Review of the Association of British Bookmakers’ Code for Responsible Gambling

and Player Protection in Licensed Betting Offices in Great Britain, and of M. Griffiths

(2014) Responsible Gambling Initiatives and Preliminary Evaluation of the ABB Code of

Conduct.

December 2014

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Review of the Association of British Bookmakers’ Code for Responsible Gambling and Player Protection in

Licensed Betting Offices in Great Britain, and of M. Griffiths (2014) Responsible Gambling Initiatives and Preliminary

Evaluation of the ABB Code of Conduct.

December 2014

Charles Livingstone PhD

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Livingstone, C. (2014) Review of the Association of British Bookmakers’ Code for Responsible Gambling and Player Protection in Licensed Betting Offices in Great Britain, and of M. Griffiths (2014) Responsible Gambling Initiatives and Preliminary Evaluation of the ABB Code of Conduct. Campaign for Fairer Gambling, London.

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Contents

Contents ............................................................................................................... 4

Introduction ......................................................................................................... 6

Disclosure ............................................................................................................. 6

Acknowledgement ................................................................................................ 7

Methodology and arrangement of this review ....................................................... 8

Summary of review and conclusions ..................................................................... 9 The concept of responsible gambling....................................................................................................... 9 Responsible gambling codes of conduct ................................................................................................. 9 The ABB’s code of conduct ............................................................................................................................ 9

Self-exclusion.......................................................................................................................................................... 9 Age verification ................................................................................................................................................... 10 Advertising and promotions ......................................................................................................................... 10 Research, education and treatment of problem gambling ............................................................. 10 Player protection measures involving ‘mandatory’ reminders and voluntary ‘limits’ ...... 10 Session data on player cards ........................................................................................................................ 10 Money loading ..................................................................................................................................................... 10 Exception reporting .......................................................................................................................................... 11 Cash machines in betting shops................................................................................................................... 11 Customer information...................................................................................................................................... 11 The ABB’s code of conduct – conclusions ................................................................................................ 11

Review of Griffiths M. (2014) Responsible Gambling Initiatives and Preliminary Evaluation of the ABB Code of Conduct ................................................................................................ 11

Conclusions ........................................................................................................................................................... 13

The concept of ‘responsible gambling ................................................................. 14 Responsible gambling codes of conduct .............................................................................................. 16

The ABB’s Code of Conduct ................................................................................. 18 ‘Existing best practice in responsible gambling’............................................................................... 18 ‘Harm minimisation strategies’................................................................................................................ 18

Staff training and awareness ....................................................................................................................... 18 Self exclusion ........................................................................................................................................................ 20 Age verification. .................................................................................................................................................. 21 Advertising and promotions ......................................................................................................................... 21 Research, education and treatment of problem gambling. ............................................................ 21

‘New harm minimisation strategies for machine players’ ............................................................ 22 Player protection................................................................................................................................................ 23 Voluntary money limits ................................................................................................................................... 24 Voluntary time based limits .......................................................................................................................... 25 Mandatory money-based reminders ......................................................................................................... 25 Mandatory time-based reminders.............................................................................................................. 25 Session data on player cards ........................................................................................................................ 26 Money loading ..................................................................................................................................................... 26 Exception reporting .......................................................................................................................................... 27 Cash machines in betting shops................................................................................................................... 27 Customer information...................................................................................................................................... 28

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Conclusions – ABB code of conduct ....................................................................................................... 28 Self-exclusion........................................................................................................................................................ 29 Age verification ................................................................................................................................................... 29 Advertising and promotions ......................................................................................................................... 29 Research, education and treatment of problem gambling ............................................................. 29 Player protection measures involving ‘mandatory’ reminders and voluntary ‘limits’ ...... 30 Session data on player cards ........................................................................................................................ 30 Money loading ..................................................................................................................................................... 30 Exception reporting .......................................................................................................................................... 31 Cash machines in betting shops................................................................................................................... 31 Customer information...................................................................................................................................... 31 Conclusions ........................................................................................................................................................... 31

Part 2: Review of Griffiths, M. (2014) Responsible gambling initiatives and preliminary evaluation of the ABB code of conduct. ............................................ 33 Introduction ..................................................................................................................................................... 33 Literature review ........................................................................................................................................... 33 Discussion of FOBT and betting industry data .................................................................................. 35

Average session length and expenditure ................................................................................................. 35 Average voluntary time and money limits ............................................................................................. 35 Number of voluntary limit setting sessions............................................................................................ 35 Behaviour on reaching voluntary limits ................................................................................................. 35 Mandatory limit information ....................................................................................................................... 36 Behaviour once mandatory limits are reached ................................................................................... 36 Customer interactions ..................................................................................................................................... 36 Self exclusion ........................................................................................................................................................ 36 Age verification compliance.......................................................................................................................... 37 Responsible gambling awareness............................................................................................................... 37 Griffths’s conclusions ........................................................................................................................................ 37

Discussion of the preliminary evaluation. ........................................................................................... 38 Conclusions ...................................................................................................................................................... 40

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Introduction This review was commissioned and funded by the Campaign for Fairer Gambling (www.fairergambling.org). The review is intended to provide a critical appraisal of the Code for Responsible Gambling and Player Protection in Licensed Betting Offices in Great Britain (the code) released by the Association of British Bookmakers (ABB) in September 2013, and of the preliminary evaluation of that code (the preliminary evaluation) commissioned by the ABB and undertaken by M. Griffiths dated July 2014. This review is critical in nature. That does not mean that it sets out to find fault with either the code or the preliminary evaluation. Rather, it seeks to relate the code and the evaluation to available evidence in order to establish ways in which the code might be improved, and of the extent to which the preliminary evaluation assists in understanding the actual impacts of the ABB code (the Code). The code and the preliminary evaluation are both available from the ABB’s website. They are clearly intended to address the concerns of the public and parliamentarians in relation to the operation of category B2 gambling machines, also known as Fixed Odds Betting Terminals (FOBTs), in betting shops throughout Britain. Thus, the principal function of this review is to focus on the extent to which such concerns may have been effectively addressed by the introduction of the code and by the preliminary evaluation.

Disclosure This review was commissioned and funded by the Campaign for Fairer Gambling. The author is also a Chief Investigator on a current Australian Research Council Grant investigating the mechanisms of industry influence of government by the Alcohol, Tobacco and Gambling industries. He has previously received grants from the Victorian Gambling Research Panel and the South Australian Independent Gambling Authority, and an international partner grant from the Ontario Problem Gambling Research Council, organisations which distribute funds derived from the proceeds of gambling. He has also received funding from local government and non-government organisations in relation to (i) the provision of expert evidence in relation to gambling applications and (ii) for specific research projects focused on aspects of gambling policy, the costs of problem gambling, distribution of gambling derived-harm, and the extent to which gambling funds provide community benefits. He was a member of the Australian Government's Ministerial Expert Advisory Group on Gambling (2010-11). He is an editorial board member of the journal Independent Gambling Studies. He is a member of the Public Health Association of Australia and the National Association of Gambling Studies (Australia), and of the Australian

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Greens. He has not received research or other funding or support from and has not entered into any collaborative agreements with any gambling, alcohol or tobacco industry body. The author is a Senior Lecturer in the School of Public health and Preventive Medicine at Monash University. The findings and opinions contained or expressed in this review are those of the author and do not reflect the views of Monash University, the Campaign for Fairer Gambling or any other person or organisation.

Acknowledgement The author is grateful to Mr Matt Zarb-Cousin for his assistance in providing information helpful to the preparation of this review.

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Methodology and arrangement of this review In relation to the code of conduct, this review utilises the order of material and subject matter as it is presented in the code and compares this to the available evidence informing each particular aspect of the code. It should be noted that the code is intended to provide interventions or measures intended to enhance ‘responsible gambling’ and ‘player protection’ in licensed betting shops in Great Britain. Accordingly, a critical review of the concept of responsible gambling is presented in this review. Further, the basis for assessment of the interventions or measures focused on player protection is the extent to which they provide additional protections to users of licensed betting shops, in particular those using FOBTs. The extent to which codes of conduct are utilised in other jurisdictions is presented. An assessment of the likely efficacy of each of the player protection or harm minimisation interventions contained in the code is provided, based on available evidence. A summary of this assessment is provided. The preliminary evaluation is then critically discussed insofar as it addresses the effectiveness of the Code. The evidence provided for the conclusions drawn in the preliminary evaluation is critically discussed. Conclusions are then presented based on critical examination of the interventions provided under the code and the findings of the preliminary evaluation.

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Summary of review and conclusions

The concept of responsible gambling ‘Responsible gambling’ is a widely used but ill-defined concept which most commonly attributes responsibility for gambling problems to those who experience gambling related harms. The individual is seen as the site and producer of harm, and the role of social, economic, financial or other factors in the development and marketing of potentially harmful products is largely ignored. This is particularly so in the context of machine gambling, which utilises a sophisticated and highly developed device with considerable demonstrated capacity to inflict harm on many of those who use it regularly. Responsible gambling practice generally assumes homogeneity of gambling forms. It rarely requires modification of system parameters, such as technical modifications to reduce harmful effects, or the pattern of distribution or marketing of gambling products.

