Raising the bar

Not long ago I visited the yearly forum on gambling addiction held by NGOs and support groups around Sweden, Norway and Denmark. When listening to the speakers presenting the latest findings and research about problematic gambling and gambling addiction, I was left with the thought: gambling addiction should not be about politics.

Gambling addiction is a psychiatric diagnosis that belongs to the group of ‘addictive disorders’ (as stated in the Diagnostic and Statistical Manual of Mental Disorders, known as DSM5). Gambling addiction is classified as a nonsubstance disorder and what’s clear is that a person afflicted with this disorder really suffers. Like other similar addictive disorders, such as alcoholism, it is not only the person suffering the disorder that is affected. It also brings harm to his or her friends and family.


Recent figures from a Swedish longitudinal gambling study show that 75,000 children live with someone who has a gambling problem. For such a small country, that is a high figure.


It’s easy to close our eyes and wish that the problem would go away. It’s even easier to point our fingers at others. But the problem won’t go away, because gambling addiction is a real problem and it affects real people. The fact is that the gambling arena is expanding.

It is getting more intense and games are getting more accessible. We get exposed to gambling more and more. A recent study from England, written by Ofcom (independent regulator and competition authority for the UK communications industries), show that 4% of all TV commercials are advertisements for gambling. On an average, a child is exposed to four gambling advertisements per week.


The debate is focusing a lot on finding the one “who is responsible” and “the owner of the problem”. Well, that one person does not exist. The discourse about gambling and gambling related problems includes a lot of stakeholders, such as operators, regulators, politicians, the healthcare sector, social services, and of course: the players. Since we do know a great deal of what the risk factors of developing problems are – let’s make sense of that knowledge and take full responsibility ourselves.


The gambling industry must focus on how they can contribute to harm minimisation – and decrease the possibility that their players develop gambling problems. How data analytics can be used to promote harm minimisation is the question. The science of psychology is trying to describe how humans behave – and then try to understand the reasons for that behaviour. It works in that order, first we need to visualise how people behave before we can understand them. Maybe the gaming industry could learn something from that?


A responsible gaming operator needs to have knowledge about the risk status of their players in order to act in a responsible way. For example, statistically unhealthy gamblers make up around 2% of the adult population. One question to ask is: how much of the operators revenue do they stand for? Data analytics and especially behavioural tracking tools are one way of getting that knowledge.


These tools find order in seemingly unstructured data and they measure the risk of developing problems. For the gaming provider, data analytics of gambling behaviour can provide intelligence about their player population and, as a consequence, find ways to act to minimise risk. This is a good thing not only for the player but also from a business standpoint since an unhealthy player is a viable risk, they are volatile and a possible ticking bomb of bad PR.


Sharing the information – gathered through the use of a behavioural tracking tool – is a good way for the gaming operators to act. This educates not only the player on how to avoid getting into trouble (and behave in irrational ways that affect their life by jeopardising relationships, education and their jobs). It also enables the player to make an informed choice about their gambling.


That same information could also be used for harm minimisation in a greater sense. If data, knowledge and information are shared with other parties within the gambling sector (regulators, academia and researchers, help lines and treatment centres) the sharing party will not only receive great PR, but the idea of what responsible gambling really is can be taken to a whole new level.


However, dogmatic minds must be left behind. Reflecting on how new research and tools can improve responsible gambling is a preferable approach.


When we talk to responsible operators who offer these kind of tools to their players they say: “There is not one thing that will work on its own – it’s the overall effort”. And that is the thing. There isn’t one single thing, one person or one actor in this industry that can solve the problem. The responsibility of solving it must be shared, but describing and understanding the problem is a good start. Sharing that knowledge and taking a cooperative responsibility is the beginning of raising responsible gambling to another level.

Responsible Gaming

John LuffResponsibly has never been more “hot” as a topic and the gaming/gambling sector is no exception. Not only is it vital that we protect our players – it is equally important that the reputation and integrity of our organisations remain intact.

In the past responsibility was too often regarded as “worthy” – something to support/embrace because an organisation could or worse, because they could not avoid it for regulatory/legal reasons. Now it is a business necessity. Responsibility simply makes good business sense.

Founder of UK based Sustainable Marketing and World Lottery Association Responsible Gaming Independent Assessment Panel member John Luff explains why.



Responsible gambling embraces employee and retailer training, player education, treatment referral, marketing, game design….indeed the whole of an organisation’s attitude and approach.

So why does responsibility make business sense?

Every organisation is unique, and so the reasons for pursuing responsible business practices will vary for each organisation. However, these five key reasons remain constant:

  • Gaining regulatory acceptance
  • Increasing brand loyalty
  • Fostering employee emotional commitment
  • Winning supplier, partner, and distributor support
  • Improving organisational performance



Go beyond compliance

Regulators want independent, professional and transparent evidence that a gambling operator has the structures, processes, strategies, and overall culture that will best serve citizens in the regulators’ jurisdictions.

Nowhere is the regulator’s concern more focused than in the area of responsible gambling. Indeed, while operators may raise money for good causes as well as paying taxes, providing employment and contributing to society and the economy in other ways, the means are just as important as the end.

One of the principal precepts of medical ethics, “First, do no harm”, is as relevant today to the gambling sector as it is to the medical sector. Regulators worldwide are waking up to the effects of gambling related-problems on society and their job is growing in scope, size, and complexity. They are looking for proof positive that operators are doing their part to address gambling-related problems and those operators are striving to protect their communities from gambling-related harms.

