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Lotteries Council Annual Conference - Sarah Gardner keynote

18 May 2023Speech by Sarah Gardner

This speech was delivered by deputy chief executive Sarah Gardner at the Lotteries Council Annual Conference on 18 May 2023.

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

Hello and thank you for that introduction. It’s great to be here at the Lotteries Council annual conference and I’m looking forward to your questions later. The Gambling Commission, as the regulator for gambling across Great Britain, works with Local Authorities to regulate the Society Lotteries sector and so we really value the opportunity to join you each year for your Conference. I know for a fact how valuable our dedicated Society Lotteries team find this event and the opportunity to catch up with so many of you face to face.

Society Lotteries or Charity Lotteries play an enormously important role in our communities. Alongside the National Lottery, Society Lotteries raise great sums for good causes up and down the country and everyone in this room should be commended for your efforts for the public good your work leads to, year in and year out. Whilst we don’t track the totals for smaller society lotteries, it’s worth pointing out that in the year to March 2022, large Society Lotteries raised £417 million for good causes. Coming through a pandemic as we have done, it makes clearer just how important fundraising for charities and good causes is. That said, how each organisation in this room today raises that money is done through the offering of a gambling product and as we will see, many more people now play Society Lotteries online than they do through the physical purchase of tickets or scratch cards.

So today, I want to spend a bit of time looking at the sector, the value it brings to communities and how it fits amongst wider gambling. I’ll spend some time reviewing how the publication of the Government’s Gambling Act Review White Paper a few weeks ago impacts on the Commission’s work and how it may impact on the Society Lotteries sector. And I’ll finish on highlighting a few areas where I think we can work together to achieve better outcomes for both consumers and the good causes you raise money for.

But first, where are we today when we look at Society Lotteries in Great Britain?

Now as many of you will know, smaller society lotteries are licensed at the local level, not by the Commission. But I think the following stats still illustrate a picture that is worth studying. When we look at gambling across England, Scotland and Wales, I think the first thing that becomes apparent, is that despite the upheavals and traumas of recent years, it’s relatively clear that the British market looks and feels like the mature licensed market that it is. When we look at the stats we have published on participation in gambling in Great Britain we see:

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

Of course, with statistics you can always see more the closer you look but, that these statistics are relatively close to where the gambling sector was at the start of 2020 is of interest in itself.

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

But how do those overall trends compare when we then focus in on the Society Lotteries sector?

  • in year to March 2023, 13.4% of adults had participated in a charity lottery in the last 4 weeks. This has increased from 10.8% in 2018 and was one of the only gambling activities not to see a significant decrease in participation during the Covid-19 pandemic
  • participation in charity lotteries increases with age. In 2022 participation in charity lotteries was 17.3% amongst 65+ year olds, compared to just 3.0% amongst those aged 16-24
  • thirdly, females are more likely than males to participate in charity lotteries, with 16.2% of females playing compared to 10.5% of men in year to March 2023. This is one of the only gambling activities to have a higher participation rate amongst females than males, Bingo being another notable one
  • finally, in year to March 2023, around three fifths, or 63% of people participated in charity lotteries online against one third or 34% participating in person. This balance has shifted over time with more people choosing to take part online rather than in person.

So what does this tell us? Society Lotteries are a successful gambling product and have been growing the number of participants in recent years, despite the Covid-19 pandemic. Those participants look different to the players of most other forms of gambling too. And as I’ve already said, they raise an enormous amount of money for good causes across the country. There is plenty to mull over in these numbers for all of you in this room. But the statistic that jumps out at me there is the rate of online play. Given that the growth of online gambling has slowed somewhat, the level of play for Society Lotteries online is stark. And that raises questions. How well do you know your customers online? Online play is of course very different for society lotteries compared to other types of gambling, often just a method of payment. But whether you’re simply offering an online payment option or have developed instant win products, questions on how you interact with your customers online are worth considering in either case.

Society Lotteries are generally a force for good in our communities, raising invaluable funds for good causes but at the Commission, we want to make sure that the good work you do isn’t tainted by failures to meet our standards.

And I know that you want the same thing.

The Gambling Commission, nationally, has the role to permit gambling but only where it is in line with our licensing objectives. So how does making gambling safer, fairer and crime free look in the year ahead?

It is of course not quite a month since the Government published the Gambling Act Review White Paper. At the Gambling Commission we supported the Review. We’ve been working closely with our sponsoring department, DCMS, on it and we published our Advice to Government on the same day the White Paper was published. We are now working closely with Government, stakeholders and partners, to push forward with implementation of the White Paper.

Now I appreciate, some of you may wonder what this has to do with you? But I think it's fair to say that with such a wide-ranging White Paper, there was always going to be elements for all parts of the gambling industry to take an interest in – even those sections that exist to raise money for good causes. That can certainly be said for Society Lotteries, for example with the commitments to consulting on the status of large free prize draws and prize competitions and around increasing the age to play Society Lotteries from 16 to 18.

