Rob Mabbett delivered the keynote speech at the KnowNow Player Protection Forum 2023. His speech was titled: “Vulnerable customers – where are we now?”.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
OPENING STATEMENT
My sincere thanks to Adrian, Neil, and Matthew for inviting me to speak at this year’s Player Protection Forum.
I attended my first KnowNow event back in 2019 and they have always been such a valuable source of education in a sector that can often be quite complex. I personally had to learn very quickly, coming from working as an operator in betting shops thinking he knew what he was on about, to working with some of the most severe cases of gambling addiction in the country with Gordon Moody, the curve was steep and KnowNow has provided such a valuable source of education and knowledge. Not only does it bring expert insight through its contributors but I always feel we are amongst friends at these events and able to discuss challenging issues freely.
I always learn about something new at a KnowNow event and yesterday was no exception, I learnt about Natural Language Processing through Paula and Daniel‘s presentation on AI, I learnt about the history of tech’s role in consumer protection and its future potential from Simo as well as the Gartner Hype Cycle, and we were all given a terrifying vision of the future from Nick and Paul who were actually five hours in the past in New York. I jest of course but they do provide a compelling argument that we will adapt to blockchain technology in the near future even though many of us find it so hard to comprehend at present.
We also touched on vulnerability a topic that will be explored more today.
VULNERABLE CUSTOMERS
I had the pleasure of meeting a health improvement officer from Wolverhampton City Council last week who visited our services in Dudley as part of his research in completing a gambling needs assessment for the area and setting up a strategy within the council to prevent gambling harm.
Wolverhampton is a fine city and in my time at Gordon Moody, I have come to think of the West Midlands as a second home. But it is an area that has more than it’s fair share of social and economic challenges. Wolverhampton has the highest alcohol-specific mortality rate within a one-year range in England. It has an IMD score of 32.1, placing it in the highest 10% of cities in England in deprivation. So it comes as no surprise that gambling is on the radar of the council.
In terms of prevalence, a recent lifestyle survey in Wolverhampton showed that 16% of adults regularly gamble, which in comparison to national statistics is fairly low, but of those that completed the survey, 1.5% classed themselves as moderate gamblers and a further 1.5% classed their gambling as problematic. In comparison to the recent UK Gambling Commission Data, which suggests just 0.2% of the population are affected by gambling harm, but this seems high and worthy of attention.
Of those whose gambling was moderate to problematic, 28% related their gambling to alcohol and of those whose gambling was moderate to problematic, 55% gambled predominately online whilst 45% gambled predominately offline – a much more even split than we are probably led to believe with the rise in online gambling in recent years, although I am led to believe from the latest issue of Coinslot International, there has been a recent uplift in offline gambling.
LICENSED PREMISES
With these numbers in mind the question was put to our guest by one of our colleagues, “Why are so many licenses for gambling establishments granted?”
This was a fair question and one that our guest answered honestly. He stated that there are 38 licenses in Wolverhampton, compared to 36 in nearby Dudley, but is way below a staggering 74 in the district of Sandwell – which covers a considerable but not huge area between Wolverhampton, Dudley and Birmingham – and Birmingham itself, being a major city, has an abundance of gambling establishments.
Of those 38 licenses in Wolverhampton, 11 are situated in the St. Peter’s ward, according to our guest the area in Wolverhampton with the highest deprivation. It was also the opinion of our guest that the most successful establishment in this ward was in the Avion Centre, which was the most deprived area in the ward. In comparison more affluent areas of Wolverhampton such as Tettenhall Regis and Penn have no gambling establishments at all.
Whilst the granting of licences was not the department of our guest, he did raise the thought that should we have such access to gambling where we know there are vulnerable people? Is cutting off the supply the best way to protect the vulnerable? We will revisit the questions raised from that meeting at the end as what I am about to speak about formed much of our discussion last week.
MOVING THE NEEDLE
The ongoing wait for the Gambling Act review white paper continues to leave us in the dark or, at the very best, a dimly lit room regarding the governments intentions around the regulation of gambling in the UK. As many of you will be aware through various media in the past few weeks, there has been a lot more content as various stakeholders make a final push to move the needle in the direction they want the review to go.
On one side there are those pushing for the needle to move in favor of less regulation or at least damage limitation – citing the millions of people that gamble safely as an enjoyable pastime and being advocates of freedom of choice. On the other side, we have calls for gambling to be heavily sanctioned in the interest of public health, that the government needs to intervene to protect those most at risk of gambling harm.
