A former industry insider’s view on the ABB Code for Responsible Gambling and Player Protection

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In his days as regional manager at the Tote, Adrian Parkinson, was responsible for introducing FOBTs into betting shops. Now a Campaign Consultant, he shares his expert viewpoint on the latest attempt at self-regulation by the bookmakers.

The Association of British Bookmakers (ABB) opens this latest attempt at self-regulation with the claim that it is “the first code of its kind to be published in the world”. This ignores the fact that responsible gambling codes exist in most developed countries which permit legalised gambling, including Australia, America and Canada.  The difference in the UK is that we have permitted the most addictive, high stake casino gaming in easy access areas, such as high streets, with little regard for their impact on players and communities…

…With 12 years of mounting empirical and anecdotal evidence of the dangers of this style of easily-accessible electronic gaming, it is only now, amidst increasing concern and political pressure, that the bookmaking sector has stepped in with more sticking plaster measures aimed at delaying the only meaningful solution – a reduction in the maximum stake.

Through its new Code for Responsible Gambling, which is to supposedly encourage responsible gambling on Fixed Odds Betting Terminals (FOBTs,) the industry appears to be deferring responsibility to operational shop based workers, many of whom run betting shops single handedly as a consequence of lone staffing. Most of the measures contained in the new code are already in place, with the code identifying that these existing measures need strengthening.

SHOP SAFETY

Over the last 10 years, security in betting shops has been ramped up, with most shops now having CCTV systems installed. However, the reduction in betting shop robberies is largely attributable to better cash handling and security measures behind the counter that have reduced the amount of money obtained during robberies. There has been a large increase in cash held on premises due to FOBTs, but the introduction of safe cash removal times, time delay safes and stricter banking guidelines have mainly contributed to less cash being available for robberies. It has always been the accepted standard that the less cash that is stolen, the less chance there is of further robberies taking place. So the reduction in robberies and increase in detection rates will be largely attributable to better cash handling procedures and the use of CCTV. These are elements all high street businesses have introduced to their portfolio of security measures.

The ABB, as part of this new Code of Conduct, continues to back the operation of lone staffing in betting shops. A strategy allowed by the continuing rise of FOBT gambling above traditional track and sports betting over the counter – one that all major operators now use as standard across their estates. It was the murder of a Ladbrokes betting shop Manager, whilst lone staffing, that motivated us to raise this issue again with Members of Parliament.

David Lammy MP has an Early Day Motion calling for a review of working conditions in betting shops and yet, despite the available evidence showing a rise in anti-social behaviour and criminal damage in betting shops driven by FOBT gambling, the industry continues to put its staff at risk. SW Londoner August 2013.

One of the tactics being employed by the industry as part of this new code is to claim they will develop shop worker skills at identifying and assisting problem gamblers. In a shop that is lone-staffed and predominantly at periods when FOBT usage is highest, this is simply not going to happen. By allowing the continued use of lone staffing, the ABB is sanctioning ineffective upholding of the licensing objectives, jeopardising both the safety of workers and proper implementation of the very “responsible gambling” they claim to support.

Communities Union, which is a stakeholder in the Safe Bet Alliance, has already called for an end to this practice.

FINDING LOCAL SOLUTIONS

The proliferation of issues in areas suffering from saturation of betting shops has resulted in the industry having to take part in local discussions and partnerships to address anti-social behaviour, problem gambling, crime and disorder. Betting shops did not perpetuate these problems before the introduction of FOBTs. That the industry is now “fire fighting” on a nationwide scale by setting up these initiatives shows the scale of the problem that FOBT gambling is having on our high streets.

ANTI MONEY LAUNDERING & TERRORIST FINANCING

FOBTs have been highlighted as a potential tool for money laundering as part of our submission to the Department of Culture, Media and Sport (DCMS) Triennial Review of gaming machines stakes and prizes. The EU is currently applying to include the betting sector under its 4th money laundering directive, but this is being vigorously challenged by the ABB and comes just as Coral is at the centre of one of the biggest incidents of money laundering in the gambling sector.

BETTING INTEGRITY

When it comes to integrity in sports, the ABB and its members are keen to share data to identify suspicious betting patterns and prevent fraudulent cost to the industry. However, when it comes to sharing FOBT data, are they so forward? Money laundering can be identified from FOBT data, as can indicators of problem gambling but, unlike in jurisdictions such as New Zealand, none of this is currently shared with the UK regulator.