For our part, whilst the implementation of the White Paper – which has over 60 areas of work for the Gambling Commission alone – will likely take a number of years to fully complete, that doesn’t mean we can’t make rapid progress in a number of key areas. But it does mean we – and Government - need to prioritise our work. We also want to make sure that where we are consulting we get it right. Less haste and more speed will be our approach.

There are as you will know already, a number of White Paper objectives, which are intended to be delivered through our Licence Conditions and Codes of Practice – the LCCP - by the Gambling Commission. Where the Commission makes changes to the LCCP we are of course legally obliged to consult on any changes and take any and all consultation responses into consideration before making changes. This will rightly take time.

And we will also want to ensure that as wide a variety of experiences and expertise inform the way that those commitments are turned into practical reality. In my own career in public service both in Government and regulation, I have seen too many examples of well-meaning policy changes having unintended consequences for the public due to the way they were implemented in the real world. So take it from me that we will be doing everything we can to avoid making that mistake during implementation. Less haste, more speed.

It is, however, our intention that the first set of White Paper-related LCCP consultations will be published this summer and pre-consultation engagement with stakeholders will have begun in a number of other policy areas. Whilst I’m not in a position to tell you what those will be yet, we will be publishing more information on this in the near future so do please keep an eye out for more updates.

What else should you be looking out for from the Gambling Commission in the coming months?

For those of you who spend 100% of your time thinking about how you can support the good causes you raise money for, it’s entirely possible you won’t have heard or read our Chief Executive, Andrew Rhodes, talking about three principles that make up what we are calling the Commission Story. Principles that we want to run through our work going forward. Don’t worry, we forgive you! But if you haven’t heard about them already, they are:

  • putting people first
  • doing the right thing
  • regulation that works for all.

Putting people first makes clear that we have clear licencing objectives, and it is important we and you embrace them and keep our attention on those who may be at risk. Those objectives are:

  • preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime
  • ensuring that gambling is conducted in a fair and open way
  • protecting children and other vulnerable people from being harmed or exploited by gambling.

And to be clear, when we talk about people at risk, we don’t just mean those at risk of harm, whether it be financial, physical, mental, or even to friends or family, but those at risk of disadvantage through unfair or illegal practices as well.

And our investment in improving the evidence base, we think is a clear example of our commitment to doing the right thing. Building on the ‘Setting the Evidence Agenda’ Conference we held in March, we will soon be publishing next steps outlining how to fill some of the evidence gaps we see over the next three years. Just last month we also published an update on the development of a new methodology for our Participation and Prevalence statistics that measure how many people gamble – including playing society lotteries - and how many people suffer harms as a result. Last year we held a successful pilot of a new methodology and published the data from that pilot. Since then we have been in the ‘experimental’ phase, and our update last month details the work of refining the methodology and getting it ready for scaling up to official statistics later this year. That is still very much our plan and when it launches fully, it will be surveying around twenty thousand people a year – one of the largest participation and prevalence surveys of its kind.

The pilot of course presented figures regarding levels of gambling related harms different to our current methodology. That’s okay. What matters from the Commission’s perspective is better data will lead to better regulation and better outcomes and that is what the Commission is most interested in.

These projects bring us back to a key focus for the Commission that flows naturally from the three principles I have just mentioned: better data, better research and better evidence will lead to better regulation and better outcomes for consumers, industry and everyone else involved in gambling.

Finally, when we think about regulation that works for all, building on our collaborative approach, we will work with the gambling industry – including society lotteries - to explore how we can roll out account management with more effective and earlier engagement for operators. All the time knowing that where operators still do not make efforts to meet our standards, our compliance and enforcement work will ensure serious repercussions.

And before I finish, I do want to say a bit more about our collaborative approach. Where operators fail to get the message about what we expect from them, in terms of keeping gambling safe, fair and crime free, we will, through our compliance and enforcement work, take action.

But where operators have got the message - and many operators who fit that description are sat in this room today – we are open to engaging with you and collaborating to raise standards and improve outcomes more quickly than we can by acting alone. And that will be especially true for the work ahead to implement the Gambling Act Review White Paper. Whenever we consult, but especially where there are issues that impact you and your consumers, we want your input. We will also be looking to engage with you and the Lotteries Council direct when appropriate. If you play by our rules keep your games fair, crime free and keep your customers safe, we want to work with you to continue to raise standards.

The Gambling Act Review White Paper is a once in a generation change for gambling in this country. It likely sets out the vast majority of the Gambling Commission’s work for the next three years. And it will have an important impact on the Lotteries sector too.

So we want to engage with you on that, we want to work with you on that journey and where we consult we will want your views. Keep your products safe, fair and crime free and we will be only too happy to continue to collaborate with you as you continue raising vital funds for good causes.

Thank you.

Last updated: 18 May 2023

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