Responsible gambling codes of conduct Responsible gambling is, in many jurisdictions, given effect via the introduction of codes of practice or conduct. Examples of these abound (and a number are referred to in the main body of this review). Overwhelmingly these codes require specific practices to be adopted, with a view to implementing ill-defined responsible gambling practices, implicitly seeking to minimise harm (although harm minimisation is rarely expressed as an explicit goal of such codes). Most measures set out in such codes of conduct (for example, provision of information, ‘responsible gambling’ messages, or limited systems of self exclusion) lack an evidence base demonstrating efficacy. Generally, these codes are examples of industry self-regulation, practices which have been shown to be ineffective in containing harm in other industries marketing harmful or potentially harmful consumer products.

The ABB’s code of conduct

Self-exclusion Despite having been in place for many years in a number of jurisdictions, there is little evidence of the efficacy of self-exclusion. Most schemes have high rates of breach, limited take-up rates, and are generally not universally applied. Existing breach rates in the UK are very high. Self-exclusion can be improved by establishment of shared exclusion systems or by a universal pre-commitment system. However no such interventions are proposed by the ABB code and the likely efficacy of this as a harm minimisation measure remains low.

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Age verification The verification of age is a matter for the Gambling Commission’s code of conduct and regulation. Ensuring that under-age individuals do not gamble is a minimum requirement for proper conduct in the provision of gambling.

Advertising and promotions The ABB code enshrines provisions which have been operating since 2007. These do not represent new practices. There is no additional harm minimisation effect associated with these provisions. These interventions are unlikely to have any harm minimisation effects beyond those already established.

Research, education and treatment of problem gambling The funds invested in treatment by the British gambling industry appear to be very low, and represent around just 0.2% of the GGY from the betting shop sector. Further, engagement with industry directed and funded research programs is likely to be counter productive in the generation of new knowledge to prevent and minimise gambling harm. There is little evidence of the efficacy of providing material to gamblers to educate them about gambling, as noted previously. Thus, this group of proposals is neither novel nor likely to bring about improved harm minimisation effects.

Player protection measures involving ‘mandatory’ reminders and voluntary ‘limits’ These measures resemble a form of pre-commitment, whereby gambling machine users are invited to nominate a limit of time and money for their gambling session, failing which they are subject to prescribed limits. However the system described in this code falls well short of best practice. It does not extend beyond single sessions, requires no pre-determined limit to be set outside the gambling venue or away from the machine, uses ‘soft’ limits that can be readily over-ridden, and the default money limit is very high compared to average earnings. On this basis there is little likelihood of harm minimisation efficacy beyond very modest effects.

Session data on player cards Provision of information about expenditure of time and money on gambling activities has the potential to be valuable for many gamblers. However, provision of information about single sessions is much less valuable than provision of comprehensive information over time. It may also have perverse effects and induce ‘loss chasing’ with some gamblers. Overall this initiative has some potential but is limited in harm minimisation efficacy by its double-voluntary nature and restriction to single gambling sessions.

Money loading This measure in other forms has some demonstrated efficacy. However, the form in which it is presented in the code is at the lower end of likely efficacy. A limit on machine load up or a restriction on the denominations that can be loaded has been shown to have positive effects. However there is no evidence that repetitive

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querying of each incremental addition to credits has any harm minimisation effects. The harm minimisation efficacy of this intervention is likely to be low.

Exception reporting This measure is largely a compliance matter and has limited harm minimisation focus or efficacy.

Cash machines in betting shops This measure has a limited but positive evidence base and is likely to produce modest positive harm minimisation effects. However its effects may be diluted by availability of debit facilities within venues and the extent to which ATMs are accessible nearby. It may also produce perverse consequences involving accessing credit accounts for cash withdrawals on ATMs outside betting venues.

Customer information As noted above, provision of information via signage, pamphlets, signage or screen based material has little if any evidence base, although there is some evidence of quite modest efficacy in relation to screen based messages. The harm minimisation efficacy of these interventions is likely to be low.

The ABB’s code of conduct – conclusions Overall, the measures proposed by the ABB code of conduct are of low to very low potential efficacy. This is consistent with most such codes. The ABB code does adopt some measures, which, if better developed and implemented, might be more effective. The introduction of a limited and voluntary form of pre-commitment has potential to become a useful tool for gamblers to effectively limit their expenditure. However, at present it is far from achieving such an outcome, and requires significant modification before this can be achieved. Removal of ATMs from betting premises is a better implemented policy but is likely to be undermined by availability of cash or credit from other sources. Overall, the harm minimisation effects of the ABB code are likely to be very modest, if detectable at all. The code occupies the lower end of likely harm minimisation efficacy. It is not particularly innovative, adopts no highly effective measures, and is likely to produce only very modest improvements in the protection from harm of those who use FOBTs.

Review of Griffiths M. (2014) Responsible Gambling Initiatives and Preliminary Evaluation of the ABB Code of Conduct Griffiths’s preliminary evaluation adopts the ‘responsible gambling’ lens with apparent enthusiasm. This concept appears to frame the approach adopted

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throughout both the initial review of literature addressing various (but not all aspects) of the ABB’s code of conduct, and the subsequent evaluation of specific measures. Overall, both sections of Griffiths’s paper present a highly positive assessment of the ABB’s code, in both theoretical and practical terms. Griffiths advised the ABB in its development of this code. This is not seen as an impediment to undertaking an evaluation of this nature, although that is arguably not best practice for such undertakings. Griffiths’s participation in the development of the code arguably represents a conflict of interest in the conduct of such an evaluation. This conflict may well prejudice, or provide the appearance of prejudice, to Griffiths’s capacity to undertake the evaluation independently. In the present author’s opinion, the preliminary evaluation is very limited in its capacity to provide a clear, transparent and unambiguous assessment of the harm minimising effects of the measures adopted by the ABB’s code of conduct. There are a number of reasons for this.

1. The review of literature which forms the first part of the preliminary evaluation is limited and in this author’s opinion provides a post hoc justification for the measures adopted by the ABB in the code. However, the review concludes, for the most part, that there is limited evidence to support most interventions – and it doesn’t deal with some important measures, such as the removal of ATMs. Financial data could have been utilised to evaluate efficacy of ATM removal or money loading limits, but such data were not presented.

2. The presentation of data used to discuss aspects of the effects of the limit

setting features is disappointing. It is difficult, in my opinion, to determine the reliability of Griffiths’s conclusions and reasoning in the absence of more detailed data. Data could reasonably be presented via tables or an appendix. Further, almost no statistical analysis is provided beyond estimates of ‘typical’ patterns of expenditure, etc. This severely limits the utility of the limited data presented, and thus hinders clear comprehension of the actual effects of the code’s measures.

3. Griffiths’s review appears, in my opinion, to be almost unfailingly positive,

in some cases in contrast to the material presented. This may be attributable to Griffiths’s enthusiasm for measures on which he appears to have advised the ABB. In any event, a more critical review may have offered more scope for constructive suggestions about how the code could be fundamentally improved.

4. The preliminary evaluation fails to identify let alone address the harm

minimisation effects of these interventions. ‘Responsible gambling’ is presented as a catch-all rubric within which harm minimisation is fully contained. This, however, is a clear misunderstanding of basic public health and harm minimisation principles.

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5. There are two interventions which, on Griffiths’s own reasoning, are

likely to have major population wide impacts on gambling harm. These are a reduction of the maximum bet limit, and the introduction of a universal pre-commitment system. Both of these were recommended by the Australian Productivity Commission (2010). The evidence for these interventions is arguably superior to that for most if not all of the interventions actually contained in the ABB’s code of conduct. However, these are not canvassed as possible additions for the improvement of the code, although the logic of their potential utility is arguably very strong. This may arise from industry opposition to measures likely to have impacts on revenue. Whatever the cause, given the nature of the preliminary evaluation, their omission is surprising,

Conclusions The preliminary evaluation is, in my opinion, considerably flawed by the issues noted above. The preliminary evaluation in my view represents an apparent attempt to demonstrate adherence to responsible gambling practices that lack an evidence base and are generally favoured by industry for the purpose of achieving public, or perhaps more importantly, political support for continued self-regulation. Such systems of self-regulation are not likely to achieve significant reductions in harm, and in any event are largely if not entirely unsupported by evidence. Until independent research assesses the value of these reforms, and others like them, the evidence base will remain of poor quality, and we can expect gambling harms to continue, largely unabated. As has been evident with many harmful products, effective reform in pursuit of harm minimisation requires the activity of a chain of independent actors at multiple levels – not the least of whom are researchers.

