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Tuesday, 4 November 2014

Never mind bet now, what about act now? - Looking into the recent ASA review into gambling company advertising


By Scott Longley, Editorial Director, Regulus Insights

‘From those wonderful folks who gave you Pearl Harbor’ (Proposed advertising slogan for Panasonic that came from a brainstorming session and title of book on the heyday of Madison Avenue advertising by Jerry Della Femina)


If there is some good news for the UK’s gambling companies from the Advertising Standards Authority (ASA) review into gambling advertising published late last week, it is that the market research undertaken as part of the process did at least find some evidence of the success of advertising in persuading consumers to bet more often. Yet while this may provide some comfort to gambling’s marketing executives, the true significance of the report is the support it is likely to give to those calling for tougher advertising controls for the industry.

In conducting its review – the first since the restrictions on gambling advertising were relaxed in 2007 – the ASA commissioned its own qualitative research and also added some questions on gambling advertising to the most recent Gambling Commission data omnibus survey in order to obtain some quantitative insights.

The evidence from this second element of the research is illuminating. While an overwhelming majority (90% of respondents) claimed that gambling ads had not prompted them to gamble, the survey did find that there was a higher tendency (20%) among those who had placed an in-play bet to be prompted by a free bet or other promotional offer.

Moreover, there was a “notable spike” among the 24-34 age group where 44% said they had been prompted to gamble by a free bet or promotional offer.

So at least the industry has confirmation that free bet offers work, and is particularly efficacious among a certain age group and with a particular product.

But that’s as far as it goes for positives. Because unfortunately for the industry the evidence that is accumulating around free bets offers and promotional offers means that it has become an area which the ASA is now targeting for further scrutiny.

The review points out that no specific action will be taken as yet - but the industry is at now on a warning with regard to ads in this area.

The ASA review said it would be taking a more proactive approach to this area after the qualitative and quantitative research undertaken as part of the review found that free bet offers and promotions were “likely to appeal to younger people and prompt them to gamble”.

Of the 398 cases in the last year, complaints over free bet offers were the most prevalent. The review said the ASA and Committee of Advertising Practice (CAP) had already conducted a “large amount of work” on this issue and that it will “remain a key priority”. The review continued: “If we spot a problem we’ll be more likely to seek a published ruling so that gambling marketers know where the line is drawn and why.”

This isn’t the only area where the ASA will be more proactive. Specific in-play advertising also came under greater scrutiny in the review, and in particular ads where according to the market research carried out for the review there was perceived to be a link between betting and ‘toughness’.

We don’t need to be advertising gurus to know which ads might be being referenced here. The review goes on to relate one story from the market research of a ‘male, family-stager from the 24-44 age group’ who said of a Ray Winstone ad for bet365: “Ray Winstone is your archetypal geezer – he has respect, he’s no nonsense, strong, firm, direct.”

Such testimony is great news for Winstone’s agent when it comes to negotiating future endorsement and advertising deals but not much good for anyone else. Though the review noted that research participants could “mostly only speculate about the potential effects of bet now advertising”, it went on to say that there was evidence that these ads did have an impact on the group of male gamblers who “confirmed they were motivated by this type of ad”.

As part of its next steps, the ASA said: “We’ll be more proactive on issues relating to social responsibility, especially around ‘toughness’ in ads and particular appeal to children, finding ways to continue to source data to inform our decision-making.”

The focus will now move to the CAP review that is due presumably in a matter of weeks. This will be looking into the rules and regulations that already apply to gambling to see whether they need to be amended or updated.

But with the ASA signalling more intense oversight, it is now more likely than not that industry practice on advertising will have to change. Prior to the publishing of this review, the main operators were already well aware of the disquiet among advertising and gambling regulators over free bet and promotional offer advertising.

The newly-formed Senet Group has already instigated a voluntary code which stops its members from conducting this type of advertising before the 9pm watershed. But at present only William Hill, Ladbrokes, Coral and Paddy Power have signed up to it, and of course this code does nothing about the ‘toughness’ complaint.

It should also be noted that the ASA review included data on the amount of complaints notched up by the individual firms which prove that the four companies mentioned were together the biggest offenders as far as cases of complaints were concerned.

In fact, it is worth commenting that while William Hill (190), Ladbrokes (184) and Coral (82) all feature in the top 10 of most complaints, Paddy Power tops the lot with a whopping 243 complaints since 2006, a total which outgunned even the 206 complaints received by the ASA about gambling ads generally. The old maxim that “All publicity is good publicity” often invoked in defence of advertising controversy, may be coming back to bite.


Department of mischief or not, this is not the best advertising accolade that we’ve ever seen. If the Senet Group is going to have more impact, it should perhaps look to its own members to follow the ASA lead and look more proactively at stoppering the flow of complaints about gambling advertising at source. It might well come to be seen as the best piece of advice that their respective marketing departments have ever received.

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