This summer the Gambling Commission amended its statement of principles for licencing and regulation and its licencing, compliance and enforcement policy statement.
The updates explained the Commission’s new role in promoting economic growth. However, as the Campaign has pointed out in its consultation response, the Commission’s desire for growth comes at the detriment of the public and in particular the most vulnerable members of society.
The primarily C2DE demographic of FOBT gamblers are losing over £1 billion per year on roulette games alone. This compares to £100 million for remote roulette and is a clear indication of the addictive nature of high-speed, high-stakes game content in easily accessible town centre locations. And, with gambling addiction now an internationally recognised mental health issue, it is inexcusable that Government continues to promote the economic growth of the gambling sector. Why is it that the Government invests handsomely in tobacco, alcohol and illegal drug deterrents, yet does not offer adequate protection from gambling addiction?
The Department for Culture, Media and Sport (DCMS) is committed to the economic growth of the sectors it is responsible for, including gambling. However, what the DCMS and Gambling Commission are in denial of is the harm to public wellbeing that the promotion of gambling causes. This socio economic cost is currently estimated at
£3.6 billion per year. It is estimated 13,000 jobs are lost across the wider consumer economy for every £1 billion lost on FOBTs in betting shops.
FOBTs are increasingly a source of criminal behaviour in betting shops with an
8.2% rise in police call outslast year attributable to acts of violence towards machines or as a consequence of losses on them. This rise is despite a policy of non-reporting of criminal damage by operators and reluctance by the Gambling Commission to investigate properly the scale of the issue. When the Gambling Commission does investigate serious issues of non-compliance their approach is distinctly non prescriptive -
slapping the wrists of Coralfor allowing £900,000 to be laundered through their shops.
In the Commission’s licensing, compliance and enforcement policy statement it suggests that it will enforce “enhanced compliance and voluntary settlements”. Given that several counts of bookmaker failings such as a lack of anti-money laundering controls and social responsibility controls have been identified by investigative journalists, whistle blowers and police inquiries, it brings into question just how the Commission considers enhanced, voluntary settlements as an effective response?
It is concerning that the Commission is already back-pedalling on standards of transparency – having removed already published enforcement notices from its website – despite claiming that “openness and transparency are central to [its] work in upholding the licensing objectives”. The recent introduction of an independent watchdog, the Senet Group, will impose fines on non-compliant operators – the four founding and so far only members. However, non-compliance within Senet Group members is unlikely, as they set the standards themselves.
Similar to the Commission’s claim to enhance compliance and voluntary settlements, the Senet Group initiative is only PR spin if there are no meaningful disclosures and no meaningful sanctions applied.
One Gambling Commission Director already has a historical association with a similar watchdog in the drinks industry.
The updated Commission statement also identifies how it ensures that gambling is conducted in a “fair and open” way. Our Campaign position is that the Commission is already failing in respect of FOBTs and remote gambling. For FOBTs there is no information provided to the player explaining that the payback percentage of 97% does not apply to funds deposited, but to the amount wagered.
Hybrid games on FOBTs are also a cause for concern, irrespective of the view regarding an appropriate maximum stake on FOBTs. Hybrid games allow B3 style games at stakes up to £2 maximum, to morph into B2 games with higher staking opportunities. A recent
Observer articleexplained this in respect of the Spamalot game offering stakes of up to £30. This is not the full picture though, as a “double or nothing” feature allows stakes of up to £100 per spin.
None of this sounds as though hybrids are “fair and open” gambling. The Commission position of letting operators do whatever they want and then seeing how to fit it into the licensing objectives is an abdication of regulatory responsibility.
Although most of the text revisions by the Commission are welcomed, the Campaign is yet to see the revisions put into practice. It is the Campaign’s view that the Commission is unfit-for-purpose. This is probably a reflection on a Gambling Act being unfit-for-purpose and gambling being under the wrong Government department at DCMS.
The Campaign maintains that the only way to effectively manage the impact of FOBTs is to reduce the stake to £2. And with
Newham
Counciland the
Liberal
Democratsalso sharing this view, the Campaign’s stance is becoming harder for central Government to ignore.