Ethical gambling – Spotlight on Governance

Earlier today (21 October 2020), David Clifton moderated the “Ethical Gambling – Spotlight on Governance” panel session at SBC EventsBetting on Sports – Europe Digital online conference.

Those who have registered for the ‘free-to-attend’ conference, but missed attending David’s session earlier today, can now catch-up here[NB: See Update 2 below for updated ‘catch-up’ information]

You can read below David’s introductory comments at the beginning of the session:

Ethical gambling – Spotlight on Governance

Moderator: David Clifton, Director, Clifton Davies Consultancy


  • Martin Lycka, Director of Regulatory Affairs, GVC
  • Katie Hartmann, Director of Legal & Regulatory Affairs, EGBA (European Gaming & Betting Association)
  • Daniela Johansson, Chief Responsibility Officer, Paf
  • Sandhya Singh, Head of Risk & Fraud, Payment & Customer Service, Napoleon Sports & Casino

One only has to look at what has happened to the reputation of gambling operators across various parts of Europe in recent years to recognise some of the reasons why public, media and political perception of the industry has diminished as far as it has.

In some cases, it has been the content and sheer volume of gambling advertising that has turned the tide of public opinion against the industry.

In other cases, it has been a series of high-profile AML, social responsibility and customer interaction failings by gambling operators that have resulted in ever-increasing financial penalties being imposed – the recent record UK fine of £13million for “systemic failings in governance arrangements” being a case in point, as too has been the Swedish Administrative Court of Appeal’s decision on Monday to uphold revocation by the Swedish gambling regulator of the licence held by Ninja Casino operator, Global Gaming.

In all cases, it has led to certain sections of the media latching on to every story of personal tragedy arising from gambling-related harm, every example of an industry increasingly perceived to put company profits ahead of customer safety. In the UK, for the first time ever, each one of the four major political parties had gambling reform listed as a key factor within their general election manifestos at the end of last year and it seems inevitable that the online gambling sector will have considerably greater regulatory restrictions imposed on it when the forthcoming government of the UK’s gambling legislation is determined. That looks like the same way that Dutch player protection rules are headed.

It’s against this background that a large proportion of my own work in recent years has been taken up with advising betting and gaming industry clients (both remote and non-remote) on fundamental reappraisals of, and improvements to, their governance frameworks.

Why is that important? Here in the UK, the Gambling Commission has summed it up in these words: “Those operators which demonstrate good governance and a high level of compliance at all levels are less likely to present a risk to the licensing objectives and will receive less regulatory oversight as a result”.

But what is governance? At its most simplistic it’s a set of rules, practices, and processes by which companies are governed, but I want to drill deeper with each of our panellists to address the question posed in the conference agenda: “Can new governance implement effective change promoting gambling as a “sustainable sector?”

David’s questions and the panellists’ answers covered the following ground:

  1. First of all, what is “ethical gambling” and what is its relevance to the question posed in the conference agenda: “Can new governance implement effective change promoting gambling as a “sustainable sector?”
  2. GVC is a massive international company. A different type of governance framework exists within a company of that size but what guidance can be shared with smaller gambling operators from the principles behind GVC’s framework?
  3. Paf holds licences in five different European jurisdictions but holds itself out as a different type of gambling company. Its website says its “clear mission is to generate profit for the benefit of society” and “sustainable business growth can only come from happy players. That is why responsible gaming is at the heart of everything we do”. What is Paf doing differently and is its approach to ethical gambling going to be sustainable in the longer term??
  4. Having heard about Paf’s approach to ethical gambling, what could other operators (including  Napoleon Sports & Casino) do to improve their good governance framework of rules, relationships, systems and processes by which their businesses are directed, controlled and held to account.
  5. Are this year’s EGBA Codes for (a) Socially Responsible Gambling and (b) Data Protection examples of principles that should be embedded within all European gambling operators’ governance frameworks and what governance-related assistance is EGBA able to provide to operators?
  6. Given the absence of harmonisation of online gambling laws and regulations throughout Europe, is there a possibility of common ethical gambling and governance standards being developed across Europe as a whole rather than on a minimum “as needed” jurisdiction to jurisdiction basis and, from the perspective of more newly established European national online gambling regimes, is there anything to be learned in this respect from the experience of GVC in the new online gambling jurisdictions within the USA?

If any readers would like to discuss how best to approach reappraisal of, and improvement to, their own governance arrangements, please contact David at


1. SBC News has reported on David’s panel session under the heading “BOSE Digital: Why the industry must shine a spotlight on responsible gambling”. You can download that article below.

2. The content of the conference (including David’s panel session) is now no longer available via the event platform, but can instead be viewed in your existing SBC Connect account (if you hold such an account) by:

  • logging in to SBC Connect and
  • selecting Betting on Sports Europe – Digital from the ‘Your Past Events’ section of the navigation.