• Kishan Patel

Gambling and the way it is conducted

Updated: Dec 1, 2021

Public opinion of gambling has deteriorated significantly over the past decade; there are well-grounded concerns regarding industry exploitation of individuals on the addictive spectrum. Estimates suggest that half of the online industry's profits are generated from harmful gambling, where players are more likely to gamble, lose more money, and gamble at unsociable hours. The Gambling Commission has increasingly fined operators for regulatory failings, yet operators continue to profit substantially from failures and harmful gambling.


Summary

Over the past decade, public opinion of gambling and the way it's conducted in Great Britain has consistently and significantly deteriorated. There are well-grounded concerns of the regulated industry's exploitative nature towards individuals on the addiction spectrum. Ultimately, there is no requirement for operators to prevent harm in those showing signs of addiction, and evidently, the industry's bottom-line benefits from these high-value customers.


There is significant analysis reflecting that individuals on the addiction spectrum:

  • wager larger amounts,

  • lose more money,

  • gamble more frequently, and

  • gamble at less social hours

relative to individuals who gamble but do not suffer gambling harm. By utilising this understanding, estimates indicate that more than half of the industry’s profits are derived from players who are on the addiction spectrum. In line with this analysis, the Gambling Commission's evidence using data from nine different operators reflects that significant percentages of deposits are universally derived from a small minority of VIP scheme customers.


Over the past few years, the Gambling Commission has increasingly fined operators who are found to have exploited customers or for other failings through regulatory settlements. Moreover, operators have been reported to coerce individuals into settlements that repay victims of thefts related to gambling on the condition of non-disclosure agreements or confidentiality provisions that may, in turn, discourage the Gambling Commission from being informed by incidents of failings.


Lastly, there are concerns that gambling-harm disproportionately affects ethnic minority communities and individuals in areas of deprivation, which may be in part due to the agglomeration of betting shops in these areas.

What is known?

Public opinion of how gambling is conducted

  • Percentage of adults agreeing that gambling is conducted fairly and can be trusted 25

  • 2010: 48%

  • 2011: 49%

  • 2012: 49%

  • 2013: 42%

  • 2014: 41%

  • 2015: 39%

  • 2016: 34%

  • 2017: 33%

  • 2018: 30%

  • 2019: 29%

Gambling industry profits from harmful gambling

  • Research of bank data reflects that the top 1% of individuals that gamble surveyed spent 58% of their income on gambling 8

  • Online gambling

  • VIP Schemes and Deposits comparison (online) 117

Operator

Customers%

Deposits%

1

0.30

26

2

0.01

1

3

5

58

4

2

83

5

3

35

6

1

21

7

3

36

8

0.004

1

9

3

48

  • Respublica estimates 58.6% of online gambling profits are from individuals who gamble and who suffer significant amounts of harm 118

  • Individuals suffering low-risk harm: 17.0%

  • Individuals suffering moderate-risk harm: 17.1%

  • Individuals suffering gambling disorder harm: 24.5%

  • Kindred’s self-reported data reflects that approximately 33.6% of the company’s revenue was accrued by individuals with probable gambling disorder in 2020 119

Geography of betting shops

  • Betting shops in Great Britain are overwhelmingly in areas of deprivation by multiple deprivation

  • 19% of betting shops are in the top 10% most deprived postcodes by multiple deprivation

  • 16%, 2nd decile

  • 16%, 3rd decile

  • 13%, 4th decile

  • 10%, 5th decile

  • 8%, 6th decile

  • 6%, 7th decile

  • 5%, 8th decile

  • 4%, 9th decile

  • 2% of betting shops are in the bottom 10% of most deprived postcodes by multiple deprivation (least deprived postcodes)

  • By ethnicity 83

  • Relative difference between ethnic distribution of populations around betting shops and national averages (2011 census)

  • All betting shops

  • White: -6.7%

  • Mixed: 22.1%

  • Asian: 40.6%

  • Black: 49.8%

  • Other: 56.5%

  • Betting shops in postal districts with 10 or more betting shops

  • White: -27.7%

  • Mixed: 88.6%

  • Asian: 160.5%

  • Black: 231.5%

  • Other: 222.6%

Gambling industry fines by UK Gambling Commission 120,121

  • 2015: £1.88M

  • 2016: £2.01M

  • 2017: £10.74M

  • 2018: £27.20M

  • 2019: £15.77M

  • 2020: £33.93M

What the industry said?


