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BACTA Social Responsibility Exchange - Mandy Gill Speech

01 November 2023Speech by Mandy Gill

This speech was delivered by director of industry and specialist knowledge Mandy Gill at the British Amusement Catering Trade Association (BACTA) Social Responsibility Exchange on 31 October 2023.

Please note: This is the speech as drafted and may slightly differ from the delivered version.

Hello everybody and thank you. It is great to be here at the BACTA Social Responsibility Exchange to speak to you today.

It is also great to see so many of you here today as well. As I am sure you all know, the Gambling Commission often has to talk about the issues we find and the failings we take action against but attending an event like today is a palpable demonstration of wanting to do the right thing and so I want to thank all of you and your businesses for taking part. I also want to thank BACTA for again hosting this event, providing practical support to their members to keep gambling safe, fair and crime free.

Today I want to discuss with you some of the social responsibility successes and failures we see at the Commission. I’ll then provide a bit of an update on consultations, including the first window of Gambling Act Review (GAR) consultations which has just closed and a forward look to the second window, as well as the Department for Culture, Media and Sport (DCMS) consultation on a statutory levy. But first, I would like to start by just giving a bit of an overview of the size of the market as a whole and then a closer look at the land based and arcades sectors.

So, what do we see when we look at the GB market? When we look at gambling across England, Scotland and Wales, I think the first thing that becomes apparent, is that despite the upheavals and uncertainty of recent years, it’s clear that the British market looks and feels like the mature licensed market that it is. When we look at the statistics we have published on participation in gambling in Great Britain we see:

  • the year to end of March 2022 saw Gross Gambling Yield (GGY) at £14.1 billion
  • and when we look at participation, the year to end of March 2023 saw 44 percent of adults taking part in a gambling activity in the last 4 weeks.

Beyond this, the land-based gambling participation rate for the last year remained statistically stable at 27 percent and online has also remained statistically stable at 26 percent. So, although the long-term trend is still for growth online, there is no explosion in online participation.

When we look specifically at gaming centres and arcades, in the year to March 2023 participation stood at 1.6 percent, down from 1.8 percent in the year to March 2022.

Over the last few months, we have had a couple of major enforcement cases that have concluded resulting in some quite substantial penalties as a result of failures in land-based premises. They are not operators of arcades, but I do think they are worth mentioning as examples of some of the social responsibility failures we have seen and taken action against.

In July we announced that one high street operator would pay a regulatory settlement of £3.25 million due to failings in the processes which were aimed at safer gambling and preventing money laundering. This was an operator that operates at the large end of the spectrum and, to many of you here today, the issues and lessons of this case may feel less relevant. But I want to highlight that this underlines that at the Commission we take land-based compliance just as seriously now as we ever have, and as some of you will know from recent assessments, with in person visits to premises very much back in the mix.

Our recent compliance and enforcement work shows that land-based operators should remain vigilant, in particular, to the risks of their customers experiencing gambling harms, while making sure they have the right controls in place to minimise the risk of money laundering.

But I do not want to stand here and just talk about where we have found failings in different premises based operators. Overall, we know the success rates for age gating in premises like yours is on a par with test purchase results in other sectors like alcohol sales in shops and supermarkets, and I thank you for your continued efforts to improve this and protect children and young people from gambling. On that subject, we also acknowledge that BACTA members have voluntarily implemented a ban on under 18s using Category D slot machines with a cash prize. As you’ll know, DCMS have recently consulted on moving that ban into legislation.

I do not think it would be a Gambling Commission speech without giving you a brief update on the Gambling Act Review and our associated consultations. As you will know, the first consultation closed on 18 October. This covered financial vulnerability checks and financial risk assessments, cross selling and direct marketing, removing features which increase intensity of play on non-slots casino games online and finally, age verification in premises.

I do think it would be helpful to run through, considering that the consultations that they have just closed, along with the second tranche, will have an impact on your businesses and touch on some social responsibility areas.