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The concept of ‘responsible gambling The ABB code draws uncritically on the concept of ‘responsible gambling’ as the underpinning of its approach to harm minimisation and player protection. ‘Responsible gambling’, is a widely used concept, generally referring to sets of harm minimisation practices utilised in gambling venues and businesses. Its origins lie in gambling businesses’ reaction to public concern about the impacts of gambling, as Blaszczynski et al (2011) report. This concept could be construed as requiring the responsible provision of gambling services, as well as the responsible consumption of gambling by individuals. However, as Blaszczynski et al (2011) argue, ‘there is considerable conceptual confusion surrounding the term “responsible gambling”’, and its definition and programmatic detail varies between jurisdictions, and between government and industry sectors. Responsible gambling, as it is generally deployed, arguably locates the locus of gambling harm at the level of the individual. Such a way of thinking reflects a ‘discourse of business as usual’, whereby the conduct of gambling businesses is not unduly disrupted by the fact of gambling related harm accruing to those who utilise gambling products. This way of conceiving of gambling problems, as largely residing within the individual, ignores evidence of the effectiveness of the gambling industry in, for example, promoting and marketing a systematically developed, high impact and potentially very unsafe product (the electronic gambling machine) (Schüll 2012). Taking the product as a largely unalterable given, responsible gambling discourses argue that problems associated with the use of this product can best be addressed by focusing on the user, rather than on the product itself. Thus,

[a] key discursive term, acknowledging yet containing the disruptive effects of harm, is ‘responsible gambling’, referring to the establishment of a ‘responsible’ practice of gambling by individuals (i.e. knowing when to stop). ‘Responsible gambling’ is a carefully structured, if elastic and goalless term, discursively transferring responsibility for industrialized (and normalized) harm production to end users. It would, perhaps, be helpful for harm minimization purposes were it to denote pursuit of the absence of harm by all means. Yet the actually existing category of ‘responsible gambling’ invariably ignores the EGM system’s harm producing capacity. (Livingstone & Woolley 2006).

For example, the (Australian) Gambling Measures Act 2012 has the object of developing and implementing ‘measures to encourage responsible gambling by all gamblers’ (s.4) rather than requiring a broader perspective including the responsible provision of gambling services. The Queensland Office of Gambling Regulation definition is that ‘[r]esponsible gambling occurs in a regulated environment where the potential for harm associated with gambling is

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minimised and people make informed decisions about their participation in gambling’ (http://www.olgr.qld.gov.au/gaming/minimising-harm 2014). This is not a universal view, although it is arguably dominant, particularly amongst industry codes. An alternative approach, however, is presented by the Victorian Responsible Gambling Foundation (VRGF 2014 http://www.responsiblegambling.vic.gov.au/sites/default/files/rgg.pdf), which defines responsible gambling in two ways: firstly as that accruing to individuals:

… they may gamble for pleasure and entertainment but are aware of their likelihood of losing, and understand the associated risks; they exercise control over their gambling activity; responsible gambling occurs in balance with other activities in their lives and is not causing problems or harm for themselves or others.

For the broader community, including gambling providers, governments, and sporting associations, responsible gambling requires:

… shared responsibility for generating awareness of the risks associated with gambling; creating and promoting environments that prevent or minimise problem gambling; and being responsive to community concerns around gambling.

Even more unusually, the legislated definition of responsible gambling adopted in New Zealand places emphasis on the responsibility of gambling operators, rather than individuals:

“Responsible Gambling” means lawful participation in gambling that is – (a) Lawful, fair and honest; and (b) Conducted –

i. In a safe and secure environment; and ii. Without pressure or devices designed to encourage gambling at levels that may cause harm; and iii. By informed participants who understand the nature of the activity and do not participate in ways that may cause harm.

Responsible gambling is largely about gamblers’ rights, and the obligations of gambling operators. Under the Act, responsible gambling is not primarily about individual gamblers taking responsibility for their own actions. (NZ DIA 2014 http://www.dia.govt.nz/pubforms.nsf/URL/GamingOperationalPolicy.pdf/$file/GamingOperationalPolicy.pdf )

However, industry definitions tend to be closely focused on ideas around individual responsibility. For example, Tabcorp, a major Australian gambling provider, adopted this definition in 2006:

… ‘responsible gambling’ strategy is centred around the provision of information, including information about ‘how to source counselling services’ (Tabcorp, 2006)

The American Gaming Association’s responsible code of gaming conduct is similarly focused on education and pledges that ‘AGA members will make

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information available promoting responsible gaming and where to find assistance’ without providing any definition of what constitutes ‘responsible gaming’ (http://www.americangaming.org/sites/default/files/aga_responsible_gaming_code_of_conduct.pdf ). The Alberta Gaming and Lottery Corporation does acknowledge the need for ‘both sides of the coin’ to act in promoting ‘responsible gaming’. However, in strategic documents outlining the approach they have adopted to implement this, the emphasis remains on providing resources and information to individuals who should then undertake gambling in a responsible way (https://aglc.ca/pdf/being_responsible/BothSidesoftheCoinSummary.pdf ). The ABB’s code of conduct is intended ‘to create a step change in responsible gambling thinking based around informed choice by adult customers. This is the first code of its kind to be published in the world’ (ABB 2013). However, it provides no definition of its concept of ‘responsible gambling’, and the assertion that this is the first such code ‘in the world’ is overblown.

Responsible gambling codes of conduct Regardless of definition, it is very common for ‘responsible gambling’ to be commonly operationalised via the adoption of particular practices, generally enshrined in such ‘codes of practice’, which instruct staff and venue operators about monitoring the behaviour of gamblers, providing them with information, and implementing certain environmental provisions (for example, around the location of Automatic Teller machines). Such codes of practice are frequently non-specific and open to significant levels of local interpretation. Further, there is in fact no evidence that industries that produce or market dangerous products are effective in harm minimisation via self regulation As Moodie et al (2013) argue:

Despite the common reliance on industry self-regulation and public—private partnerships, there is no evidence of their effectiveness or safety. Public regulation and market intervention are the only evidence-based mechanisms to prevent harm caused by the unhealthy commodity industries (Moodie et al 2013)

In addition to codes referred to above, other examples of codes of practice have been developed by both government agencies and private operators (http://www.olgr.qld.gov.au/__data/assets/pdf_file/0019/251506/responsibleGamblingCodeOfPractice.pdf 2014; http://assets.justice.vic.gov.au/vcglr/resources/198fb5bc-7192-4e8d-9ae4-6d670321918f/ministerial_direction_respgamblingcodeconduct.pdf 2014; http://www.partofthesolution.com.au/docs/publicdocs/click-here020841C19E40D9413EF9727856516FD9F9367B7426C46D9D.pdf?sfvrsn=2 2014; http://www.alhgroup.com.au/documents/EGM-Gaming-Venue-RG-Code-of-Conduct-APPROVED-ver-1.1%20.pdf 2014).

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Researchers have identified a lack of evidence supporting actually existing harm minimisation practices within Australian (and other) gambling venues. For example, Blaszczynski (2001) commented that ‘there is a significant absence of credible research data on the effectiveness of specific interventions’ and ‘virtually no evidence to confirm their effectiveness’. The Australian Productivity Commission (1999) identified significant evidence gaps around these practices, as did Hing (2004). A recent review of actually existing harm minimisation measures generally concurred with these conclusions (Livingstone et al 2014). Williams et al (2012) and Williams (2013) take a slightly different view, arguing that, in the aggregate, a range of harm minimisation measures have demonstrated some efficacy in reducing gambling related harm. Livingstone et al (2014) also concur in this view, but note that the most profound effects associated with harm minimisation tend to be more structural in nature, rather than interventions implemented as a consequence of responsible gambling codes of conduct. The next section of this review considers the actual implementations proposed by the ABB’s code of conduct in the light of these considerations, and having regard to available evidence.

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The ABB’s Code of Conduct The ABB code is reasonably typical of such codes, with its harm minimisation elements categorised thus:

• Issuing clearer and more accessible information on how to gamble responsibly and highlighting the sources of help available; • Providing customers with new tools such as mandatory time and money based reminders, the ability to set spend and time limits on gaming machines and to request machine session data; • Training staff to detect the signs of potential problem gambling more quickly and how to interact more effectively with those identified; and • Undertaking more consistent central analysis of data to identify abnormal activity both in specific shops and, where possible, that relating to individual customers. (ABB 2013).

This review will address each of the specific elements of the ABB’s code in the order they appear in that code.

‘Existing best practice in responsible gambling’ This section of the ABB code relates to the physical security of betting shops, better policing and co-operation with police and others to prevent crime within those premises, to anti-money laundering and terrorist financing activity, and to the integrity of sports betting. Although the avoidance of crime in betting shops, the minimisation of money laundering and terrorist financing activity, and betting integrity are important issues, they are neither consumer protection nor harm minimisation measures in the context of reducing the harms associated with gambling, in particular excess expenditure of time or money by those using high impact gambling machines. It is therefore difficult to conceive of these issues as demonstrating ‘existing best practice in responsible gambling’, even as responsible gambling is generally defined. At best, these measures demonstrate conformity with minimum acceptable community and legal standards. These elements of the ABB code are not relevant to this review of the code and, accordingly, will not be addressed.

‘Harm minimisation strategies’

Staff training and awareness The ABB code appears to put much emphasis on the role of their staff in assisting individuals to make ‘informed choices regarding their gambling’ and to interact

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in order to ‘protect customers’. In addition to accreditation and training procedures, the code also requires that:

• All shop staff will be trained, in consultation with providers of responsible gambling expertise, to recognise a wider range of problem gambling indicators and will aim to identify those customers at risk of developing a gambling problem. • All shop staff will be actively encouraged to ‘walk the shop floor’ as part and parcel of an enhanced customer engagement role, including initiating customer interaction in response to specific customer behaviour which needs to be addressed.

