LONDON, UK – 10th September 2024

“There are far, far too many gambling adverts. It’s just too much. I have said to the whole industry, we should stop all gambling advertising on television.” Not my words. Spoken several years ago at a US gambling regulator public hearing by Kenny Alexander, then CEO of GVC, now Entain, owning Labrokes and Coral.

Several years prior at a similar hearing, Ralph Topping then COO of William Hill expressed: “We will do something until we are told to stop doing it” to excuse some past bad behavior. Gambling executives will not volunteer to give up market share. They need to be told what to do and need to be at-risk if they do not do it.

When Illinois proposed increasing the online betting tax from 15% to 40%, the big two legal operators, FanDuel owned by Flutter and DraftKings, threatened to leave the state. Then DraftKings decided to stay but apply a fee on gambler winnings. The tax increased, they are all still there, there are now no fees.  Flutter admitted the higher tax would be absorbed by reductions in offers and marketing.

The trade has the capacity to tolerate necessary changes. Legislators, regulators, media – please do not listen to their protests. The Flutter group has a market value of £29 billion, obtained in part through overseas black-market operations. It includes the following entities:

• Paddy Power, regularly reprimanded by the ASA
• Sky (SGB), whose data abuse is the subject of an ICO investigation
• Stars, whose executives were penalized in the US for illegal activity
• FanDuel, promoting Daily Fantasy Sports Betiting in the US under the guise that it is not gambling
• Betfair, which was placed under special measures by the Gambling Commission special measures and which was an interested party in a gambler suicide inquest

They say – “there is nothing wrong with a harmless flutter”. There is an awful lot wrong when a Flutter executive complains about the prospect of increased taxes. The socio-economic cost of Flutter related harm is a negative fiscal drain on services such as Health and Justice in the National Budget. The market value of Flutter could fill the £22 billion black hole.

“It could be you!” was the misleading description of probability in advertising of the National Lottery Draw when it was sold to us in 1994. The reality is “It could be anybody and sometimes it’s nobody”. Bookies claimed the Lottery would cannibalize their shops. As compensation two gaming machines per shop and betting on overseas lottery numbers were allowed. Numbers, with a gross profit of over £100 million a year, includes a bingo derivative
every three minutes. It is really gaming, not betting, and therefore should not be permitted in shops.

Casinos were also allowed Lottery compensation of new table games. I had to wait until 2002 for approval of my first game, Three Card Poker. Casino executives had said it would be 1997, but some did not want my game to get in and some did not want to pay me. I sold my game assets in 2011 to a US company which paid off that debt to me over several years.

The bookies’ False Narrative Factory claimed my campaigning was casino aligned – an outrageous lie to protect their illegally introduced gaming machines – FOBTs. My campaigning was and is philanthropically motivated.
Today, the pro-bookie trolling community engage in money-motivated malicious denigration of academics, health
professionals and reform advocates. The trollers and their creepy instigators fail to comprehend that this strengthens the resolve of their targets.

Reformer evidence is never intentionally imperfect. By contrast, the trade shuts down whistleblowers and hides evidence. It uses non-disclosure agreements, commercial confidentiality, bogus legal arguments, and flawed testimony at inquests and civil proceedings. The balance of probability is that the financially biased and deliberately imperfect trade evidence does not weigh as heavily as the reformer evidence.

My table game encouraged engagement, through all the design aspects of the cloth layout, the player advice card and even the procedure manual. All contribute to marketing at point-of-sale and in-content. On a traditional slot machine with a handle, the reels were real. Now on an electronic slot game, the random number generator
will not start a spin until the result is determined. The spin is not really real – it is just in-content marketing.

The roulette wheel and ball do not have memories. Each result is independent. But prior results are displayed to imply the validity of patterns. Deceptive marketing to encourage delusional behavior. In the last century our casinos were not allowed to advertise, but numbers grew and revenues grew. With so much at content and in
content marketing, why is any other gambling marketing acceptable?

In the last century the terms “responsible” and “safe” were never associated with gambling. Now they are used to help keep feeding the monster. Trade media adverts offered up to 70% of gambler lifetime losses to super-affiliates. Why is anyone allowed to profit from steering losers to the “best online casino” when there is no such thing?