We received over 3000 responses to the consultations, with the financial vulnerability and financial risk checks driving many of those. I hope many of you, whether as individual organisations or feeding into BACTA response, managed to submit a response. These are genuinely open consultations where we want to hear from as many people as possible.

As we have mentioned, financial vulnerability checks and financial risk assessments will not extend to land-based premises. This is a policy for remote gambling only, so if anyone in the audience was worried about implementation of this policy, please do not be. You also will not be affected by the changes to online non slots casino games of course, as this applies to remote gambling only as well.

However, the remaining two, on direct marketing and on age verification in premises, will impact you. Cross selling and direct marketing in land-based premises may not be as prevalent as online operators, but our proposal was to explore improving marketing preferences for all gambling customers.

Secondly on age verification in premises. Now as I mentioned earlier, land-based operators do a good job of verifying that customers are old enough to be allowed to gamble. This consultation asked about increasing the age in which we considered it good practice for staff to challenge customers to verify their age from 21 to 25, bringing this challenge in line with other products such as tobacco and alcohol. So should the changes suggested in the consultation or similar changes to those be introduced once we have reviewed the consultation submissions, this would be another key consideration for the sector.

You will also be aware that the Commission has been supporting DCMS with regards to their own land-based consultation which included proposals related to machine entitlements in arcades and bingo and cashless payments on gaming machines. Alongside that work the Commission has also began some pre-consultation engagement with industry on its own review of the Gaming Machine Technical Standards that will include an assessment of the role of session limits across Category B and C machines and the role of other safer gambling measures and tools – such as those included within your ‘Responsible Game Design Code of Conduct’.

As you will know, a couple of weeks ago the Government launched its consultation on the statutory levy. Just to highlight, the consultation proposes a rate of 0.1 percent on land-based arcades and bingo, to be paid by operators with GGY over £500,000.

Now the levy consultation is being ran by DCMS, not by the Commission. But I would encourage you like I would with any Commission consultation to submit a response, either through your own individual organisations, or by feeding into BACTA's response. This really is your chance to get your voice heard on an incredibly important issue.

Moving onto the next tranche of consultations. We are already moving forward to the second round of consultations which we expect to publish in early Winter. Although not yet finalised, I can tell you that this tranche will contain important opportunities for people to have their say on proposals including:

  • socially responsible incentives - ensuring that incentives like bonuses and free bets are constructed in a socially responsible manner that does not exacerbate the risk of harm
  • gambling management tools - including whether it is appropriate to make online deposit limits mandatory or opt-out rather than opt-in
  • regulatory returns – my colleague Ben Haden, who is the Director of Research and Statistics recently published a blog on our website which explains the reasoning behind the changes, but we will consult on increasing frequency of regulatory returns, and removing a significant number of items that are out of date or not useful.

Again, a couple of areas here that touch on social responsibility and that you may be interested in due to potential impact on you as operators. The major one being the first, socially responsible incentives. Now as I say these are yet to be finalised, but just a heads up so you are aware that this is one of the areas in which we will be consulting on shortly.

As some of you will be aware, in June we hosted an account management workshop where we discussed some of the ways in which the Commission can improve its working relationship with operators. I think we had a really good discussion, and some of you had a really good vent at some of the issues with that relationship.

I am pleased that we have now begun to move into the next stage of implementation of an account management structure and I know that this work is now moving forward. I know that this will provide a genuine opportunity to work through how the Commission can work better with operators over the coming years. I am afraid to say I will not be here for that journey as I will be moving to pastures new soon, but I am sure the Commission staff working in this area will work hard to ensure that this new approach works and is useful for both sides.

So just to end, I want to say thank you again for inviting me along to speak to you today. This is an incredibly busy time for the Commission as we implement the Government’s White Paper, and no doubt it is for you as you are impacted by it too. We’ll continue to engage and continue to listen to responses to all of our consultations. We’ll also continue our work to make gambling safer, fairer and crime free, and I thank you all for your assistance and support with this. I hope you have a great rest of the day.

Last updated: 1 November 2023

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