HARM MINIMISATION STRATEGIES

Staff-initiated interaction with customers is a small step towards enabling some of the more human orientated aspects of ensuring responsible gambling. More so than warning signs or leaflets, human interaction and involvement in gambling problems are effective, but there is a large capital cost to the proposed level of training that is required for it to be effective. The reality of internal training among the larger operators is secondment of those qualified from organisations like Gamcare, to hold one day training seminars for operational staff. Attendance is never 100% and their effectiveness is questionable. The scale of the problem at operational level has been known for many years, but only now after 12 years on the high streets is the industry trying to engender socially responsible FOBT gambling at shop level.

As raised by the issue of lone staffing, suggestions such as “walking the shop floor”, recognising the signs of problem gambling, “interaction in response to specific customer behaviour”, conflict management, maintaining a strict under-21 policy, serving customers and ensuring the licensing objectives are up held are big asks for a single member of staff in charge of licensed premises.

Adding compliance objectives to the middle and senior management levels of all operators does start to bring a more responsible culture into the ranks of those who should already be driving it. However, anecdotal evidence brought to us shows that middle management is still revenue driven where FOBTs are concerned and very much at the expense of problem gamblers.

SELF-EXCLUSION

It is incredible that the industry still uses “effective” alongside self-exclusion, though they do concede it is a “challenging area”. Voluntary self-exclusion has been proven time and time again to be ineffective. Yet the industry still champions it. The reality is that it is a cheap alternative to more effective measures and one that persistently fails to protect problem gamblers. The failures of self-exclusion are painted very clearly in this Bureau of Investigative Journalism article and one victim of self-exclusion taking William Hill to court.

AGE VERIFICATION

The ABB claims that all operators already enforce a “rigid think 21 policy”. Yet test purchasing evidence, at least that published, shows the opposite. With FOBTs known to have specific appeal to the 18-24 age group, the same is true of those under 18. It is this product that has led to a surge in those under 18 attempting to get into betting shops. I recall shop managers being in favour of an “over 21’s” policy once FOBTs became established as a result of the increasing number of under 18’s attempting to get into betting shops.

Age verification is another facet relevant to lone staffing. The betting sector is rightly proud of employing high numbers of women and young people. But, as Howard Reed, former Chief Economist at the IPPR, points out, the betting sector pay structure at shop level is close to minimum wage. Lone staffing invariably involves women or young people paid not much more than minimum wage managing licensed premises with direct responsibility for age verification along with all the other elements of this new code.

ADVERTISING AND PROMOTIONS

The aggressive marketing of FOBTs will continue with tournaments aimed at continuing the constant recycling of players.  Gamble Aware and Helpline numbers are already available in shops, but explanations of the dangers and different play style of casino content on FOBTs is not available. Tournaments entice new players into high risk, high stake and high speed gaming with the illusion that it is “harmless fun”. The reality, as Roger Radler discovered, is that it is the most addictive form of gambling and it’s on every high street. The bookmakers even incorporate targets for tournaments as part of a shop team’s budgets and objectives whilst advertising illusory big wins from machine play in their windows.

The industry, through the new Responsible Gambling Committee, will investigate complaints about breaches in the spirit of legislation from within the industry and the public. FOBT tournaments and marketing should be at the top of their list. If the industry wants to genuinely encourage responsible gambling in a socially responsible environment, then it must stop active enticement of players.

RESEARCH, EDUCATION & TREATMENT

Even though the industry is happy to disregard secondary research based on previous British Gambling Prevalence Surveys (BGPS), it is willing to fund a further survey next year. Whether this will be funded separately from existing donations to the Responsible Gambling Trust (RGT) or the industry is masking the funding of this in the existing funding arrangement is not made clear as part of this new code. Even with current suggested donation levels, contributions to the RGT represent only £13 per problem gambler per year, based on the 2010 BGPS.

