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October 2019: Industry Challenges

Phase one of the Gambling Commission’s Industry Challenge initiative, set at our industry briefing in October 2019.

  1. Contents
  2. Phase one: Update on industry progress
  3. Expert Groups’ input to Commission thinking

Expert Groups’ input to Commission thinking

Feedback from experts by experience highlighted the risks that incentives pose to vulnerable groups and questioned the ability of the industry to self-regulate. The dominant view was that HVC schemes should be banned altogether as they acted as an accelerant in their own personal gambling behaviour. For the Expert by Experience Group it is a unanimous view.

Of the 26 former HVCs who contributed to the GamCare Forum survey, half stated the HVC schemes caused them to spend more on gambling. The EbE group saw no evidence from their own experience or wider research and practice to suggest that HVC schemes are “safe” at any age and that the restriction to over 25s was wrong and in their view schemes are either safe or they are not.

Short of a ban, suggestions for additional controls included robust affordability and safer gambling checks and a requirement to establish a customer’s source of funds. GamCare staff highlighted the importance of progressing a single-customer view solution to avoid circumvention of these controls.

A single customer view solution is where it would be possible to understand a customer’s holistic gambling activity across all operators to enable a more informed and consistent interaction when appropriate.

The feedback identified heightened risks associated with social isolation and the sense of status associated with being treated as an HVC. At the Expert by Experience workshop, the use of knowledge of customers’ preferences, habits and vulnerabilities by HVC staff to offer incentives, which encouraged increased gambling or a recommencement of gambling after a period of inactivity was highlighted.

In feedback from GamCare staff, this point was also linked to the question of VIP staff remuneration and the risk of incentivising commercial targets to the exclusion of player protection.

Transaction or monetary based customer incentives were identified as more common than hospitality or gifts, and there was concern about the impact of customers striving for a higher tier of HVC status or gambling beyond their means to receive specific incentives.

Aside from HVC schemes, the use of monetary incentives more widely to promote gambling services was cited, such as free bets, as problematic and something the Commission should address.

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Industry progress
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Commission Assessment
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