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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.
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