NEW HARM MINIMISATION STRATEGIES FOR MACHINE PLAYERS

Voluntary Monetary & Time Limits

Enabling voluntary limits on money and time spent in a session of play is a welcome measure, but not one that will have high take up among pathologically addicted gamblers, especially with a 30 second delay followed by the resuming of play. Being voluntary means all players will not have to make that choice prior to the commencement of play and it isn’t clear whether pre-commitment will be mandatory or purely through a voluntary take up. A similar stake and time restriction measure was introduced following the 2004 Code of Practice, which was not mandatory but initiated by the player out of choice, who had to select the option if desired. Monitoring of this showed zero take up by players during the trial period and was consequently removed. The industry knows this is a measure that will have very little impact on problem gamblers and consequently revenue.

It is interesting that after 12 years in operation and many technological advances in game, software and cabinet design, the industry and their machine suppliers are still unable to track sessional play. This admission under the new code raises serious questions about the reading of data provided to NatCen as part of the RGT research into Category B machines.

Mandatory money based reminders

A 30 minute cycle of mandatory time based reminders for all players is again a welcome proposal. However, there is no indication of a time delay to allow for reflection after the 30 minute period of play, nor what interaction takes place by the player to remove the warning message once a decision has been made. If this is simply a pop up warning message then it would be completely ineffective.

All of these measures, suggest the ABB, could lead to “opportunities for customer interaction”. Those opportunities, flashed up on the back office control system, could also be easily overlooked by shop staff. Monitoring of the back office computer by staff is limited as the focal point for attention is the till and screen system. Having the player approach the counter to request override of the warning message is a much better way to instigate customer interaction.

Session Data on Player Cards

The use of player tracking is essential in order to monitor all FOBT players and the introduction of player loyalty cards goes some way to achieving this. Though, as the ABB points out, not all operators are able to facilitate this. The use of loyalty cards as part of a monitoring package also raises concerns in relation to the very nature of those cards and their use by operators. Loyalty cards are aimed at achieving their very name – “customer loyalty” – through player rewards which are generally based on money spent. It is questionable that mixing the retention of players combined with monitoring for problem gambling is achievable.

Provision of time spent and money lost via player loyalty cards is a very welcome development but, again, only the larger operators are able to provide this until sessional data is better provided.

Money Loading

The ability to load money from the counter with the use of debit cards has been questioned since its introduction around 2004. When the ABB talks about customers being forced to make individual choices about “each £20 denomination”, this is nothing more than easy screen clicks to credit the money into the player’s bank. It does not create a “pause for thought” situation for any player. Repeated loading of money is a sure sign of a player chasing losses and it is surprising that only now is the industry is proposing to train staff to recognise this with the potential for interaction.

Exception Reporting

This measure is fundamental to spotting money laundering, more so than problematic gambling, and is something that can be done today. High cash input versus low churn is a key indicator of money laundering that could easily be flagged up centrally already. The issue for the industry is that it hasn’t yet provided adequate training or reporting procedures to staff to combat money laundering.

Cash Machines in Betting Shops

Our campaign has already highlighted the absurdity of this measure which was covered in the Huffington Post and I have questioned the issue of cash machines in betting shops as an issue earlier this year.

CUSTOMER INFORMATION

The provision of customer information messages and the proposed improvements to the nature of those messages is welcome, but absolutely no assistance to pathologically addicted gamblers has been proposed. Increasing the frequency of these messages is welcome but so too would be increasing the strength and appearance of those messages as a player’s time or spend increases.

Providing more information on the difference in play on a FOBT versus an equivalent live event would be more effective. Informing players that the 20 second spin cycle on FOBT roulette is actually 4 to 5 times faster than real roulette should be standard practice. The increased speed of play results in increased speed of losses and we believe this is one of the factors that contribute to high levels of aggression and anger among betting shop FOBT players.

The industry still continues to mislead players as to the actual potential losses that can be incurred through FOBT use. The misconception perpetuated by the industry that the machines pay out at 97% when in actual fact cash losses per session of play can run at over 18% based on cash retention, has never been explained. This fundamental piece of information should be displayed on FOBTs as standard, but still the industry wants to avoid letting players know the true nature of FOBT gambling.

COMPLIANCE & EVALUATION

It will be interesting and a strong indicator of how seriously the ABB takes its commitment to socially responsible gambling to note the independent persons they appoint to the new Responsible Gambling Committee. Professor Mark Griffiths of Nottingham Trent University appears prominent in terms of input to the new code. However, his views on electronic gaming machines appear to have changed with his increasing closeness to the industry.

Read more about Adrian and his background.

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