We have reported previously on the introduction by the Gambling Commission of an Annual Assurance Statement pilot scheme for gambling operators with a significant market share or extensive operations, assessed by the Commission as those having an annual gross gambling yield of £25 million or more.
Described by the then Chairman of the Commission, Philip Graf, as being “very much about changing peoples’ behaviour”, the first year’s assurance statements submitted by such operators were received less than positively by the Commission, Philip Graf commenting that the first year’s pilot scheme had illustrated that there was “some way to go”.
This resulted in the Commission holding a series of workshops, having highlighted what it described as “the continued challenge licensees are experiencing in assessing revenue from ‘at-risk’ and ‘problem gamblers’ within the customer base”. It went on to say: “We recognise that this is a complex and highly sensitive area and also that the approach will necessarily be different across licensees and sectors. We consider that understanding this aspect of a licensee’s customer base is not a simple challenge but neither do we think that it is impossible to address”.
As indicated by the above statement, the most challenging aspect of the assurance statement (and one which the Commission asked operators to re-address) related to consideration of the following issues:
- the likely prevalence of at-risk and problem gambling within the operator’s customer base,
- what the operator is doing to reduce gambling-related harm, why it considers that these actions will be effective and what measures it employs to understand effectiveness and
- different approaches that operators could apply to assess the revenue from “at risk” and “problem gamblers”, highlighting strengths and weaknesses.
We assisted a number of operators to address these issues in their supplemental responses and will be pleased to advise any others still considering how best to do so.
Whilst the above issues might be thought most applicable to B2C operators, the Commission made it clear that “whilst B2B licensees may have no direct exposure to ‘at risk’ gamblers and ‘problem gamblers’, they are in a position to contribute to the evaluation. We expect B2Bs to describe their own efforts to help identify and tackle gambling-related harm and share any insights that would assist B2C licensees in assessing the revenue impact of efforts to mitigate gambling-related harm”.
The Commission has now published a Word version of the Annual Assurance Statement template for Year 2 of the pilot scheme (that can also be downloaded as a pdf below, together with the Commission’s covering announcement). According to the Commission, the relevant timescales are as follows:
- 15 December 2017 – Deadline for 2017 submission
- December 2017/January 2018 – Commission consideration and analysis of the submitted statements
- February/March 2018 – one-to-one feedback calls on the submitted statements
- April/May 2018 – wider feedback on the outcomes of the second assurance statement cycle (this could be in the form of workshops)
- June 2018 – third cycle of the assurance statement pilot commences.
To assist all operators required to submit an Annual Assurance Statement by 15 December, it is worth setting out below in its entirety that part of the Commission’s footnote to the Year 2 template in which it addresses the following question: What do we mean by ‘at risk’ and ‘problem’ gambling (AR/PG)?
“The AR/PG sections allow you to build on responses submitted in December 2016 to note developments and progress. We recognise that this is a complex area and that the approach taken by operators will necessarily be different across licensees and sectors.
There are different ways of categorising problem and at-risk gamblers. Indeed, the way that problem gambling has been defined and measured has changed over time as we have come to understand more about its dimensions. In Great Britain two internationally-recognised problem gambling screens are used for the prevalence surveys, the Problem Gambling Screen Indicator (PGSI) and the American Psychiatric Association’s ‘Diagnostic and Statistical Manual of Mental Disorders’ (now in its fifth edition – or DSM-5). PGSI uses 9 questions with answer options scoring 0, 1, 2 or 3 (so a maximum score of 27 is possible). 0 is non-problem gambling, 1-2 is low-risk, 3-7 is moderate risk, 8 or more is problem gambling. DSM uses 10 questions with 4 answer options, and answers are scored dichotomously (ie for each question people either meet the criteria or they don’t) (so a maximum possible score is 10). If people endorse 3 or more criteria they are classed as a problem gambler (clinicians might use an additional category of pathological gambler for those endorsing 5 or more).
It should be noted that an ‘at risk’ diagnosis on either of these scales does not indicate the absence of gambling-related harm. Players categorised as ‘at-risk’ might already be experiencing harm, or might be more likely to move in and out of experiencing harm. For this reason, licensees need to consider a broader population than the simple headline number of problem gamblers.
A single definition of AR and PG is not necessarily helpful as this may depend on different sectors and factors. The importance of assessing the estimated extent of AR and PG within an operator’s customer base is to understand how well an operator understands negative effects on consumers and is able to take action to mitigate the risk of gambling-related harm within that base. Operators should therefore:
- consider the likely prevalence of at-risk and problem gambling within their customer base and how it has changed since the last statement,
- set out what they are doing to reduce gambling-related harm,
- set out why they consider that these actions will be effective and what measures they employ to understand effectiveness.
An update on progress with developing an approach to assess the revenue from ‘at risk’ and ‘problem gamblers’ should also be provided. This could include detail on how a licensee has implemented an approach it referenced in its previous statement, or could include more detail on different approaches that could be used and the planned steps the operator intends to take to be able to use these approaches. Where licensees are able, they should extend this to include consideration of the level of spending likely to derive from ‘at risk’ or ‘problem gamblers’ and thereby the extent to which licensee revenues are generated by customers in those categories.
In recent years, a number of studies have been carried out on expenditure by problem gamblers in Great Britain (in addition to the large number of international studies). As we discussed at our 2016 workshops, licensees may wish to consider these studies with a view to understanding risk levels within their own businesses. These studies may also be insightful in terms of helping licensees to understand the primary research options available to them:
- Orford, J., Wardle, H., Griffiths, M. (2013) What proportion of gambling is problem gambling? Estimates from the 2010 British Gambling Prevalence Survey. International Gambling Studies
- (2016) People who play machines in bookmakers: secondary analysis of loyalty card survey data. NatCen, London, UK
- Ipsos Mori (2016) Problem gambling in licensed bingo venues. GambleAware.
To this extent, the AS should be considered an important tool for putting the consumer first.”