The code also specifies the information that will be incorporated into the industry standard for staff training. The core of this aspect of the code is the idea that interaction between staff and shop users will provide a vehicle to intervene at the point that a user begins to demonstrate particular behaviours and/or traits, thought to be consistent with those exhibited by a ‘problem’ or ‘at-risk gambler. However, the evidence base for such interventions is, at best, very modest. There is in fact little evidence for the harm minimisation effects of such interventions, even assuming that it is possible to identify gamblers as gambling harmfully. There appears to be little consensus amongst experts in this field as to the practicality of intervening, given that there is some reluctance on the part of staff to intervene in such circumstances (see Thomas et al 2014, Delfabbro et al 2012). In one case a modest study demonstrated some efficacy in relation to the positive effects of a counselling session for those identified as problem gamblers (Cantinotti & Ladouceur ND). However, the intervention adopted in that study is not proposed under the ABB’s code. There are a number of sources focused on the development, scope and uptake of staff training in responsible gambling awareness, or the extent to which identifiers of problem gambling might be effectively developed and utilised, but these have not assessed the efficacy of this intervention as it affects the behaviour of gamblers, or the extent of its harm minimising effects (see Ladouceur et al 2004, Hing & Nuske (2011), Responsible Gambling Council 2011, Allcock et al 2002, Giroux et al 2008, Osborne Group 2007, Delfabbro et al 2012, Delfabbro et al 2012a). It is of course possible that this intervention may be effective in reducing the harmful effects of gambling, particularly FOBT or other EGM gambling. However there is no reasonable evidence that interventions of this nature are an effective harm minimisation intervention. In any case these measures do not address the prevention of gambling problems and are only able to be deployed after a problem has visibly developed. It should also be noted that provisions regarding this set of practices is also set out in the UK Gambling Commission’s Gambling Codes of Practice (GC 2014). Such provisions are not innovative or world leading; they are commonplace and generally perceived as relatively ineffective.

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Self exclusion Self exclusion, whereby those who believe themselves to be experiencing harm from gambling are assisted to ‘ban’ themselves from gambling premises, is an established practice in a number of countries, including Australia, New Zealand, Canada, the United States, and many European jurisdictions. The ABB code asserts that

[t]he most effective system of self-exclusion is a localised one where the self-excluded person excludes from shops where the customer has been a regular attendee and is known to staff. When a customer requests self-exclusion, it should be facilitated with immediate effect for that particular shop … (ABB 2013)

The code also undertakes that ABB members will facilitate self-exclusion from other gambling channels operated by the member, will keep good records, and enforce self-exclusion arrangements effectively. However, despite being a feature of many responsible gambling practices for as much as 25 years, there is only modest evidence that self exclusion systems offer some benefits to individuals, rather than providing population wide minimisation effects (see Ariyabuddhiphongs 2013; Gainsbury 2010, 2014; Williams et al. 2007; Williams et al. 2012, Hing & Nuske 2011). There is also a paucity of evidence supporting the longer term effects of self exclusion even at the individual level with only a handful of studies examining such effects (Ladouceur et al. 2000, Ladouceur et al. 2007, and reviews by Gainsbury 2010, 2014, and Williams et al. 2012). Self exclusion tends to be troubled by low take up rates (Williams et al 2012, O’Neill et al 2003) and have high rates of breaching, where self excluded individuals enter and gamble on premises from which they have excluded themselves. Such breaching rates are as high as 80% (see Ladouceur et al. 2007; Williams et al. 2012; Gainsbury 2014, Croucher & Croucher 2005 Cohen et al 2011, O’Neill et al 2003). High breach rates are associated with lack of positive identification systems in countries such as the USA, Canada, Australia and the UK where it is not common to require identification when seeking access to gambling premises (Verlik 2008). In 2013-14 in the UK, for example, out of 24,471 people who had self-excluded, there were 19,589 breaches detected, a rate of over 80% (GC 2014a). The actual breach rate is likely to be considerably higher. Breaches are thought to be lower in European jurisdictions where access to casinos is subject to production of identification (Williams et al 2012, Gainsbury 2014). Electronic self-exclusion which allows gamblers to set a zero-pound limit within a linked, universal pre-commitment systems may be a way to overcome identification issues and breaches of individual gamblers, and may prevent the gambler from using machines. Self exclusion may be a partially effective intervention for those with established

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gambling problems seeking to exercise more effective control. However, where there are a plethora of gambling opportunities, or where positive identification is not required, self exclusion is frequently breached or readily circumvented. More importantly, this intervention is, in public health terms, ‘downstream’ – it is most effective where gambling harm is already established, and even then has at best a very modest evidence base. It should also be noted that provisions regarding this set of practices is also set out in the Gambling Commission’s Gambling Codes of Practice (GC 2014).

Age verification. Verification of the age of patrons is a matter of meeting community and legal standards and although meeting these standards is laudable, such compliance does not constitute an innovative, far-reaching or significant harm minimisation intervention. Were minimum age requirements not met this would constitute a breach of licensing requirements with appropriate sanctions coming into effect. It should also be noted that provisions regarding this set of practices is also set out in the Gambling Commission’s Gambling Codes of Practice (GC 2014).

Advertising and promotions The ABB code adopts existing practices which have been in effect since 2007. New measures adopted under the code require ‘pro-active’ promotion of responsible gambling messages and provision of information about the national gambling helpline, and an undertaking to hold ABB members ‘to account’ for ‘in spirit’ breaches of regulation in this area. How this will be achieved is unclear. In relation to signage in gambling venues, there is very little evidence of effectiveness. Studies assessing signage have not demonstrated effectiveness in reducing harm, having instead assessed gambler awareness and recall of messages (Reid 2005, Hing 2004). There is however evidence that signs in venues compete poorly against promotional material also displayed in gambling premises (Reid 2005). There is also evidence that signage is not seen as an effective harm minimisation measure by gambling venue users themselves (Hing 2004). Providing information about gambling help lines may provide assistance to those who are otherwise unaware of the availability of assistance, or who are unaware of contact details. However there is no evidence of the harm minimisation efficacy of responsible gambling signage in gambling venues.

Research, education and treatment of problem gambling. The ABB code provides for continuing support by ABB members for the RGT and

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for harm minimisation expenditure, noting that the British gambling industry contributes ‘nearly £6 million per annum to minimise gambling-related harm’. As a proportion of gross gambling yield, this represents less than 0.4% of revenue generated by machines in betting premises alone, which was £1,567.3 million in 2013-14 (GC 2014a), or about 0.2% of GGY including off course betting and gambling machines (£3,048 million). It is by no means a significant proportion of gambling revenue. The code also undertakes to provide information about gambling support and counselling services and to promote responsible gambling campaigns. In this context comments in the preceding section of this review are relevant. Support is also pledged for the funding of a British prevalence survey. Prevalence surveys may be a good source of some useful data, but are expensive and often fail to provide sufficiently robust and localised data to support useful policy development, especially in relation to harm minimisation (see Young 2013 ART 21(1)). Support for industry funded and/or determined research agendas is also of increasingly questionable value, and may be detrimental to the development of effective harm minimisation measures. In this context recent work by Cassidy is of great relevance (Cassidy et al 2014; Cassidy 2014). Commitments under this section of the ABB’s code are thus unlikely to generate useful harm minimisation initiatives, and may be detrimental to the development of effective approaches to the minimisation of harm. Further, financial support for harm minimisation by the gambling industry appears to be very modest, having regard to the scale of the industry.

‘New harm minimisation strategies for machine players’ This section of the ABB code concedes that there is public concern about the harmful impacts of FOBTs and asserts that this concern has motivated the ABB ‘to create a step change in our responsible gambling thinking’. Accordingly, this section sets out a series of consumer protection measures, which the code describes as improving public confidence in the betting industry and seeking to ‘make a difference to those machine players at risk of developing a problem with their gambling’. There is thus a continuation of the concept that individuals are the problem, rather than the machines themselves, suggesting that a range of interventions (e.g., reduction of maximum stakes, modification of other machine characteristics, etc) are not seen as viable by the ABB. The code also commits the industry to replacing these measures should they be shown to have only marginal effectiveness, and to assess new technological solutions for their harm minimisation effectiveness.

