Enforcing the Code: Betting shop employees and the contradictions of gambling harm reduction

By Dr Sam Kirwan and Dr Jo Large

One unmissable aspect of the post-Covid, cost-of-living crisis is the ongoing collapse of high-street retail. Yet, alongside the charity shops and vape sellers, one sector remains relatively intact; betting remains an integral part of the British high street, with a prevalence directly inverse to surrounding socio-economic indicators.

There has been no shortage of critique regarding the role played by high-street betting in contributing to conditions of poverty under austerity. When in 2014 Aditya Chakrabortty described the high-street betting sector as a form of ‘predatory capitalism’, he was highlighting the ways in which the liberalised gambling sector appears to reflect the very worst dynamics of neoliberal society. As Markham and Young and Banks and Waters have argued, the modern gambling industry, characterised by a concentration of power and expansion of influence, appears boundless in its will to extract maximum profit from its customers, with little regard for the ways in which its products amplify misery and inequality. Among the many critiques of the role of the Gambling Commission (the regulator created by the 2005 Gambling Act), the most damning is that it has enabled the proliferation of harm by emphasising ‘safer gambling’ frameworks without challenging these underlying logics of exploitation and extraction

Amidst these critiques of the high-street betting sector, there has been a lack of attention to the betting shop as a space of employment (Rebecca Cassidy’s fascinating ethnography of betting shops remains an outlier in this respect). This lack of interest is unusual given how the role of betting-shop employee has changed so drastically since the 2005 Gambling Act, and also given that much of the responsibility for reducing gambling harm in the premises-based sector falls upon the frontline employees who must implement the components of the ‘Social Responsibility Code’ (SRC) (part of the Licensing Conditions and Code of Practice). These include the need to intervene when there are indicators of ‘problem gambling’, to enforce self-exclusion schemes, and to carry out age-verification procedures.

Our research

Over the summer and autumn of 2023 we carried out semi-structured interviews with current and retired frontline employees in the sector. Whilst our focus was on the implementation of these ‘safer gambling’ approaches implemented in the SRC, these interviews covered a range of employment issues, often returning to issues of personal safety within an aggression-laden environment, and how betting practices and environments had changed in their time within the sector.

Most of our participants expressed a strong feeling that intervening in customers’ gambling habits, where there was a clear potential for harm, was something they felt staff should be doing. Many talked positively about when they had been able to encourage a customer to reflect upon their gambling and the harms it was creating. Despite the difficulties in implementing self-exclusion schemes they were seen to be a valuable tool that staff would always seek to enforce. Many of their reflections were in line with the underlying narratives of the SRC regarding the capacity for employees to prevent harm within the shop.

But participants also felt that the conditions for being able to carry out this harm-reduction work had significantly deteriorated in the era of Fixed Odds Betting Terminals (FOBTs), single-manning and multi-shop work (the mandating of staff running shops on their own and moving between shops without warning), and the profit-driven orientation of the modern gambling conglomerates. In these conditions, aspects of the SRC were experienced as factors that exacerbated the stresses and anxiety of work rather than reducing them. When participants were reflecting upon this most critically, these codes were seen as a way of shifting responsibility from operators onto frontline employees: making sure that it is staff that bear the risk and anxiety of reducing gambling harm.

An example of this raised in our interviews was the difficulty of acting on the back-office alerts created by FOBTs regarding excessive time or spend. Many noted the anxiety and fear of dismissal if they failed to act on these alerts and other potential indicators of ‘problem gambling’, despite the fact that coming out from behind the screen might itself be a disciplinary offence if it meant not being able to take bets. They could also put themselves in a potentially dangerous situation in the context of the customer aggression created by FOBTs.

There has been widespread criticism of the idea that a liberalised market, creating deliberately addictive and harmful products that enable the vast transfer of wealth from the most vulnerable in society to the most privileged, can be tamed or constrained by ‘safer gambling’ codes that rely on customers recognising their own ‘problem gambling’ and taking preventative action. We argue that what should be added to this critique are the ways in which this structure has shifted responsibility for gambling harm onto low-paid, precarious workers, who are balancing competing demands in the aggressive and stressful environment created by this industry approach. A desperate need for gambling reform has been eloquently articulated by Van Schalkwyk and Cassidy, among others. We argue that consideration of high-street gambling as a space of employment should be part of this reform. It should not remain possible for operators to continue to offer products that are intrinsically harmful, in spaces that are intrinsically unsafe, and be allowed to shift the responsibility and risk for any ensuing harms onto their lowest-paid employees.

One year on from the UK Government’s gambling White Paper: Where are we now?

By Dr Philip Newall, Lecturer in Psychology.

This blog was originally published by the Society for the Study of Addiction.  The original article can be viewed on their website.

