National Strategy to Reduce Gambling Harms
Launch of the National Strategy to Reduce Gambling Harms
Thursday 25 April 2019
William Moyes, Chair, keynote speech
Welcome to the launch of the Gambling Commission’s National Strategy to Reduce Gambling Harms. I and my colleagues are very pleased that you have found time to join us today.
I am especially glad to welcome the Minister, Mims Davies MP, and Professor Tim Kendall, the National Clinical Director for Mental Health for NHS England. Thank you both for joining us.
Although the Gambling Commission has led the development of this strategy and will play a leading part in delivering it, we haven’t been working in isolation. We have had excellent support from Ministers and officials in DCMS, the Departments of Health and Social Care and Education, and their counterparts in the devolved administrations. We are very grateful for this support and we look forward to working in partnership with you to deliver the strategy.
Before I turn to the strategy itself I also want to thank Sir Chris Kelly and his colleagues on the Responsible Gambling Strategy Board. Their work over the last six years has made a significant contribution to improving knowledge of how gambling can become harmful, and understanding of the steps that the gambling industry, the Commission and others could take to identify when harm is occurring and how to intervene effectively to tackle it. Their thinking and research has greatly influenced the content of the strategy we are launching today.
The purpose of this strategy is clear and simple. The Gambling Commission is determined to make better and faster progress in reducing gambling harms, and to achieve substantial and lasting progress over the next three years, which is the period covered by the strategy.
Whilst the majority of people who gamble do so without experiencing harm, the consequences of gambling harm can be severe and can impact individuals, families and wider communities. This strategy is therefore focussed both on reducing the harms that can be faced by people who gamble and those harms that may be experienced by friends, families and others.
Delivering a significant and sustained reduction in such harms will not be achieved by a narrow focus on ‘responsible gambling’. That is an approach that places too much of the burden on the individual to gamble responsibly and not enough responsibility on businesses, and those that oversee them, to ensure that gambling is provided in a way that maximises protections and minimises the risk of harm.
That is why we have not simply rolled forward the existing National Responsible Gambling Strategy. Instead we are today launching a new National Strategy to Reduce Gambling Harms. A new strategy with a new approach- a public health approach- that focusses much more on the part that products and the environment play.
The focus of this new strategy couldn’t be clearer with just two strategic priorities:
Prevention and Education-
There is a clear need for a framework for gambling harm prevention and education which identifies the right mix of interventions to be applied at both the individual and population level.At one end of the spectrum this means information and education campaigns that raise awareness of the harm that can result from gambling. At the other end of the spectrum it means imposing regulatory restrictions, on a precautionary basis when necessary, upon those products and gambling environments that pose the greatest risk of harm.
By deploying in a more coordinated way the weight of regulation to drive industry behaviour and the power of education to inform consumer behaviour, we can deliver a seismic shift in harm prevention. An approach designed not just to seek to mitigate harms once they have occurred, but an approach that actively seeks to prevent those harms from happening in first place. Prevention, not just mitigation. Tackling the causes, not just the symptoms.
Of course, no system of prevention will provide a guarantee that harm won’t occur in the future. Nor will it help address the harms that may already be occurring. That is why the second strategic priority focusses upon the treatment and support that people should be able to access if their gambling is becoming harmful to themselves or their families.
Treatment and Support-
Until recently gambling harms didn’t have the same visibility in our health systems as other public health challenges. That view is changing, thanks in large part to the work being done by public health bodies across Scotland, Wales and England.
And the consequence of that is a growing recognition that the NHS has a bigger part to play in designing, delivering and assessing services for those who need support when gambling may have become harmful.
Indeed, the NHS is probably already doing more to treat gambling harms than anyone recognises, because people with addictive gambling behaviour often display other health problems. These co-morbidities tend to become the focus of NHS-funded treatment, and the addictive gambling behaviour can often be overlooked, particularly if clinical staff are not trained to spot the symptoms of addictive gambling behaviour and to know how to intervene.
So, the Commission warmly welcomes the statement in the NHS long term plan to invest in expanding NHS specialist clinics to help more people with serious gambling problems. Alongside the strategy we are launching today there is a clear opportunity to make significant progress towards truly national treatment and support options that help ensure that people can access the type of support they need, when they need it, and where they need it.
To ensure that real progress is made on those two priorities, the strategy sets out the four vehicles through which action will be enabled:
- Regulation and oversight-regulators and other oversight bodies working in partnership to prevent harm and to increase the quality and public accountability of the treatment and support system.
- Collaboration-seeking out innovative approaches to reducing harms by encouraging collaboration between different businesses and organisations and across different sectors.
- Evaluation-having a clear focus on what works best to reduce harm and by the widespread adoption of a firmly evidence-based approach to evaluating the success of prevention activities and support services.
- Research to inform action-having robust, independent research that not only increases our knowledge and understanding but that drives real action to reduce harms.
Together these four enablers will more sharply focus the activities under the strategy and put all of us in a strong position to deliver the strategic priorities.
The Commission recognises that this is an ambitious strategy and we intend to put the full weight of the Gambling Commission behind it to ensure that we make real progress in delivering on those ambitions. A full implementation plan will be published by the end of July.
However, we are not blind to the challenges that exist in reducing gambling harms. As is often the case one of the most significant hurdles we will face is the availability of resources. Nevertheless, we are determined that this challenge cannot be allowed to derail progress.