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Player protection Voluntary money limits Voluntary time limits Mandatory money-based reminders Mandatory time-based reminders This aspect of the code provides for the use of a form of technologically supported pre-commitment. Pre-commitment systems are mechanisms whereby gamblers can set a limit to their gambling before becoming immersed in a gambling session. Pre-commitment systems of various types have been utilised in a number of jurisdictions, including Sweden (Centre for the Advancement of Best Practices 2009; Svenska Spel 2013); Norway (Hoffmann 2012); and Nova Scotia, Canada (Bernhard et al. 2006; Schellinck and Schrans 2007, 2010; Omnifacts Bristol research 2007). In Australia, some loyalty card programs are required to incorporate a form of pre-commitment. Williams (2010) posits that the effectiveness of pre-commitment systems relies on:

• whether the system is universal; pre-commitment must be used by all gamblers on all machines across a wide geographic area; • whether limit setting is required; and • the extent to which limits are binding and revocable (Williams 2010). Blaszczynski et al (2008) argue that gamblers often lose track of how much they have spent gambling. Thus, some form of pre-commitment that keeps track of this may be helpful in providing a ‘reality check’ for gamblers. In accordance with Williams’s (2010) criteria, a highly effective pre-commitment system would involve imposition by the gambler of a limit which cannot be over-ridden during a gambling session, and which binds the user across all similar gambling forms. For example, a system using a card or similar device to access a gambler’s pre-set limits across all gambling machine venues within a jurisdiction would be very effective in assisting gamblers to make predetermined decisions about how much they wish to spend. If access to gambling machines (for example) is not possible without such a card, the capacity to effectively self-exclude would also be considerably enhanced. Voluntary systems, on the other hand, may be much less effective in providing an effective capacity for pre-commitment. In Nova Scotia, less than 1% of gamblers utilised a voluntary pre-commitment system (Polatschek et al. 2013) and in a trial in an Australian state, uptake was low partly because gamblers did not see the system as relevant to them (Delfabbro 2012). Further, voluntary systems may stigmatise gamblers, if they are perceived as being useful only for those with gambling problems. In contrast, universal systems requiring limit setting or imposing a statutory limit may normalise pre-commitment and allow it to be seen as providing a useful tool for all gamblers (Delfabbro 2012. Schellinck and Schrans 2010). In a number of Australian states (as noted above) pre-commitment systems are a

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required feature of loyalty card programs. All such systems in Australia are voluntary and non-binding – that is, when a limit is reached users are able to continue their session, often after receiving a message advising them that the limit has been reached (see Delfabbro 2012, Nisbet 2005, Office of regulatory Policy 2009, Schottler Consulting 2008, 2009, 2010, 2010a, 2010b). Further, evaluations of such systems demonstrate very low take-up rates of between 0.7% - 2.3% of gamblers. The Australian Productivity Commission recommended adoption of a pre-commitment system with a number of features that would make it difficult for gambling machine users to over-ride or avoid setting limits, although it did not recommend adoption of a mandatory maximum limit (PC 2010). However, fierce resistance from the gambling industry, headed by the Australian clubs industry (operators of large scale gambling machine venues in many Australian states) successfully resisted legislation to give effect to this recommendation (Panichi 2012). In Norway however, a universal pre-commitment system operates with mandated limits of about £80 per day or £380 per month for those using multix terminals (which incorporate gambling machine games and other gambling forms) Analysis of data from this system has found that about 15% of gamblers reach this limit monthly. It is clear that the effectiveness of pre-commitment systems will depend on the extent to which Williams’s criteria are observed. Assessing the player protection measures adopted under the ABB code is a useful exercise, as it provides some measure against which the likely efficacy of the measures might be predicted.

Voluntary money limits Under this aspect of the code gamblers are invited to set a money limit of their choosing. This appears to be unlimited and to over-ride the mandatory limit (£250). Thus, a limit of (say) £400 would permit the user to gamble on the machine until they had spent that amount. Once the limit is reached, the gambler can continue to gamble after waiting for 30 seconds, and can set a new limit. The system operates only for the session on a single machine, and there is no requirement for the gambler to identify themselves for personal record keeping or other purposes, nor to set an irrevocable limit when not engaged in a gambling session. It is arguable in fact that this is not so much a limit as a reminder; and one which can be very easily over-ridden. Thus, William’s criteria are not observed – there is no requirement to set a limit; the system is not widespread; and is not binding, beyond a requirement to wait for a very short period of time before recommencing gambling machine use. The efficacy of this system is likely to be low. In well-developed pre-commitment systems increasing a limit would be possible only at predetermined intervals, and not in the course of a gambling session. This reflects a recognition that gamblers may not make a decision to increase their limit when they are not in the ‘heat of the moment’ and certainly when they are not in a gambling venue

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surrounded by visual and auditory cues to spend.

Voluntary time based limits Under this aspect of the code gamblers are invited to set a time limit (or reminder) of their choosing. This appears to be unlimited and to over-ride the mandatory limit (30 minutes). As with the money limit, after the passage of 30 seconds involving a reminder and responsible gambling message, use of the machine can resume and a new limit set. As with the money limit, William’s criteria are not observed – there is no requirement to set a limit; the system is not widespread; and is not binding, beyond a requirement to wait for a relatively short period of time before recommencing gambling machine use. The efficacy of this system is likely to be low.

Mandatory money-based reminders Where gamblers opt not to set their own limits, or reminders, a reminder is provided to the gambler after they have spent £250 during their session. A ‘break in play’ of 30 seconds is required before gambling can recommence. This is also regarded as a trigger to initiate staff-user contact, although unlike a ‘hard limit’ (i.e., where the gambler is unable to continue gambling until their daily or monthly limit is reset following the passage of sufficient time) this does not require that gambling cease. In this measure, two of the three criteria set out above are not met. Although a limit is required (in this case a mandated limit, in the form of a reminder) there is not widespread application of this limit and it is not binding. After a brief period of time gambling can recommence, either on the same machine or by moving from machine to machine, or, in some cases, between venues. Thus, the efficacy of this measure is likely to be at best moderate and most likely low.

Mandatory time-based reminders As with money-based reminders, if a personal limit is not set the system requires gamblers to wait 30 seconds after they have spent 30 minutes on a machine. However, the session can then recommence, although reaching the limit is also regarded as a trigger to initiate staff-user contact. However there is no requirement that gambling cease once the limit has been reached. Again, two the above criteria are not met, suggesting that the efficacy of this measure is likely to be at best moderate and most likely low. Overall, this system of ‘player protection’ may represent a very modest advance on gambling machine operation with no restraint. However, these measures constitute a substantially voluntary systems with ‘soft’ limits, no universal applicability, no requirement for cessation of play beyond a brief break, and with

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comparatively high money limits or reminder levels - £250 is 53.1% of Britain’s average weekly earnings, including bonuses, as at May 2014 (ONS 2014). http://www.ons.gov.uk/ons/rel/lms/labour-market-statistics/may-2014/info-awe-may-2014.html The overall efficacy of this system could be predicted to be low and to demonstrate only modest harm minimisation effects. In particular, those likely to take advantage of it would tend to be those who already exercise effective pre-commitment without technological assistance, although for some people in this category the limits may provide a useful reminder. Until the system is properly and carefully evaluated using machine level data (preferably tied to individual gambler behaviour) it will be difficult to determine actual efficacy from a harm minimisation perspective.

Session data on player cards This measure provide a capacity for users with loyalty cards to be provided with a summary of time and money spent during specific session of gambling machine use. It is voluntary for users to have or to utilise such cards and to seek such data. Although provision of such evidence is potentially useful, it would be more useful still if data over longer periods of time were accessible. Such information is reportedly popular with gamblers – in a Canadian study 88% of participants indicated support for such an option (Centre for Advancement of Best Practice 2009). Some unintended consequences of such a system however include the possibility that some gamblers would be encouraged to ‘chase losses’ by provision of such information (Bernhard et al 2006, Schellinck & Schrans 2007). This problem could be avoided in a system in which binding universal pre-commitment was required, as users would be locked out of the system upon reaching that limit. In the absence of such a system, it is possible that this information may be more harmful for some gamblers. The provision of this information should come with support. One study quoted a gambler who reported that “you would want to kill yourself [if you knew what you spent]” (Nisbet, 2005) While this measure may provide useful information for some users to reflect on the amount of money they have lost and therefore provide some harm minimising effects, these may be offset by the lack of a system of binding limits which could provide gamblers with an effective tool to respond to information about excessive consumption of gambling. At present evidence around the efficacy of such measures is at best modest, and appears to be contradictory.

Money loading Restraint on capacity to ‘load up’ credits on machines or via debit systems is generally regarded as providing some harm minimisation effects. In Queensland, a reduction in the amount that could be loaded up on to gambling machines, and restriction of the denomination of notes accepted by machines, was associated with a significant decline in gambling machine revenues. An evaluation of this measure indicated that it appeared to have been effective in reducing the amount gambled by those in the problem gambler category. However, the limit in

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Queensland was set at $AU100 (£54) with maximum denomination being $20 (£11)(Brodie et al 2007). Given that FOBTs permit maximum bets of £100, asking the user to repeatedly verify that they wish to commit at each £20 credit increment when loading up the machine (with no hard limit) is less likely to be successful than a hard load-up limit, and perhaps a reduction in maximum bet sizes (another key measure recommended by the Australian Productivity Commission). The harm minimisation efficacy of this intervention is likely to be at best modest. There is in any event no evidence available at present on the harm minimisation efficacy of this intervention.

Exception reporting Exception reporting is generally a regulatory compliance matter with little application to harm minimisation. However, if exceptional patterns of play are noted and acted upon via effective actions this may assist some gamblers. However it is unclear what interventions are proposed via the code and it appears to be focused primarily on compliance.