Dr Philip Newall writes about the public health impact of gambling, and reflects on the promise of the government’s 2023 gambling White Paper.

On 27 April 2023, the UK Government published its White Paper on gambling – “High stakes: gambling reform for the digital age”. This long-awaited document was the government’s response to the 16,000 pieces of evidence submitted in response to its December 2020 call for evidence.

In common with other White Papers, the key recommendations were not enacted immediately upon publication, but have themselves been subject to a number of public consultations from the relevant government department and the regulator, the Gambling Commission. This has felt to many of us working in the area as a frustratingly slow pace of change.

Given that a year has now passed since the White Paper was published, I am writing to give my independent assessment of some key changes thus far. This blog reflects a public health perspective, which highlights the need to reduce the population’s risk of experiencing harm from gambling. In the well-known ‘cliff analogy’, this is expressed as the need to invest in better fences around a high cliff to prevent people from falling off, compared to the alternative of spending money on ambulances to take people who have fallen off the cliff to hospital.

Incremental changes to products and marketing

There have been wide-ranging changes within the gambling industry, and in comparison, more incremental changes to gambling policy. New technologies have delivered new ways to gamble, including mobile devicesvideo game loot boxes, and cryptocurrencies. This is not to forget more traditional gambling formats, such as lottery tickets, which are still available in any newsagent, high-street gambling machines, and seaside fruit machines, which are still legal for children to use. Many of these gambling opportunities are marketed aggressively to potential consumers, for example, via the ‘gamblification’ of professional sportsocial media marketing, and bingo adverts shown during daytime television.

Online slots were singled out in the White Paper as a particularly high-risk gambling product (with 64 mentions in total). Compared to high-street gambling machines, online slots are faster (2.5 seconds per spin, compared to 20 seconds on a high-street roulette machine), more available (24-hours a day, with remote access), and also result in higher losses per £1 wagered (with slot games taking around 10% of all money bet, compared to 2.7% in high-street roulette machines).

In February 2024 the government announced a £5 maximum stake for online slots, which would reduce to £2 for 18–24-year-olds. Campaigners had been hoping for a £2 maximum stake for everyone, to mirror the £2 maximum stake introduced in 2019 for high-street gambling machines. However, even a £2 maximum stake for everyone would have been at best a small step in public health terms.

The maximum stake for online slots acts only on the highest-risk subset of gamblers using one specific gambling product. The maximum stake does nothing to prevent harm occurring from someone who bets only £1 a spin on online slots, let alone someone who bets throughout a football match via an ‘in-play’ betting app on their phone – another new type of gambling invented in the last 20 years, which shows conceptual similarities with slots-based gambling due to its fast and immersive nature. People who tend to lose the most money from online slots also tend to live in more deprived parts of the country, and their losses occur not by betting larger amounts than other gamblers, but by spending more time gambling.

Reliance on industry to regulate itself

Gambling marketing has seen less government-led action, despite this being one of the aspects of gambling that is visible even to non-gamblers. There are two stated reasons for this, which I discuss below.

The White Paper approvingly mentioned the Premier League’s decision to remove gambling logos from the front of football shirts from August 2026 onwards. While strong self-regulatory action would mean that government regulation is unnecessary, a study published later last year suggested that this particular action would only remove around 7% of all gambling logos from an average Premier League football match, due to the preponderance of gambling logos on pitch-side hoardings and in other locations. This change also does nothing to address gambling marketing in other leagues, such as the Women’s Super League or the Scottish Premier League.

The White Paper also said that there is “little evidence of a causal link” between advertising and harm. However, a letter in Addiction, authored by 53 gambling researchers (myself included), argued that this is because of the methodological difficulties in establishing causality given the tools and datasets available to researchers. What some stakeholders call a lack of evidence of harm, could equally be described as a lack of evidence of safety.

What could a more effective public health approach to gambling look like?

A public health approach to gambling could take many forms, as long as it keeps the main feature of acting on as great a proportion of the overall population of gamblers as possible. Two proposals include maximum speed limits and a centralised payment system.

Maximum stake limits only act on the subset of gamblers betting at above the proposed limit on that specific gambling product. By comparison, policies that act to reduce the speed and ease of gambling work no matter how much or little a gambler is staking, and can be inventively applied to a wide range of gambling products.

While the Gambling Commission has placed a minimum spin time of 2.5 seconds for online slots, this minimum spin time could be increased, which would reduce the speed at which people can gamble. Similar minimums could also be placed in other online casino games, which can be played much faster than their land-based equivalents. Even live sports betting can be made slower than it is now. For example, an Australian Government policy forces live in-play bets to be made via telephone call, instead of via the faster and more immersive interface of a mobile phone app.

