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By Dan Waugh, Partner, Regulus Partners
“Everything should be made as simple as possible, but not simpler.” Albert Einstein
It is a feature of gambling regulation that, while the issues are often complex, public discourse on the subject struggles to rise above the simplistic. Debates tend to be polarised and ‘good stories’ told by both the pro-gambling and anti-gambling lobbies rarely admit inconvenient facts – especially where the matter of gambling-related harm is concerned. Despite the best endeavours of the regulator, evidence tends to be chosen selectively and often manipulated to accord with predetermined theories.
That last year’s Responsible Gambling Trust research into B2 machines gave succour to both the Association of British Bookmakers and the Campaign for Fairer Gambling provides the perfect illustration. The verdict that addressing stake size in isolation was unlikely to fully resolve issues of problem gambling should not have been a surprise to anyone connected with the industry. Previous studies and basic common sense had told us this some time ago. We perhaps should not have been surprised either that both sides would seek vindication in this finding.
In the Gambling Commission’s 2009 ‘Qualitative Survey of Machine Gamblers’, Professor Mark Griffiths set out three dimensions influencing customer behaviour on machines – situational (characteristics of the environment), personal (characteristics of the player) and structural (characteristics of the machine). His study suggested that all three were important in understanding play and problematic play.
So if we can accept that the issue of machines and behaviour is complex and multi-faceted, perhaps now is time to recognise that within our only formal and (at least in theory) regularised review of regulations – the Triennial Review (which is scheduled to return next year).
An expanded review of what types of slot machine are made available in Britain and how (rather than one that limits itself to questions on stakes and prizes), underpinned by a rolling programme of research has much to recommend it. It would contextualise policy discussions on machine regulation by considering factors such as sociability, environment, marketing, access and supervision alongside structural characteristics; it would help the Gambling Commission to deal with new issues (such as current hot topics of skill-based hybrid slots and the proliferation of digital content in-venue) as they emerge; it would put other issues (such as the casino industry’s long-running and so far frustrated efforts to gain an increase in machines) into a formal decision-making process; and it would create a more stable environment for industry investment and innovation.
Anchoring the process with a sustained programme of independent, collaborative and sequential research seems infinitely preferable to the knee-jerk rounds of partisan ‘evidence-gathering’ that has been the hallmark of previous reviews (the fact that the 2013 review resulted in more than 9,000 identical submissions from the betting sector is telling). The Government and Commission are heading in the right direction by insisting that all future submissions should be grounded in evidence – but doubt will persist as to the integrity of studies undertaken by interested parties. An ongoing programme of independent research seems desirable.
It may all sound like hard (and possibly expensive) work but who’s to say it wouldn’t be more efficient and less painful than the current pattern of lobbying and counter-lobbying that characterises the slots debate today? If a portion of the time, effort and lobbyist fees that are currently expended on debating these questions (creating much noise but little in the way of signal) was diverted towards a review such as this, everyone might benefit. The government and regulator would have a better mechanism for dealing with gambling headaches, industry would be able to focus on moving forward rather than defending the status quo and concern groups could shift from a mode of agitation to one of constructive engagement.
Whether it’s too late already to achieve an expansion of the 2016 review remains to be seen; but if we are to gravitate away from our unhelpful obsession with stakes and prizes, we need to start planning today.