Cash machines in betting shops Removal of Automatic Teller Machines from gambling premises has been evaluated as a reasonably effective harm minimisation measure in Victoria. Although ATMs were not previously permitted in gambling rooms, they were permitted within other parts of gambling venues. In mid 2012 these were removed pursuant to regulation. An evaluation of this intervention (Thomas et al 2013) found that removal of ATMs had been effective with individuals in the problem gambler category, and had been associated with a decline in overall gambling machine expenditure of 9.3% in real terms (as calculated by Livingstone et al 2014), although the ATM removal also coincided with significant changes to the ownership structure of the gambling machine industry in Victoria, and reductions in the gambling machine tax, to the significant benefit of gambling machine operators. As provided for in the ABB code, gambling venue patrons in Victoria are able to obtain cash using EFTPOS systems, which involves some interaction with a staff member. This may reduce the potential effectiveness of the intervention to some degree. A further factor is the availability of ATMs in nearby locations. In most high income countries ‘High Street’ locations are well provided with ATMs so alternative sources of cash are generally ubiquitous, and may involve the perverse consequence of providing more ready access to credit cards as sources of cash for gambling. The likely harm minimisation effects of this intervention are modest, although likely to be positive.

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Customer information Provision of information in whatever form is potentially useful and may assist gamblers to better understand gambling forms and assist in identifying sources of assistance. However, as noted above in relation to signage and information, there is little evidence of the effectiveness of this (in whatever form) as a harm minimisation measure. There is some evidence around the efficacy of on-screen messages. Some studies (Gallagher et al. 2004; Stewart and Wohl 2013; Jardin and Wolfert 2009; and a review by Monaghan 2010) suggest that warnings are likely to reduce time spent gambling and/or expenditure. A very modest (4.2%) self-reported intention to change actual gambling behaviour was associated with exposure to such messages, when trialled in a venue setting. This study did not collect user data to verify any such changes in gambler behaviour (Blaszczynski et al. 2014). However, there were a number of limitations to most such studies. Almost all assessments of the actual effectiveness of messages were laboratory based, and a number used university or college students (Steenbergh et al. 2004; Monaghan and Blaszczynski 2010; Floyd et al. 2006; Stewart and Wohl 2013; Jardin and Wulfert 2009). Overall, there is no solid evidence of the efficacy of such messages as harm minimisation measures.

Conclusions – ABB code of conduct Codes of conduct in relation to the provision of ‘responsible gambling’ have become common in many jurisdictions in recent years, and some aspects of the ABB code are in fact dealt with by the Gambling Commission’s Codes of Practice (GC 2014). Resting as it does on the ill-defined and often fluid concept of ‘responsible gambling’ the ABB code retains the binary division between ‘problem’ and ‘non-problem’ gamblers, identifying the former as the locus of harm and the latter as unproblematic self-regulating consumers. The problem with this construction is that it overlooks the fundamental principles of a public health approach to reducing harm and protecting public health. It is difficult, inefficient and costly - if not futile - to try to predict who will become a problem gambler. Therefore population wide measures that universally apply to all gamblers, in all shops, on all machines and all sessions are those most likely to have the greatest benefit in protecting the public. Particular measures contained within the code appear to have varying degrees of likely efficacy in relation to the minimisation of harm. Preventing crime in betting shops, co-operating with authorities in anti-money laundering activities, the prevention of terrorist funding, and maintaining the integrity of betting on sport are important but they are not harm minimisation activities intended to reduce the harm accruing to gamblers, their families, or the wider society. These activities do not represent ‘best practice in responsible gambling’, as ill-defined as that concept may be in this Code.

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Staff training and awareness measures are popular in gambling codes of practice, but there is no consensus amongst experts as to how these might be implemented, whether they are likely to achieve harm minimisation efficacy, and no actual evidence of such efficacy. This is particularly so, given that these measures rely upon self-regulation, for which there is no evidence for safety or efficacy in the context of unhealthy commodity industries (Moodie et al, 2013), such as gambling.

Self-exclusion Despite having been in place for many years in a number of jurisdictions, there is little evidence of the efficacy of self-exclusion. Most schemes, particularly in Anglophone countries, have high rates of breach, limited take-up rates, and are generally not universally applied. A gambler excluded from one betting shop under the ABB system can simply walk into another nearby. Existing breach rates in the UK are very high. Self-exclusion can be improved by establishment of shared exclusion systems using a common database, subject to requirement for provision of identification, or more efficiently and effectively by introduction of a universal pre-commitment system. However no such interventions are proposed by the ABB code and the likely efficacy of this as a harm minimisation measure remains low.

Age verification The verification of age is a matter for the Gambling Commission’s code of conduct and regulation. Although it is important to observe the law effectively ensuring that under-age individuals do not gamble is a minimum requirement for proper conduct in the provision of gambling. It is therefore not an innovative or significant additional harm minimisation measure.

Advertising and promotions The ABB code enshrines provisions which have been operating since 2007. These do not represent new practices. There is no additional harm minimisation effect associated with these provisions. In relation to the provision of responsible gambling information, available evidence has not so far demonstrated the efficacy of this measure. These interventions are unlikely to have any harm minimisation effects beyond those already established.

Research, education and treatment of problem gambling The funds invested in treatment by the British gambling industry appear to be very low, and represent around just 0.2% of the GGY from the betting shop sector. Further, engagement with the industry directed and funded research program is a matter of growing concern for many researchers, and likely to be counter productive in the generation of new knowledge to prevent and minimise gambling harm. There is little evidence of the efficacy of providing material to

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gamblers to educate them about gambling, as noted previously. Thus, this group of proposals is neither novel nor likely to bring about improved harm minimisation effects.

Player protection measures involving ‘mandatory’ reminders and voluntary ‘limits’ These measures resemble a form of pre-commitment, whereby gambling machine users are invited to nominate a limit of time and money for their gambling session, failing which they are subject to prescribed limits. However the system described in this code falls well short of best practice. Pre-commitment is most effective when limit setting is required, when the system operates across a jurisdiction, and when the limits are binding and cannot be readily revoked. Even in the context of a significantly weak voluntary system, a thirty second timeframe after which a gambler can increase a voluntary limit appears to be particularly brief. An extension of this time to at least a 24 hr period would provide a more meaningful opportunity for a gambler to consider this decision more carefully. The system provided for by the ABB code is far removed from these requirements. It does not extend beyond single sessions, requires no pre-determined limit to be set outside the gambling venue or away from the machine, uses ‘soft’ limits that can be readily over-ridden, and the default money limit is very high compared to average earnings. On this basis there is little likelihood of harm minimisation efficacy beyond very modest effects.

Session data on player cards Provision of information about expenditure of time and money on gambling activities has the potential to be valuable for many gamblers. However, provision of information about single sessions is much less valuable than provision of comprehensive information over time, and in a voluntary ‘opt-in’ format is likely to demonstrate less efficacy than within a universal pre-commitment system. It may also have perverse effects and induce ‘loss chasing’ with some gamblers. Overall this initiative has some potential but is limited in harm minimisation efficacy by its double-voluntary nature and restriction to single gambling sessions.

Money loading This measure in other forms has some demonstrated efficacy. However, as with a number of other measures set out in the ABB code of conduct, the form in which it is presented in the code is at the lower end of likely efficacy. A limit on machine load up or a restriction on the denominations that can be loaded has been shown to have positive effects. However there is no evidence that repetitive querying of each incremental addition to credits has any harm minimisation effects.

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The harm minimisation efficacy of this intervention is likely to be low.

Exception reporting This measure is largely a compliance matter and has limited harm minimisation focus or efficacy.

Cash machines in betting shops This measure has a limited but positive evidence base and is likely to produce modest positive harm minimisation effects. However its effects may be diluted by availability of debit facilities within venues and the extent to which ATMs are accessible nearby. It may also produce perverse consequences involving accessing credit accounts for cash withdrawals on ATMs outside betting venues.

Customer information As noted above, provision of information via signage, pamphlets, signage or screen based material has little if any evidence base, although there is some evidence of quite modest efficacy in relation to screen based messages. On this basis, the harm minimisation efficacy of these interventions is likely to be low.

Conclusions Overall, the measures proposed by the ABB code of conduct are of low to very low potential efficacy. This is consistent with most such codes. The ABB code does adopt some measures, which, if better developed and implemented, might be more effective. The introduction of a limited and voluntary form of pre-commitment has potential to become a useful tool for gamblers to effectively limit their expenditure. However, at present it is far from achieving such an outcome, and requires significant modification before this can be achieved. Removal of ATMs from betting premises is a better implemented policy but is likely to be undermined by availability of cash or credit from other sources. Overall, the harm minimisation effects of the ABB code are likely to be very modest, if detectable at all. There is evidence that, collectively, modest measures can reduce harm and gambling expenditure. However, the most effective measures in achieving this outcome tend to be those implemented broadly and outside the control of individual operators – measures such as caps on gambling machine density, reductions in the maximum bet permitted, ‘hard’ load up limits, modification of gambling machine characteristics, removal of ATMs, and other system modifications (Livingstone et al 2014). None of these measures bar the ATM removal have been adopted by the ABB code. On this basis, the code occupies the lower end of likely harm minimisation efficacy. It is not particularly innovative, adopts no highly effective measures,

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and is likely to produce only very modest improvements in the protection from harm of those who use FOBTs.

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Part 2: Review of Griffiths, M. (2014) Responsible gambling initiatives and preliminary evaluation of the ABB code of conduct.