“Gambler has a big win” is not a news story. It is designed to  promote gambling. With some national media acting as affiliates, will some genuine gambling stories be shelved rather than published? A tipster suggests “several horses to put in your daily accumulator”. Why more than one or two tips a day? Why an accumulator? Why are bookies promoting tipsters?

An ad offers “Double your odds – was 2 to 1 – now 4 to 1”. It is not double my odds – I did not bet at 2 to 1. And maybe nobody did.  “Epic value – 4 to 1” – if the true odds is 6 to 1 it is pathetic value. All of this nonsense fails to comply with a rational interpretation of the fair and open licensing objective.

“When the Fun Stops, Stop” was planned ten years ago as part of a “responsible gambling” political firebreak, to prevent reformers gaining traction. That sham failed and was replaced by “Take Time to Think”, another alleged protection measure, another sham. The amount spent on these marketing shams has exceeded
the amount spent on research, education and treatment.

A shop window ad displays “Bet in Play” whilst also displaying “Take Time to Think”. An absurd and impractical contradiction. The Betting and Gaming Council (BGC) messaging is that “Each month around 22.5 million people enjoy a bet and the overwhelming majority do so safely and responsibly.” The 22.5 million includes the Lottery, which is not legally defined as betting. The Lottery is not a BGC member. Not every bet is enjoyable.

There is a world of difference between a bet and the habitual, repetitive, high frequency, high volatility engagement in risky gambling. Sign-up offers, bonus promotions, VIP schemes and affiliates have more function for online than land-based. Online targets anybody in any condition, anywhere at any time by any method with any content.

There is a higher socio-economic cost of online gambling. Also, it is economically detrimental with low employment, short supply chains and minimal economic multipliers. Remember the bookies did not want the Lottery to bite them. But online gambling is a far more monstrous cannibal, taking revenues away from all other disposable income activities.

The Gambling Act incudes an “aim-to-permit”. It does not include an “aim-to- promote”. The Gambling Commission principle of promotion of growth of the sector harms the economy as whole. Gambling causes financial harm to the financially vulnerable. The wealthy take from the poor, the few take from the many. Some of
the wealthy few are overseas, some are offshore. A new report by the National Economic Research Associates
(NERA) which I commissioned must be considered. Based on NERA, I estimate that online gambling has resulted in a loss to the economy of around £40 billion in wages, £10 billion in taxes and £20 billion in the societal costs of harm.

Prevalence data has limitations as it applies to past year only, so does not encompass future or historical harm. It fails to capture the data of those moving in and out of harm over the years. Around 0.9% of adults have self-excluded from online gambling through GAMSTOP. Assuming 50% of adults have engaged in online gambling this would equate to 1.8% of online gamblers self-excluding. New evidence with the superior methodology of
the Gambling Survey for Great Britain must be considered.

The BGC still quotes outdated rates below 1%, when millions have suffered, are suffering or will suffer gambling harm at some time in their lifetime. The BGC is inexcusably perpetuating the cover-up of the quantum of gambling harms. New evidence requires new deliberation of the Tory white paper.

My policy recommendations for this parliamentary year are:

1. Urgent introduction of the statutory levy
2. Reconsideration of the white paper measures including advertising
3. Revision of the Gambling Commission statement of principles to
(a) delete the principle of “promotion of economic growth”
(b) add a new principle of “permitted but not promoted”
4. Increase the point of consumption tax rate for online gambling

The Public Health Minister, Andrew Gwynne, expressed that the drinks sector should not be at the table to advise on drinks policy. I do enjoy drinking, but I do agree with the Minister. Similarly, the gambling sector has had too much influence for too long.

It is not anti-gambling or prohibitionist to demand better legislation, better regulation and better enforcement. The most important gambling policy stakeholders are bereaved families – not just today – every day. Other important stakeholders are harmed individuals, affected others, those coming of age, future generations and reform advocates.

I hope we do not need to have this event again next year, but if we do need to, then we will be here. Thank you to all attendees, panelists, speakers, our compare and our hosts.