All successful operators know that compliance is increasingly becoming an entry-level requirement. They realise that in presenting their case, they need to go beyond proving mere compliance.

Compliance will get you to the starting blocks, but it will not help you win the race.

This is especially relevant for gambling operators that face strong competition within their jurisdictions or are applying for licenses outside their jurisdictions. Not only does providing proof positive evidence of responsible structures, processes and strategies strengthen your business case – it serves as proof positive that you have taken your organisation beyond mere compliance. Today, if you want to be in business you have to demonstrate that you embrace responsible business.



The golden rule of marketing- trust equals brand loyalty

Today choice is increasing in all markets and sectors. But in no sector is it expanding as fast as in the gaming and gambling sector. Within the space of a few years it has moved from restricted player choice to the point where player choice is virtually exploding. Expanded player choice has been generated by the emergence of new suppliers, new products, new technologies, and new marketing strategies. It has been further enhanced by open legislation, trans-border possibilities, and convenient access to gaming/gambling platforms.


When consumers are confused or overloaded with choice, they turn to brands that they trust. Hence, as choice increases, so does the importance of your brand. This golden rule of marketing holds especially true in our increasingly global market. Players will remain loyal to and recommend the brands that are seen to have the players’ best interests at heart.

But it is not just about customer numbers; it is about maintaining good relationships with the right kind of customers. A good reputation for responsible gambling will help a lottery to attract the right kind of customer, and to retain a responsible, constant, and steady customer base. A good reputation can actually extend your customer base. Potential customers that may initially be put off from gambling are more likely to give a reputable operator a try. Perhaps most importantly, it is easier in any sector to retain a customer than it is to win back a lost customer. Nothing loses a customer more quickly than loss of trust.

In this context, responsibility contributes powerfully to the marketing mix. A responsible approach to business and to gambling in particular can be promoted via above-the-line marketing, through your social media presence, and in your lobbying activities. It is an important tool in getting your message across to such customer-influencing elements as the news media and consumer advocacy groups.



Employee commitment: Winning hearts and minds

An organisation cannot prosper without the faith and support of its members. It should permeate every aspect of the organisation – from the highest levels of corporate governance, down to the people that sell the products and how they are sold. There can be no more concrete evidence of an organisation’s true culture and commitment than its approach to responsible gambling.

Knowledge that your organisation has a world-class approach to responsible gambling evokes an employee’s emotional commitment and fosters pride throughout the organisation. Employees will be more likely to stand behind their organisation, work harder for it, contribute to its success, be more creative in promoting it, and – most importantly – endorse it outside the workplace, if they are proud to associate themselves with it. “You can’t sell it outside if you can’t sell it inside” may be a cliché. But it is a cliché for a good reason – it’s true.



Business partner and other stakeholder support

No organisation works in a vacuum. All organisations need suppliers, distributors, and other business partners for an ever-increasing variety of reasons. These business partners have a choice: whether to work with you or not. If so, how enthusiastically do they want to work with you and with what level of endorsement? Do they even want their brand or their business to be associated with you?

What applies to your customers and your employees, applies to your business partners as well. The same holds for other stakeholders, such as community groups, academic institutions, research bodies, and lobbyists. They all need to know that your organisation is reputable and can be trusted. They need to believe – indeed to know – that an organisation’s responsible gambling practices are reputable, trustworthy, and best-in-class.



The path to improved performance

All organisations – in their commitment to responsible gambling – will want to know the answers to the following questions:

  • How well are we doing compared to others – in our sector and outside?
  • Is our responsible gaming programme on a path of continuous improvement?
  • Is what we are doing best practice?
  • Could we do what we are doing more effectively, more efficiently, and more economically?
  • Are there any new ideas with regard to responsible gambling that we should be considering?
  • Do we have the best possible responsible gambling measures, structures, and processes in place?


Although internal audits and formal management accounting reviews will touch on all of these questions, an external responsibility audit can help the applicant clarify the answers to all of these questions through its precise structuring. Indeed, commitment to responsibility by its nature requires some form of external validation by a recognised and reputable agent.

The audit should embrace global standards, yet allow for cultural and regional differences. Individual national and regional forms of accreditation do exist, and many of them are excellent. But we live in a world where brand awareness has gone global, owing in large part to the “always on” nature of today’s technology. As a result, all stakeholders increasingly expect organisations to measure themselves against global standards.

The evidence required for responsibility relates to the day-to-day management of an organisation. Nothing is requested that should not be readily available as part of the organisation’s daily business. Therefore no extra costs or resources should be entailed by having to gather additional information or data to meet an external audit.

A responsibility audit should be designed to complement and improve the safeguards that individual operators already have in place – not meant to replace them. Similarly, it should not compromise regional, national, or international regulatory compliance nor should it conflict with professional requirements. They should, however, allow organisations to showcase their steps toward compliance and prove how their responsible gambling programmes go above and beyond compliance.


Conclusion – layers, guns and money

Of course, you do not have to choose responsibility. There is always a choice. But in my view the only choices are embrace, celebrate and communicate your organisation’s commitment to responsibility or in the words of Warren Zevon be prepared to send for “lawyers, guns and money”. Please put aside the guns but in an age of social media enabling transparency at the speed of light if you are anything less than responsible you will need the money and lawyers.


John Luff