Introduction Griffiths adopts a responsible gambling lens in this paper, expressly adopting the ‘Reno Model’ approach (Blaszczynski et al 2004), via which gambling decisions and consequent harm are uncritically located at the level of individuals. Although this may represent a change from the ‘medical’ or ‘disease’ model of gambling treatment, it does not provide recognition of the importance of environmental, social or population level factors in the construction of gambling harms. A public health approach to the harms of gambling would acknowledge such issues and address them specifically. This does not appear to be a concern of Griffiths in this paper. The ABB code itself refers repeatedly to Griffiths’s work supporting the preparation of the code of conduct. It is not best practice for those responsible for design or development of a set of interventions to undertake subsequent evaluation of those interventions, or indeed post hoc justification of them, but these appear to have occurred in this instance. More independence in the review of these measures would have provided greater credibility for the findings of the ‘preliminary evaluation’. The conflict of interest created by Griffiths’s involvement in the development of the code arguably undermines his capacity for independence in evaluating it. Griffiths appears to have had access to industry data for the purposes of preparing the paper. These data appear to have been subject to some form of analysis. However, no methodology is described, and no data tables provided. Usual standards for the rigorous production of evidence appear to have been overlooked in this evaluation. Overall, the paper draws on these data to report somewhat uncritically and very positively on the success of the ABB code of conduct and its measures.

Literature review Following a summary of results and a discussion of the nature of responsible gambling, Griffiths initially presents an outline of the elements of the ABB code and its grounding in responsible gambling perspectives. The paper then proceeds to a review of material broadly relevant to the measures contained in the ABB code, commencing with a discussion of literature focused on pre-commitment and limit setting. This section of the review is largely concerned with material describing user attitudes, and refers to little data about the harm minimisation efficacy of pre-commitment or limit setting. It

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records strong opposition to mandatory spend limits amongst gamblers and suggests that limits to time are likely to be effective in online gambling cohorts. It also interestingly refers to the potential efficacy of low bet limits (Blaszczynski et al 2001), which demonstrated likely good efficacy in reducing expenditure by problem gamblers. Lower bet limits are not a measure adopted by the ABB’s code, however, and Griffiths does not recommend them. Material relating to ‘pop-up’ messages is then reviewed. This material indicates that there is good potential for dynamic pop-up messages to be effective in assisting users to stay within their limits, and to cease gambling machine use after particular periods of time (notably 60 minutes). However this review provides sparse data on actual effects. In one example however, Griffiths notes that:

Of the 11,232 sessions that lasted at least 1,000 consecutive slot games prior to the pop-up message change, 75 sessions immediately terminated after the simple pop-up message was shown (0.67%). This behaviour was almost certainly due to the appearance of the pop-up message. After the new pop-up was introduced, 169 sessions immediately terminated when the pop-up message was shown at 1,000 consecutive slot games (1.39%) ... The data … suggested that pop-up messages can influence a small number of gamblers to cease their playing session (Griffths 2014).

Although it is interesting to discover that pop-up messages appear to have some effects amongst persistent gamblers, the scale of effects demonstrated appears to be quite low – 0nly 1.4% of gambling sessions appear to have been affected by the pop-ups even after modification. Further, no data on statistical power or significance are provided so it is difficult to assess the extent of this effect. The review then considers material relating to self exclusion programs. As noted above, there is limited evidence of the efficacy of self exclusion programs and Griffiths generally supports this conclusion. However, by referring to a study undertaken by Griffiths, Wood and Parke (2009), Griffiths suggests that self exclusion may be more effective as a responsible gambling tool for non-problem gamblers than as a tool for problem gamblers, although his argument in support of this proposition is difficult to follow, and based on the proposition that some non-problem gamblers may occasionally experience periods of loss of control associated with drinking bouts or specific events. Although some data are provided in relation to this study important information such as the sample size and statistical significance, etc, are not provided. Material relating to customer interaction is also reviewed. This section also broadly agrees with the conclusions reached by the present author (above). However, Griffiths suggests that in a jurisdiction (the Netherlands, or Switzerland) where identification is required to gain access to casinos, interaction can be effective as information about user activities can be tracked over a period of time. However, this summation is not particularly valuable in the absence of a recommendation that the UK adopt this additional requirement, as such opportunities do not arise in the UK.

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Age verification is then discussed as a social responsibility practice.

Discussion of FOBT and betting industry data

Average session length and expenditure Griffiths reports that the data he was provided with covered a period of 15 weeks from 1 March 2014. He does not specify the number of sessions contained in these data nor the number of sites from which the data were collected. He indicates that the average duration of FOBT use was ‘approximately nine minutes’, and average expenditure £7. He concludes that this suggests that ‘the data appear to show that the vast majority of FOBT players gamble responsibly’. This conclusion could be better substantiated were the distribution of both expenditure and time for user sessions shown, or the data presented transparently via an appropriate table or tables. It is quite possible that a significant number of FOBT session could result in considerably higher expenditure and time duration. It also conflates the session expenditure with user expenditure, which could of course be much greater if several sessions are undertaken over the course of time.

Average voluntary time and money limits Griffiths reports that time limits set were between 38 and 48 minutes with typical money limits set at ‘around £350-£450’. It is unclear why these imprecise estimates of average or median limits are adopted. He concludes that these limits ‘are modest’ although £450 is close to the UK’s average weekly income. This is arguably a far from modest limit for a session of FOBT use.

Number of voluntary limit setting sessions Griffiths reports that in the first week of the data the number of voluntary money limits set was 10,721 (time limits were 5,652), but that by week 15 this had declined to 1,557 (time limits 832). These represented 0.27% of sessions in week 1 and 0.04% of sessions in week 15 (money setting). At the individual shop level he reports that in week 1 the average number of sessions for money setting was 1.3. These represent very modest proportions of the estimated 4,000,000 sessions per week in week 1. Quite correctly, Griffiths concludes that the take up rates of these tools was very low, and suggest the use of a player card as a mechanism to encourage and facilitate higher rates of utilisation. However, as Griffiths also notes, take-up rates of such technology are low in voluntary environments. It is clear that the take up rates for this intervention are amongst the lowest recorded in the literature – which Griffiths implicitly concedes.

Behaviour on reaching voluntary limits Griffiths notes that on reaching voluntary limits - ‘approximately 20%-25% of reached their pre-set money limits’ (Griffiths 2014) – again, no explanation is offered as to the imprecision of this statistic – between 43% and 50% ceased using the machine and various other outcomes occurred, including a small

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proportion who viewed the pop-up and continued using the machine after inserting more money. Larger proportion of those setting time limits continued using the machine after viewing the pop-up message. Griffiths interprets these results as ‘encouraging’ although the sample of sessions using this feature is a very small component of total sessions. Given that voluntary limits are typically very high, according to Griffiths’s report of the data, these results could also be interpreted with caution, suggesting that those setting such limits do so to avoid mandatory limits.

Mandatory limit information Griffiths indicates that mandatory spend warnings were provided in between 4.4% and 5.1% of sessions during the trial, with mandatory time limits reached in between 8.3% and 9.3% of sessions. Griffiths interprets these data as positive, suggesting that reminding people of these limits ‘can only be a good thing’. He also suggests that ‘the mandatory limits set … by the ABB … appear to be appropriate’. This may be so, but it is also possible that setting the money limit at £250 is quite high, and that this is the reason few users reach that limit. It is also the case that a small number of gamblers provide very significant proportions of gambling revenue – in Australia, the Productivity Commission averaged the proportion contributed by problem gamblers on gambling machines at 40% of total revenue, with another 20% contributed by ‘at-risk’ gamblers (PC 2010). Similarly, around a tenth of FOBT users appear to reach the 30 minute time limit. This may reflect a similar pattern of consumption.

Behaviour once mandatory limits are reached Griffiths reports that 75% of those who reach mandatory limits continue to use the FOBT and insert more money. A modest 4% stopped using the machine at this point. Of those reaching time limits, 94% continue to use the machine with 44% of them inserting more money. Griffiths regards these data as encouraging, suggesting that ‘there is no evidence to suggest that those that carry on playing do not have the time and money resource to carry on playing’ (Griffiths 2014). There is, of course, no evidence to suggest that they do, either. Clearly, for the majority of intense FOBT users who reach the high money limit, the effect of the pop-up messages is negligible.

Customer interactions Griffiths also asserts that a substantial increase in staff-user interactions is attributable to the number of users reaching limits, and that this may have beneficial effects. However, no such beneficial effects are demonstrated, and Griffiths notes that the content and quality of these interactions is not known. Amore comprehensive evaluation of the Code would have benefited from even a modest program of qualitative research involving staff.

Self exclusion Griffiths notes that the number of self-exclusions increased by 35% over the period of the introduction of the ABB code, to a peak of 6,328 in the three

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months to June 2014. This may reflect the launch of the code, increased awareness of the availability of self-exclusion, or, as Griffiths suggests, ‘the visibility of the new code to players at a local level’. No data are presented to identify the cause of the increase and although it may be reasonable to conclude that the launch of the new code may have played a role in this increase it will be interesting to see whether this trend continues over time. National self-exclusion data indicate that average growth in self-exclusion was around 9% between 2012-13 and 2013-14 (from 22,528 to 24,471)(GC 2014a). The detected rate of breaching of self-exclusion remains a major issue however, with a breach rate of around 80%. Although increased utilisation of self-exclusion may be a positive, its harm minimisation effects would also be improved substantially by utilisation of a card based universal pre-commitment system.

