Industry Forum minutes for 26 June 2024

Minutes of the meeting of the Industry Forum, 26 June 2024.

Location: Virtual meeting on Microsoft Teams.

Members:

• Nick Rust (Chair)
• Tony Boulton
• Kirsty Caldwell
• Charles Cohen
• Mark Pearson
• Nigel Roddis
• Helen Walton
• David Williams.

In attendance:

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• REDACTED (minute taker)
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Apologies:

• Ashley Padgett
• Leo Walker.

Item 1: Welcome, apologies, and declarations of interest

Members suggested some amendments to minutes of previous meeting relating to communication between operators and consumers.

Members reflected on how the Industry Forum (IF) has been received positively within the industry as a whole.

An update was provided on the recent Gambling Commission (the Commission) Board meeting in May which was attended by the Chairs of all Expert Groups. It was noted that there could be opportunities for collaboration with the other Expert Groups in the future. IF members remarked that they are grateful for the IF Chair being front and centre as the voice of the industry in forums such as the Commission Board meetings.

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Item 2: Research & Statistics: developing our understanding of unlicensed gambling

An overview of the Commission’s evidence-based approach to research was provided, including a 2-way approach to engaging with stakeholders such as consumers, the industry and the third sector, and a summary of the gaps and priorities in the Commission’s research and data work.

Unlicensed online gambling: The first stage of the Commission’s data innovation project was presented, including ‘why and how’ we are developing data. The success of how the project would be evaluated was summarised:

• the Commission wants to get closer to understanding the size of the unlicensed market via data and evidence which could aid effective disruption
• members were directed to the Commission website on evidence gaps for a more detailed breakdown of areas we are exploring and the sources of evidence we are using
• discussion paper will be published later this year which will help to provide transparency around the Commission work on unlicensed market data.

The work on unlicensed online gambling personas and channels was presented, including the Commission methodology for tracking how consumers find unlicensed sites:

• members observed how unlicensed providers are adapting to other forms of attracting customers, including WhatsApp messaging
• members stated their concern that publishing model methodology risks unlicensed operators using this as an evasion model. The Commission are keen to be transparent to collect more accurate data.

It was explained how the Commission listens to and learns from the experiences of gambling consumers, for the unlicensed gambling project, they sampled consumers who had gambled online within the 4 weeks prior to the survey, excluding those who only play National Lottery draws or scratchcards, and/or those who only take part in private betting. A recap was provided on the Commission's Path to Play research and its relevance to their ongoing project into online unlicensed gambling that aims to understand:

• whether customers are aware of the difference between licensed and unlicensed operators
• the extent to which consumers gamble using these unlicensed sites
• what drives consumers to use the unlicensed sites (whether knowingly or unknowingly).

Examples were given of some of the quantitative findings from research into unlicensed gambling REDACTED. The next steps in the Consumer Voice research and how findings will be used was shared.

Members were asked for their feedback on the unlicensed market and commented:

• the unlicensed market is a major concern for the industry and needs to be addressed urgently. Vulnerable consumers can get around Gamstop leading to the risk of gambling harm. The unlicensed market also poses a serious threat to sports integrity. Another significant consequence is tax and levy evasion from unlicensed gambling providers
• language is important, using correct and consistent terminology when describing the unlicensed market
• the regulator and operators need to provide more clarity around unlicensed and unregulated gambling generally
• concern raised that financial risk checks could steer some consumers towards the unlicensed market
• members are keen to collaborate with the Commission on solving the problem of unlicensed gambling. Commission colleagues responded that they are keen to receive input from the industry on this work
• licensed operators could consider investment into researching unlicensed gambling and how it may or may not make a difference. The view was shared that a collaborative approach is generally favoured on this topic.

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Item 3: Consumer Facing Communications (comms) Campaign

The comms team explained that the Commission have spent the last year looking into the possibility of running a consumer awareness campaign.

The Commission want to be more proactive at tackling misinformation.

Summary given on ‘discovery phase’ of consumer awareness campaign which as a result identified 2 key themes: trust in the regulator including the remit of the Commission and the unlicensed market.

The Commission have been working alongside Yonder, a third party research agency to better understand consumers views and experiences on these topics.

Comms team have worked with different stakeholders to get a wider view of different types of consumers and there is ongoing work to reach different demographics of players.

The Commission are also using data from our contact centre to support the project.

There will be some behavioural insights work and testing on how communications land later this year.

IF members made comments and suggested recommendations for the consumer facing comms project:

• it is important for the Commission to establish the difference between regulated and unregulated operators. The Commission has already got a ‘kite mark’ available for licensed operators to use which serves to notify they are licensed in the UK – along with a register of licensed operators. This could be made clearer
• more communication is needed on the unlicensed market, this would help the Commission to build trust
• there needs to be one message only coming from this campaign, this will help the Commission to measure its success
• does the Commission need to build trust with the public – is that what the campaign should be for? Communication with industry should also be a focus, there are opportunities to collaborate here if a good line of communication is developed
• clarity is needed to understand exactly what the project is for and how it will help to ‘manage behaviours that could lead to gambling harm’ and also exactly how it ties in with the Commission’s objectives
• members raised the questions whether this campaign should be a priority and whether it links to the objectives of the Commission
• is there a crossover with any other organisations looking at a similar topic?

Item 4: Interim Measure: discussion

A discussion took place on the implementation of the interim industry voluntary code and the pilot of financial risk checks. Members shared views including a desire to receive guidance from the Commission around expectations for implementation.

Item 5: Any Other Business and next meeting

Members asked what the Industry Liaison Working Group will be used for.

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