Chair William Moyes North West Reducing Gambling Harms
Good morning everyone. Thank you for joining us today.
The programme that Councils and the Combined Authority across Greater Manchester are launching today is ambitious and very welcome for being so. The adoption of a well-planned public health approach to tackling gambling harms across Greater Manchester is exactly what the National Strategy to Reduce Gambling Harms was designed to stimulate. I and my colleagues on the Gambling Commission are very pleased that you have taken this initiative. We hope it will be replicated elsewhere.
I want to talk today about the background to the National Strategy and the Commission’s plans to build on it. We intend to broaden and strengthen the steps we have already taken to challenge gambling operators and to build partnerships with key agencies such as local government and the NHS to secure effective treatment and preventative services for those whose gambling is causing them real harm.
However, first I want to say how delighted I am that funding of £750k has been secured for this project. This has come from a settlement made in response to regulatory action by the Gambling Commission. It’s great to see such money being used to make a real difference here in Greater Manchester.
I have been Chair of the Gambling Commission for just over three years. In that time the Commission has developed a very strong focus on understanding the scale of gambling harm and developing effective plans to tackle this problem in partnership with others. There are three elements to our approach.
First, we had to develop a reliable and shared understanding of the scale of the problem of gambling addiction.
Today the gambling industry in Great Britain is worth over £14 billion in terms of Gross Gambling Yield, and employs around one hundred thousand people.
Some 24 million people gambled in Great Britain last year and of that 10.5 million do so online, increasingly on their mobile phones. For the vast majority of those 24 million, gambling will remain nothing more than entertainment. But unfortunately, given the wrong circumstances, what had been entertainment could become the source of serious harm, leading to financial difficulties, mental health problems and even suicide.
According to the 2016 Health Survey which is the most robust data, there are around 340,000 problem gamblers in Great Britain and another 1.7 million people are at risk of becoming problem gamblers. But these numbers don’t include the family members, friends or the communities that also suffer harm through the harms suffered by those at risk.
What is less well understood is the cost to the country of gambling harm – families broken up, mental health problems, criminal activity to finance excessive gambling etc. There is more work to be done to develop a reliable understanding of the scale of harm to the country.
As well as understanding the scale of the problem, the Commission has worked hard to engage the understanding and support of other key agencies, particularly the Health Departments in England, Scotland and Wales, and their respective NHS service planners and public health agencies. The outcome is a clear consensus that gambling harms represented a public health problem that required a national coordinated response. This philosophy is very much reflected in your bid to us for funding for this project.
A big part of our role was to develop the National Strategy to provide a framework for planning and intervention by others as well as by us. We believe that strategy has been welcomed and we hope that it will continue to guide others - public bodies, voluntary sector organisations, and gambling operators – in planning different interventions and services.
We will continue to assess the impact of the national strategy and adjust it to reflect changing circumstances. But, it is important to recognise that many of the elements of the strategy require action by others – research programmes to broaden understanding of the problem and how best to tackle it, the development of appropriate clinical interventions throughout the country and education to prevent harm occurring.
However, there are some important areas where the Commission must be in the lead, and these are the second element of our programme of work. The regulatory regime needs to be constantly developed to ensure that it addresses the right issues and it needs to be applied robustly. Regulation also needs to find ways to get gamblers whose patterns of play are seriously harmful to recognise the damage they are doing to themselves and their families and to modify their behaviour.
The Gambling Commission keeps a close watch on gambling companies who operate in Great Britain. Where we find practices that are likely to cause harm or problems that may lead to it, we take action. In this financial year we have already enforced £10.5 million in penalty packages on gambling companies who have not met our licensing standards.
That makes it £50.4 million since 2016, as well as six licence revocations resulting from our enforcement work.
But where we find the market has changed in ways that make our rules ineffective or where we find that there are gaps, we take action as well, to change the Licence Conditions and Codes of Practice. As a result:
- last year we strengthened online age and identity verification requirements to further protect those at risk of harm; and
- just this month we have banned gambling with credit cards. This new ban will come into effect in April and we will evaluate its effect as well as any potential ways of getting around the ban.
We are of course not finished with putting controls in place. To take online gambling as an example, we gained responsibility for regulating the full online market in 2015. Since then we have increasingly cracked down on poor and dangerous practice. Our enforcement work has got tougher; we published our Online Review in 2018 and have been carrying out its recommendations ever since. Now we are seriously looking at other areas where online gambling can lead to harm, including online stakes.
However, to make gambling fairer and safer we need to change the culture of gambling companies and this is the third element of our approach.
Increasingly the Boards of gambling operators claim to understand that they need to put consumer safety first and we welcome this. But warm words are not enough.
My questions to Boards have been and remain:
- How do you know that the company’s stated policies on consumer protection are being followed in practice? How do you know that junior staff and middle management have absorbed the message and changed their behaviour?
- Does the company’s approach to promotion, bonuses, training and development reinforce the message that protecting consumers from harm is top priority? Or does the company’s management regime give the subliminal message that the real priority is growing market share and financial strength?
The evidence is not good. During my time a number of serious licence breaches have involved staff encouraging so-called VIP gamblers to gamble when they had self-excluded.
So, we think that increasingly our enforcement activity will have to consider not just the company, but also the behaviour of key individuals, particularly those who currently hold personal licences or who might be required to hold licences in the future. Perhaps the threat of exclusion of specific individuals from the industry will have a greater impact than fining the company.
In developing this approach we need to understand better the experience of those whose gambling has caused them harm.
In support of the National Strategy, the Commission is actively looking at ways to bring this important voice further into the work of the Commission. Just last week the Commission’s Board also decided to formalise the role of those with lived experience in our own work and we will shortly be announcing the next steps. More widely, funding for projects that will connect with those with lived experience is being found, including funding for the Health and Social Care Alliance in Scotland to give one example.
The launch of a coordinated harm reduction programme here, covering 10 councils and over 2 million residents, is the first scheme of its kind across Great Britain. We will do our best to ensure it is not the last.
In order to advance the aims and objectives of the National Strategy, we need local government, the NHS, the third sector and wider society to work together. It was that approach that led the public health teams across Greater Manchester to come to us seeking funding for their own three-year plan to reduce gambling harms.
Aligned with the National Strategy, your project sets out to:
- Improve the approach to prevention across Greater Manchester to reduce the number of people who start to experience harm from gambling. For instance, by working to establish consistent education provision about gambling across schools and colleges.
- Improve support for those already experiencing harm from gambling by establishing further support clinics, and ensuring robust pathways of care;
- Collect evidence from services and service users across Greater Manchester to better understand gambling related harm and the impact of different remedial approaches - who is impacted, what is the impact of different interventions? Embedding screening across front line providers and collecting data systematically to understand the demographics of gambling harm are a couple of ways to achieve this.
This plan is ambitious in its scope and through a collective effort has the chance to make a difference to thousands of lives and families across Greater Manchester. The need for that collective effort makes it all the more welcome to see so many partners and stakeholders represented here today. It is precisely this level of ambition and this recognition of the collective effort required that made the Gambling Commission happy to support the need to fund this project.
As the National Strategy progresses it is the Commission’s earnest hope that this programme will make progress and act as a valuable example to likeminded organisations and Councils up and down the country. We are already in discussions with others on how they can mirror the progress made here and before too long I hope we will be announcing support for similar programmes in other parts of the country.
And of course, the Gambling Commission will continue to use the full weight of our regulatory powers to support your efforts.
Today marks a great step forward in the struggle to understand, prevent and reduce gambling harms. If we all work together, we will make progress.