While much online gambling revenue is hard to track, the government could take control of this issue by introducing a mandatory centralised payment system for all gambling. Since each high-spending gambler has active accounts with an average of six gambling operators, this would be more effective in tracking and limiting the spending of vulnerable gamblers than the current system where this is the responsibility of gambling operators. This system could also be designed in a way that helps all gamblers to keep track of and limit their spend, which would make it a population-based intervention, and could provide a wealth of data for researchers to build a stronger evidence base on effective ways of preventing gambling harms.

Overall, my view is that the changes in UK gambling policy have been frustratingly slow and overly incremental. The forthcoming changes to online slots will leave most gamblers unaffected, and therefore provide no additional protections for most compared to the current status quo. The same is true for gambling marketing, where the industry has misleadingly framed the methodological difficulties of conducting research as a justification to largely support the status quo – even though this status quo is as unsupported by the ‘evidence’ as any other potential arrangement.

 

Ad Overload – Rethinking Gambling Advertising Regulations in the Digital Age

By Dr Raffaello Rossi, Lecturer in Marketing

In 2020, the UK government announced an overhaul of the Gambling Act to make the laws “fit for the digital age”.  Having spent a couple of years researching gambling ads on social media – I thought: “wow, this is exactly what we need” – not only because our own research had shown:

  • 1m UK gambling ads per year on Twitter only,
  • Two-thirds of all gambling accounts followers online are under 25,
  • Gambling ads on social media are highly appealing to children – but not to adults, and that
  • During one weekend, gambling ads on X (Twitter) reap an incredible 34 million views – putting social media marketing now at the heart of the industries marketing efforts.

However, my enthusiasm waned when the Gambling Act Review White Paper was unveiled in April 2023. Surprisingly, it lacked in actual interventions around (online) gambling marketing, and did not follow what most of our European neighbours have recently done. Whilst Belgium and Italy have recently almost entirely banned gambling marketing, Germany and Netherlands have intervened in several key areas – making Great Britain increasingly an outliner by allowing almost all forms of gambling marketing with minimal restrictions on online efforts.

Source: Rossi, R., Nairn, A., Ford, B., and Wheaton, J. (2023). Gambling Act review: how EU countries are tightening restrictions on ads and why the UK should too. The Conversation. UK.

The challenges of regulating online advertising

The core challenge lies in the fundamental differences between online and offline marketing, rendering our current regulatory framework, rooted in the offline world’s regulations from the 1960s, inadequate and unable to work efficiently.  Online marketing presents distinct features that require tailored regulations, and I’d like to highlight three crucial differences:

Firstly, the advent of “targeted ads” – enables incredible precise demographic targeting, surpassing traditional marketing capabilities. This enables brands, for example, to show ads only to males, age 18-25, that play football, and follow sports-related accounts online. This targeting far exceeds the possibilities of traditional marketing, and if not restricted, could enable gambling brands to focus their marketing communications on young and vulnerable audience – who, from a business point of view, is the most lucrative audience.

Secondly, the transient nature of online ads, such as “stories” or paid-for ads, poses a challenge to accountability.  Unlike TV commercials with a centralised database were ads are stored, there’s no mechanism to store and monitor online ads. Once they are gone (e.g. after 24h for stories, or after being deleted by the account) – they are gone!  So, how is this policed?  Currently, we are mainly relying on users to report potential breaches.  This means users need to act quickly when encountering a suspicious gambling ad, screenshot the ad, and finally, report it the Advertising Standards Authorities.  However, I don’t think many people do so.  But, what this means, is that the lack of policy in place to deal with this systemically, has created a “dark space” where advertising may go unchecked. In other words, I believe, that neither researchers, policy-makers nor enforcement officers at the ASA have a clue of what is actually happening out there, as we do not have the provisions to monitor it.

The final challenge stems from the unprecedented volume of online and social media advertising.  With 1 million unique UK gambling ads on Twitter alone, the sheer diversity of content makes policing and monitoring a daunting task. With AI coming into the mix – as Edoardo Tozzi has shown – this might make things even worse.  So far, gambling brands’ main costs in creating their 1m ads per year has been paying for their staff to design them.  Now, with AI being able to create ads within seconds, soon we might not see 1m ads per year, but 10-times or 100-times as much – there is virtually no limit.  And no policies in place that would protect us.

So, where are we going from here? 

Well, first of all, I believe we need to start accepting that online marketing is so fundamentally different, that our old laws and regulations don’t work. What should follow is the introduction of online specific marketing regulations.  However, I also believe that we need to start facing an uncomfortable truth: we need to start regulating the volume of (gambling) marketing, as opposed to solely focusing on the content.  Because even if the 100m AI-generated ads adhere to all regulations, do we really want to see our world plastered in gambling ads?

Reposted from the University of Bristol Business School blog