Age verification compliance Griffiths reports on an exercise in monitoring challenges issued to young people and concludes that compliance was at approximately 80%. This is essentially a compliance requirement. Although Griffiths is correct in identifying young people as at risk of gambling problems, it would be startling were minors able to gain access to betting premises at a rate greater than 20%. As Griffiths also notes, there is room for improvement.

Responsible gambling awareness Griffiths reports that two surveys sought to identify awareness of responsible gambling messages, and some attitudes towards bookmakers in relation to responsible gambling, amongst the public and gamblers in the period around the launch of the code. He concludes that awareness increased after the launch (from 27% to 40%) and that 68% of a small sample of loyalty card members believe that bookmakers take responsible gambling seriously. However, ‘[t] here was little evidence that the new Code changed attitudes about responsible gambling’ and that most respondents believed that responsible gambling was something that only concerned problem gamblers. His recommendations suggest that ‘as there is little evidence of a negative effect’ these information dissemination initiatives should be continued, but re-oriented towards the message that responsible gambling is a message for anyone who gambles. He further recommends that ‘the Code is not designed to stop those people that are already problem gamblers. All the betting industry can do in these cases is to refer such people on to service providers’ (Griffiths 2014).

Griffths’s conclusions Overall, Griffiths concludes that the ABB code is having an impact. However,

[w]hether the impact is having a positive impact (sic) in terms of promoting responsible gambling and minimizing harm in a wider sense remains to be seen but the early indications outlined in this report are positive (although the sharp decline in the number of players that are voluntarily setting their own limits is an area that needs to be addressed) (Griffths 2014).

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He also points to the increased utilisation of self exclusion as evidence of success, and reiterates his concern that the responsible gambling initiatives contained in the code are viewed by gamblers as being intended solely for problem gamblers. He is encouraged by increased research into responsible gambling initiatives, expressing the belief that gambling businesses now understand that the long term success of their businesses relies on ‘problem-free players’. Unfortunately, he provides no evidence for this assertion, which is directly contradicted by the frequently repeated observation that problem gamblers constitute the single largest revenue source of many gambling forms, particularly gambling machines.

Discussion of the preliminary evaluation. The preliminary evaluation is very limited in its capacity to provide a clear, transparent and unambiguous assessment of the harm minimising effects of the measures adopted by the ABB’s code of conduct. There are a number of reasons for this. Firstly, the review of literature which forms the first part of the preliminary evaluation is limited and in the author’s opinion provides a post hoc justification for the measures adopted by the ABB in the code. This is unsurprising, and it is of course relevant to outline the theoretical or empirical basis for any interventions. However, the review concludes, for the most part, that there is limited evidence to support most interventions – and it doesn’t deal with some important measures, such as the removal of ATMs. This intervention may arguably provide the most harm minimisation effects of all those contained in the code. However it is not referred to in either the review of literature, or in the summary of data presented in the second part of the preliminary evaluation. This is disappointing and financial data crucial to an evaluation of this nature could have provided some interesting insights, into both the effect of ATM removal and of the introduction of limit setting capacity. It is surprising that these data were not provided for analytical purposes, or, if they were, that they were not utilised. This is also the case for data around credit loading. Secondly, the presentation of data used to discuss aspects of the effects of the limit setting features is disappointing. It is difficult, in my opinion, to determine the reliability of Griffiths’s conclusions and reasoning in the absence of more detailed data. In an evaluation of this nature, data could be presented via tables or an appendix to demonstrate the pattern of distribution of bets, of amounts wagered within sessions, of time spent per session, and, with some additional observational studies, and/or analysis of loyalty data, of the number of sessions per day or week typically engaged in by individual gamblers. Disclosure of financial data and session characteristics would have allowed a much better understanding of the actual effects of the measures implemented by the code. Further, almost no statistical analysis is provided beyond estimates of ‘typical’ patterns of expenditure, etc. This severely limits the utility of the limited data presented, and thus hinders clear comprehension of the actual effects of the code’s measures. That this is an ‘preliminary evaluation’ is, in my view, no excuse

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for not providing these data. In fact, disclosure of data may have allowed other researchers to undertake further useful and constructive analysis. Thirdly, Griffiths’s review appears, in my opinion, to be almost unfailingly positive, in some cases in contrast to the material presented. This may be attributable to Griffiths’s enthusiasm for measures on which he appears to have advised the ABB. In any event, a more critical review may have offered more scope for constructive suggestions about how the code could be fundamentally improved. For example, the low take up rate for voluntary limits, and the high levels at which these were typically set, could be construed as requiring considerable further thought and reform of the system. Further, the high rate of continued use after reaching what by any measure is a high mandatory limit (or more correctly, a spend warning) of £250 is, in my opinion, a matter for some careful reflection. However, this is not evident. Fourthly, the preliminary evaluation fails to identify let alone address the harm minimisation effects of these interventions. ‘Responsible gambling’ is presented as a catch-all rubric within which harm minimisation is fully contained. This, however, is a clear misunderstanding of basic public health and harm minimisation principles. As noted in the early part of this review, responsible gambling presents a specific view of the nature of gambling harm, which locates the locus of harm at the individual level and fails to take account of societal, economic, financial or discursive factors, let alone the likely impact of population health principles to harms associated with gambling. Gambling harm accrues in the first instance to individuals, their families, friends, employers, neighbours and society at large; but harm minimisation is best achieved through recognition of the need to provide interventions that reduce the likelihood of harm across the population. Griffiths hints at this in his allusion to seatbelts and airbags at the conclusion of the preliminary evaluation; unfortunately, little of such thinking is, in my view, evident throughout the balance of the paper. This is disappointing. Fifthly, there are two interventions which, on Griffiths’s own reasoning, are likely to have major population wide impacts on gambling harm. These are a reduction of the maximum bet limit; and the introduction of a universal pre-commitment system. Both of these were recommended by the Australian Productivity Commission (2010). The evidence for these interventions is arguably superior to that for most if not all of the interventions actually contained in the ABB’s code of practice (see Livingstone et al 2014). Using Griffiths’s own logic, limit setting and self-exclusion would both be greatly enhanced by adoption of a universal pre-commitment system. The stigma he identifies via the perception that limit setting is useful only for those with gambling problems would be addressed. Further, very valuable research data could be extracted from de-identified user accounts, including a clear understanding of session behaviour and the effectiveness or otherwise of limits, mandatory or voluntary. Reduction in maximum bets appears as a self-evident measure, given that FOBT revenue constitutes two thirds of gambling machine revenue in the UK despite FOBTs forming about one quarter of the pool of machines (GC 2011). Opposition to this intervention may arise from the simple fact that FOBTs now contribute the majority of the revenue accruing to betting shops (about 51%)(GC 2014), but if gambling machines are

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intended to provide harmless recreational activity it is difficult to comprehend why a maximum stake of £100 is necessary. This seems to be underlined by Griffiths’s interpretation of industry statistics, which suggest that most FOBT users lose no more than £7 per session. If this is so, why is a bet of £100 necessary? Elaboration, or indeed presentation of relevant data would assist in deciphering this issue.

Conclusions The preliminary evaluation is, in my opinion, considerably flawed by the issues noted above. An independent evaluation undertaken by independent gambling researchers who did not assist in the design of a code of conduct, without a track record of funding support from industry, with unhindered access to gambling machine data including financial data, and with a capacity to carefully analyse and publish such data, would provide far more useful information for policy makers. The preliminary evaluation in my view represents an apparent attempt to demonstrate adherence to responsible gambling practices that lack an evidence base and are generally favoured by industry for the purpose of achieving public, or perhaps more importantly, political support for continued self-regulation. Such systems of self-regulation are not likely to achieve significant reductions in harm, and in any event are largely if not entirely unsupported by evidence. Until independent research assesses the value of these reforms, and others like them, the evidence base will remain of poor quality, and we can expect gambling harms to continue, largely unabated. It is not in the interests of those who rely on gambling revenue for their livelihood to produce reforms that will reduce that revenue, as effective harm minimising gambling reform almost certainly will. As has been evident with many harmful products, effective reform in pursuit of harm minimisation requires the activity of a chain of independent actors at multiple levels – not the least of whom are researchers.

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Notes: About the Campaign for Fairer Gambling It is a campaign striving for fairness in gambling. So, the campaign is centred around the three licensing objectives of the Gambling Act 2005, aimed at: 1. preventing gambling from being a source of crime or disorder, being associated with

crime or disorder or being used to support crime, 2. ensuring that gambling is conducted in a fair and open way, and 3. protecting children and other vulnerable persons from being harmed or exploited by

gambling. The Campaign aims to: 1. Engage with politicians to toughen legislation 2. Gather evidence of unfairness and non-transparency 3. Rally support from special interest groups to highlight the negative social and

economic impact caused by problem gambling under the current legislation The Campaign for Fairer Gambling www.fairergambling.org is a not-for-profit entity funded by Derek Webb and Hannah O’Donnell. It recently launched the “Stop the FOBTs” campaign to highlight the problems associated with Fixed Odds Betting Terminals www.stopthefobts.org. Press contacts: Rachael van Oudheusden/Lucy Knighton 0115 948 6900 info@stopthefobts.org / fobts@bcsagency.com