.  

In the on-line sector, the multi-operator self-exclusion scheme is a much-needed and very welcome initiative. The SENSE self-exclusion scheme operated in casinos has been effective, so the government is right to support GAMSTOP.  

In addition, the government should also consider the following: 

• Require all operators to monitor and report on the effectiveness of their controls around vulnerable customers, using a common reporting format that reviews what systems are in place and what action is being taken as a result of the findings. This could be done by making annual assurance statements mandatory for all licence holders and publishing the aggregated findings. The Gambling Commission is already piloting an assurance scheme and from the initial statements it seems that more needs to be done to encourage operators to provide more accurate and detailed information about the effectiveness of their controls. 
• Implement more training programmes for staff so they can identify signs of problem gambling and be able to intercede safely. As problem gamblers have argued, if a barman isn’t allowed to serve a customer who has had too many, why do betting operators allow known problem gamblers to keep feeding the machines? Staff need more effective training on managing these difficult situations safely. Where problems might be envisaged, operators could also consider installing panic buttons for staff and provide staffing levels to ensure there are always at least two members of staff on duty. Notices supporting staff and communicating a zero-tolerance of abusive behaviour towards staff are also recommended. 

• Draft an industry-wide code that requires gaming companies to monitor gambling patterns and intervene at an early stage if indicators of problem behaviour are identified. This could be applied to online as well as retail gambling through the use of algorithms currently being explored. 

The measures outlined in Question 13 to address concerns about gambling advertising are also welcomed to ensure that both government and industry have a thorough understanding of the effects of gambling advertising on children, young people and vulnerable groups.  

Finally, with regard to local authorities, we would welcome a more proactive approach from government to ensure that local authorities are managing the granting of licences in the local interest and are actively requiring operators to demonstrate that they meet the conditions of their licence on an on-going basis. This should include demonstrating that they “protect children and other vulnerable persons from being harmed or exploited by gambling’. Regular monitoring of the licence requirements would raise the bar and encourage operators to be more active in implementing effective controls to minimise problem gambling and the harm it causes.  

We know that many in the industry are working hard to promote socially responsible gambling. They should be rewarded for the efforts, winning bids for new licences and building reputation on their best practice.