Brigid Simmonds, Chair of the Betting and Gaming Council 122

“But you are right in that if people start asking them for their tax return, as somebody as suggested, people will start walking away - I mean, I wouldn't share my tax return with anybody. We will be driving people to a black market. We will be doing what they've done in Sweden, where the numbers are up to about 40% of people, because they've been too tight. We've got to be balanced.


We believe the way forward is taking a risk-based approach founded on evidence. This means not considering affordability in isolation, but in the context of many other data points including frequency of bets and deposits, personal circumstances, time, products used and, crucially, changes in usual patterns of behaviour for each customer. When all these inputs are considered together, we can take an impactful approach to player protection.


The vast majority of gambling activity in Great Britain is carried out in a fair and transparent fashion.”


Simmonds utilises a strawman argument by failing to recognise that gambling companies already have access to financial data through credit check companies. Still, instead of using data analytics to protect customers, operators use data analytics for profit.


Ian Proctor, Chairman of Flutter UK and Ireland 98

“At Flutter we believe it is important to ask ourselves the big questions and that the Government’s review of the Act represents a chance for real change. Gambling has gone through a technical transformation over the last 15 years, and the rules have not kept pace.”


Proctor states that Flutter believes in self-reflection and that the review of the Act represents a chance for real change. Notably, Proctor points out that the need for gambling reform is due to a technical transformation instead of concerns for gambling-harm as a public health issue with evidence that emerged as early as 2007. Proctor also reflects a sentiment that there is a need for rules with this industry, which suggests that the industry cannot self-regulate.


Brigid Simmonds, Chair of the Betting and Gaming Council 123

“Just as pubs, in my former incarnation, are important to high streets so are betting shops. Betting shops and their managers really care about their customers, and they want to make sure that they have the right experience but they also stay safe


Simmonds states that betting shops are important to the high-street and compares them to pubs. The Chair of the BGC also states that betting shops and managers care about their customers and that they want to make sure that they stay safe.


Neil Goulden, Chair of the Responsible Gambling Trust and the Association of British Bookmakers 124

[Issue of problem gambling] “dwarfed by problems with drug use, alcohol abuse and obesity”


“[Bookmakers] would not have released data or have taken the actions it continues to take in prevention of harm without my personal influence and urging,”


[urging] “the industry to take consumer product protection more seriously or face more bad press and a loss of government and consumer confidence”.


Goulden mendaciously diminishes the significance of gambling-harm relative to other public health issues such as drug use, alcohol abuse, and obesity. Scientific evidence and commentary from the World Health Organisation, directly contrasts with these statements. Goulden states that his ties and influence with the industry, combined with his role within safer gambling efforts have caused the industry to be more open and prevent harm.


Goulden reflects that he could push the industry to take matters more seriously with the warning of public relation repercussions and a loss of government and consumer confidence. Through this, it is clear that the action against gambling-harm by the industry would still be motivated by profits and factors relating to profit-making, instead of a desire to be principled in not causing harm.


Ulrik Bengtsson, CEO of William Hill 125

“Claiming the black market doesn’t exist is like saying the Earth is flat”


“I do realise we have a huge obligation to make sure our customers play within their means. We should do a reasonable amount of affordability checks, but it can’t be to the extent where it is so intrusive that we force these people out. So it’s all about finding the right balance to keep the customers in the UK ecosystem; to keep them safe, to secure the tax base and to secure the industry”


Bengtsson implies that individuals with lived experience and other campaigners for reform deny the existence of the black market.


