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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
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.
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