We need the appropriate structures in place to ensure that the money goes to the right destinations, that commissioning is effective and efficient and that all stakeholders have trust and confidence in the independence of the system.
Under the leadership of Kate Lampard, GambleAware have taken significant steps to reassure stakeholders that they are independent of industry influence and have focussed upon improving the effectiveness of their commissioning arrangements. However, it is clear from the consultation responses we received when developing the strategy that a wide range of stakeholders still do not have sufficient trust in the current arrangements for research, education and treatment and do not feel confident that they deliver independent research or fully effective treatment services.
We must tackle this lack of confidence and create arrangements that command widespread support.
We cannot continue to have an approach where GambleAware or other commissioning bodies have to rely upon uncertain and unpredictable voluntary funding streams.
We cannot continue to have a system that makes it too easy for the independence of research to be challenged (sometimes mischievously and without basis) simply because it does not match someone’s world view.
We cannot continue to operate treatment services without the types of public oversight and accountability that other health services face.
That is why over the coming months we will work with partners to review the current approach, under what is known as the ‘tripartite arrangements’, to build trust and confidence and develop an approach to addressing harms that is as good as is found anywhere.
Alongside a more trusted and accountable system we must also secure appropriate funding. Resources must match the real need for services and should not be constrained by an unambitious (and perhaps false) view on what gambling operators are able and willing to contribute. In a nearly £15bn industry, money should not be the biggest hurdle to successful delivery of this strategy.
The last few years have seen a series of pretty pointless debates over what proportion of Gross Gambling Yield the industry should contribute; whether GambleAware needs £10 or £12 million; and whether almost meeting those fairly low targets is a sign that the voluntary funding system is working well enough.
I want to be very clear about the view the Commission takes. The current levels of funding come nowhere near to addressing the real needs. Whilst we do not yet have a single figure or calculation for how much should be contributed, a quick glance at last year’s report on progress against the former strategy should tell us all we need to know. The RGSB concluded that based upon the need for more people to access support and treatment; based upon a requirement for more effective, independent research; based upon a public health approach to prevention and education- we should be looking to generate £70 million a year…at least.
So, it is now very clear where the industry needs to get to next. We welcome the stated commitment in your Board rooms to making gambling safer. We acknowledge the positive signs of growing cross industry collaboration on addressing harms. But the time has come to back good intentions with hard cash, at a level that matches the challenges, and can be relied on year after year. It may take some time to reach required levels of funding but the journey needs to start now.
Of course, anyone who has run a public service or a third sector organisation will know that the level of funding isn’t the only resource challenge you face. The sustainability and certainty of those funding streams are just as important to building services that are resilient and that meet current and future needs. The system of prevention and treatment of gambling harms is no different. That is why the effective delivery of this strategy will require there to be an adequate, predictable and sustainable level of funding. Our ability to direct funds to promote research, education and treatment is increasingly dependent on operators breaching their licences and then agreeing settlements – often substantial financial settlements – with the Commission. No one will be able to plan properly to deliver this strategy if prevention and treatment continues to be funded by voluntary contributions from industry or regulatory settlements following licence breaches.
The implementation of a statutory levy, the powers for which are already on the statute book, would not only help to secure appropriate levels of funding but would provide a certainty to the funding streams that would allow for a sustainable and more long-term approach to be taken. Our support for the principle of a statutory levy is already on record, in our advice to government during the Gambling Review.
The publication of this new strategy has not diminished that support. Indeed, it has brought into sharper relief the need for such an approach to funding. The Gambling Commission continues to support a statutory levy to fund prevention activities and treatment and support services.
So those are some of the challenges. But alongside challenges come tremendous opportunities. An opportunity to make the British gambling industry the safest in the world; an opportunity to build a treatment system that gives people the support they need, when they need it; an opportunity to have a real and positive impact on people’s lives and people’s communities. Those opportunities can only be fully exploited if we work together. Whilst the Gambling Commission has unashamedly taken on the role of leading the development of this strategy, successful delivery can not be by us alone. What this strategy does is to open the door to those with lived experience; to industry; to academics and researchers; to the NHS and other public services; to fellow regulators.
Gambling related harms are a public health concern and a public health response requires strong partnerships and co-operation. For those that are already working with us I believe that this strategy gives us a strong framework to further develop our current partnerships. For those that we are yet to work with we hope that it will act as a starting point for future partnerships.
To close I don’t want to speak to the politicians, the regulators or the industry CEOs in the room. I want to turn to those who have direct, lived experience of gambling:
- To the leisure gambler: who wants to feel reassured that their gambling can remain enjoyable and safe
- To the person who feels that they are starting to lose control over their gambling: who wants to seek support
- To the friend or relative: who wants to know how best to respond to their loved one’s challenges with gambling
- To the parent that has lost a child to gambling related suicide: who wants to stop their tragedy from affecting others
Your experiences have played a significant part in shaping this strategy. As we and others implement the strategic priorities we will do so in a way that is always grounded in evidence and expertise. Yes, that will include drawing upon people who are experts through academic research. It will include people who are experts because of their professional history in the gambling industry. But importantly we will also place the voice of experts by experience right at the centre of the delivery of this strategy. People whose expertise comes from first hand experience of the highs and the lows that can come from gambling. Because together we will make better and faster progress to reduce gambling harms.