Are children really gambling as much as reported?

David Williams, director of public affairs at The Rank Group, delves into the issues behind a reported rise in youth gambling

The below is an excerpt of the speech made by David Williams, director of public affairs at The Rank Group, during this week’s parliamentary discussion titled: ‘Are children really gambling and if they are, what needs to be done about it?’

Are children really gambling, we ask? The answer, of course, is ‘yes’. But what is gambling, what is gaming, what is legal and what is going on behind the statistics quoted with alarm in the nation’s press?

I want to start by setting out a number of findings from the prevalence surveys that have been carried out on youth gambling in this country since 2011.

– First, participation in gambling by children in Great Britain has declined, quite significantly, over the last seven years – from 23% on a past-week basis in 2011, to 14% on the same basis in 2018. The decline is evident for both boys and girls and across all age cohorts studied.

– Second, the vast majority of gambling by children is currently legal. The most popular forms of gambling by children are betting or playing cards with friends and family, and playing low-stake machines. The proportion of children gambling on age-restricted products has fallen from 14% in 2011 to 6% in 2017. We may decide that such activities ought to be banned; in reality, these are matters for legislation and enforcement.

– Third, past-week participation by children in online gambling – according to the surveys – has fallen from 3% in 2007, to 2% in 2011, to 1% from 2016 onwards. The proportion of children playing legal online gambling-style games – activities that the Gambling Commission does not consider to be ‘gambling’ – is three times as high.

– Fourth, reported rates of problem gambling by children declined between 2014 and 2016. It has increased in 2017 and 2018 – as widely reported in recent media, but this is due, in part at least, to significant changes in survey sampling. As the Gambling Commission repeatedly makes clear in its report, data from 2017 and 2018 are not comparable with data from 2014 to 2016.

These facts ought not to lessen our concern about youth gambling; but getting a grip on the facts available to us is critical if we are to address those concerns.

If we are serious about harm prevention, we need to employ a really clear and disciplined framework for the use and quoting of data and statistics. Seeking rigour around how we report the issues is not unreasonable.

And the responsibility for challenging the misuse of data lies far more widely amongst constituents than simply the betting industry who will always carry the label of being out for its own good.

On diagnosis and dosage, we could point to the Advertising Standards Authority’s review at the start of February as a depressing case-study in how polarised things have become. Fairly entrenched elements of the media led with an interpretation that children are exposed to a quarter more gambling ads than a decade ago, whilst others looked to the CEO of the ASA who preferred to highlight that exposure of children and young people to gambling ads is decreasing. What are we left with? Confusion, certainly. Impatience, yes. And ultimately, a muddled picture where we run the risk of eclipsing an important opportunity – to my mind – for the industry to sharpen up its act and practises and, in doing so, accelerate the process of regaining trust and resetting the balance of the debate.

On this, the betting and gaming industry must shoulder its fair share of blame for the binary and polarised climate that we all too often find ourselves in. As an industry we have been far too slow to cotton on to social concerns and public trends, and meet them head-on with intelligent and reasonable solutions. We’re in danger of reducing everything to a “permit” or “prohibit” position; it’s not where we want to be.

Take advertising as an example – it very clearly is in the vanguard of issues exercising those of us who care about children and gambling. What would happen if we banned advertising in its entirety as a leading newspaper columnist demanded earlier this month? Of course it would decrease exposure to children and to vulnerable people, but at what cost?

At what cost to the millions of customers who appreciate choice, and who have benefitted from the 2005 Act which stripped away much of the regulation that had kept a lid on competition? If we simply permit or prohibit, we fail the vast majority of our customers in the middle – adult customers who have fallen silent as the debate has become polarised, adult customers who bet responsibly with regulated operators and who enjoy great choice. Prohibition would weaken the relationship between regulated revenues and vital funding of research, education and treatment, and undo much of the progress we are making. And there has been progress, of course: the whistle-to-whistle ban which comes into effect later this year has been widely welcomed.

And yet we’d be willing to go further if we could. Providing we don’t simply give competitive advantage away to less scrupulous operators, we’d endorse a more robust clampdown on TV advertising around sports. Similarly, a look at the shirt sponsors of many of the top football clubs in the country – an issue often flagged as being of concern when it comes to the normalisation of gambling amongst children – reveals that a large number of the gambling sponsorships are for non-UK facing brands.  Are we really suggesting that large numbers of British children are betting on Asian-facing sites, such as Fun 88? These brands are not looking to target UK customers, but forcing UK-facing brands to comply with regulations whilst other operators are exempt will do little to shift public perception and address key issues. One of my company’s brands, Grosvenor, were the shirt sponsors of Fulham FC until recently – we pulled it within weeks of a new senior management team arriving; there is evidence of proactive, responsible best practice.

I am not looking to deny that sponsorship presents valid concerns in this space – and yet some of these must be soluble. We’re here this evening to work out what we can do. Is it beyond us all to get football clubs, operators and kit manufacturers to sit around the same table and, perhaps, offer kits without those sponsors to allow choice – particularly for parents. Isn’t choice a more appealing solution than censure? I understand that one of the issues parents face with some children once they outgrow youth sizes is that they HAVE to buy small-adult size kits. Can’t we change the sizes of these kits? Do we always have to complicate issues when solutions might be under our noses? The football clubs and the manufacturers ought to be joining discussions like this.

Returning to the core question of whether children are gambling. They are certainly video gaming on smartphones, consoles and computers. Loot boxes and skins have entered our lexicon, and in-app purchases are evidently part of the gaming landscape for some young people. For me, this is where the video gaming industry rather than the gambling industry needs to be working harder than ever to combat malpractice and irresponsible design. We all need to wake up to the fact that our children are quicker than us when it comes to embracing technologies, and necessary research must be done to get a sense of the scale of the issue and to put in place the appropriate levels of protection. Perhaps I would say this wouldn’t I, but I do believe that enlightened and responsible operators are investing in safer gambling and finding technology-led solutions to some of the issues we face, whilst video game developers are held to a lower level of scrutiny. That’s not a whinge – it’s a call for action.

And just as I caution against a binary debate around prohibition, nor do I think legislation alone is the answer without, at least, a degree of self-regulation. Indeed, if operators adhere only to the law we could see a landscape where children are welcome in bingo halls. That is the law – a law that we, as operators, choose to supersede with what we consider to be the right thing to do; we have a strict over-18s only policy. Similarly, across our casino estate in this country we operate a Think 25 policy; legally it is only required to be a Think 21 policy. I’m not looking for a round of applause, but am I am keen to contest a narrative which suggests that responsible operators are not self-regulating.

I don’t deny that there is more to do and that the industry has failed to grasp some nettles quickly enough, but I think it would be wrong to assume that at every opportunity the industry looks to bend itself around the law or the regulator to exploit gaps. We need to restore normal order to the discussion, shake off the remaining minority who are resistant to change, and work together – with the regulator, with parliamentarians and with technology providers, amongst others – to better protect children from the worst excesses of a wider gaming landscape. To do that, we must take ourselves away from the extremes of a debate, and in doing so, we stand a better chance of making the progress that every single person in this room surely wants to see delivered.

David Williams | Regulation | The Rank Group | UK | Underage gambling