Spokesperson for Ladbrokes 126

“we recognise that (name removed) has problems with his gambling and have therefore shared the details of our multi-operator self-exclusion scheme with him”


Ladbrokes reflects that their process for preventing gambling-harm in individuals with a loss of control is to send these individuals a message referring them to self-exclusion schemes.


References

8. Muggleton N, Parpart P, Newall P, Leake D, Gathergood J, Stewart N. The association between gambling and financial, social and health outcomes in big financial data. Nature Human Behaviour. 2021;5(3): 319–326. Available from: doi:10.1038/s41562-020-01045-w [Accessed: 22nd March 2021]

25. Gunstone B, Gosschalk K, Joyner O, Diaconu A, Sheikh M. The impact of the COVID-19 lockdown on gambling behaviour, harms and demand for treatment and support. Gambling Research Exchange Ontario. 2020.

83. TalkGEN. Gambling in BAME & Risk Factors. Available from: https://www.talkgen.org/post/gambling-in-bame-and-other-risk-factors [Accessed: 31st March 2021]

98. Proctor I. Flutter: Gambling industry is listening, and responding, to addiction concerns. CityAM. 12 February 2021. Available from: https://www.cityam.com/flutter-gambling-industry-is-listening-and-responding-to-addiction-concerns/ [Accessed: 29th March 2021]

117. Gambling Commission. What is a VIP. [Presentation] Gambling Commission.

118. UK Parliament. Chapter 5: Gambling-related harm. Available from: https://publications.parliament.uk/pa/ld5801/ldselect/ldgamb/79/7908.htm [Accessed: 20th September 2020]

119. Kindred Group plc. Our journey towards zero. Available from: https://www.kindredgroup.com/sustainability/our-journey-towards-zero/ [Accessed: 27th March 2021]

120. Gambling Business Group. FOI Request: Info Reg Settlements 070220. Available from: https://gamblingbusinessgroup.co.uk/wp-content/uploads/2020/03/FOI-Request-Info-Reg-Settlements-070220.pdf [Accessed: 27th March 2021]

121. Gambling Industry Fines. Gambling Industry Fines. Available from: https://gamblingindustryfines.com/ [Accessed: 27th March 2021]

122. Racing TV. ‘Racing must stand alongside betting industry’ in Gambling Act review: Simmonds. Racing TV. 13 December 2020. Available from: https://www.racingtv.com/news/racing-must-stand-alongside-betting-industry-in-gambling-act-review-simmonds [Accessed: 29th March 2021]

123. Burley Hannah. ‘Sponsorship in sport should be allowed’ - The Big Interview with Brigid Simmonds, chair of the Betting and Gaming Council. The Scotsman. 10 February 2020. Available from: https://www.scotsman.com/business/sponsorship-sport-should-be-allowed-big-interview-brigid-simmonds-chair-betting-and-gaming-council-1555471 [Accessed: 30th March 2021]

124. Ramesh R. Gambling charity chair lobbied for bookmakers, documents show. The Guardian. 6 January 2016. Available from: https://www.theguardian.com/society/2016/jan/06/documents-reveal-gambling-charity-chair-conflict-of-interest [Accessed: 30th March 2021]

125. Racing TV. ‘Racing must stand alongside betting industry’ in Gambling Act review: Simmonds. Racing TV. 13 December 2020. Available from: https://www.racingtv.com/news/racing-must-stand-alongside-betting-industry-in-gambling-act-review-simmonds [Accessed: 29th March 2021]

126. UK Rehab. Gambling Addict Says Betting Companies Are Not Doing Enough to Help. Available from: https://www.uk-rehab.com/behavioural-addictions/problem-gambling/gambling-addict-says-betting-companies-are-not-doing-enough-to-help/ [Accessed: 30th March 2021]