This is not unusual for a government of course as they will debate this across many issues and products and getting this balance right is important, not just for the safety and well being of the public but in terms of the image of the government. Too liberal and the government is seen as uncaring and greedy, too restrictive and the public claim we live in a nanny state.
What is not helpful, this is how polarised the argument has become. Inaccurate claims and false figures from both sides only lead to a distrust and serve to increase the stigma around gambling and seeking support when gambling becomes an issue. There is a lack of debate in some quarters where not agreeing with a point of view is seen as being directly opposed to it. Are you in favour of banning all gambling sponsorship in football? No. Ah well then, you must be in favour of all gambling sponsorship then? No, of course not, let’s have the debate.
LOSING SIGHT OF THE CUSTOMER
It is my opinion that in these efforts to move the needle, we are in danger of losing sight of the customer. After all we can come up with a whole range of measures to prevent gambling harm but if we don’t engage the customer, what is their effect? How are we meeting the objective of the gambling commission – which is to protect the young and the vulnerable – if we are alienating them by stigmatising an already heavily stigmatised sector? It is counterproductive.
Statements such as, four legs good – two legs bad, referring to the levy for horseracing being bigger than the funding for research, education, prevention and treatment of gambling harm, do not help. Especially when the figures of £80 million for horse racing and £20 million for RET are wrong.
PUBLIC HEALTH ISSUES
So where are we at when it comes to vulnerability? Identifying and protecting those who may be more likely to be affected by gambling harm?
In recent years we have seen advertising bans, the restriction of sale, and the stigmatisation of tobacco – a product that has been proved to be so harmful to your health that the government feel they must act in the interest of public health. Whilst there was a counter to these arguments, albeit a weak one with the money raised in tax through smoking, the effect is that fewer people now smoke compared to previous years, although the increase of vaping thought to be a healthier option is staggering and one that is seen as a tobacco substitute.
We have seen the debate around sugar vs. fat and which one is worse for our health. The introduction of a sugar tax on fizzy drinks as an output from this, is again an act in the interest of public health and one seen to ease the burden on our health system.
When it comes to alcohol, we have settled on a unit system which helps the government to advise on the safer levels of consumption. But what about gambling?
GAMBLING HARM
There are no gambling units per se, certainly not from a health perspective in the way that a hundred units of alcohol per week will inevitably cause harm to a person regardless of their status. It is extremely difficult to assess what is a safe level of consumption for gambling or how vulnerable a person is financially. A hundred pounds a week spent on gambling can have a wide varying impact on someone from being severely harmful to not harmful at all.
Affordability checking is one way of addressing this but it is a very individual matter and one where we need a single customer view to be able to truly assess each individuals case. With the exception of young people, where the 18-25 age bracket is seen as a more vulnerable group and many operators have introduced mandatory limits, a safe level of gambling from a health perspective – a gambling unit – does not exist and blanket restrictions would not only run the risk of alienating customers. But more importantly, would make vulnerable customers less visible by pushing their gambling activity underground.
We talk about safer or responsible gambling. There is no such thing as safer or responsible smoking and there are no physical illnesses that are a result of gambling in the same way that type two diabetes can be a result of a poor diet. Gambling is unique and as a result the prevention of gambling harm is unique, it has it’s own challenges that we must understand to be able to prevent it. For us to be able to do that we must have our eyes on it, it must be visible through well regulated platforms with clear and accurate data available to inform our decision making and ultimately to inform policy.
Gambling is a problem if it causes a problem – I think we are all aware of that and to simply move the problem elsewhere by over regulation, alienating customers and stigmatising the product does not act in the best interests of those who may be vulnerable to gambling harm.
And gambling can cause a huge amount of harm, not just financially but indeed physically too. Evidence of this can be seen by the images of those pre- and post-treatment at Gordon Moody, as well as other treatment providers. It may not be as obvious as substance abuse and often people will know that something is wrong with their loved one but they will not think to connect it to gambling. The person affected will more than likely want their loved ones to think it is anything but gambling such is the stigma around the subject.
We talk a lot about vulnerability but in my time at Gordon Moody I have been amazed at the resilience of those who have entered our care and what they have endured during active addiction. The lengths they have gone to keeping their gambling secret is heartbreaking and it is so important that along that journey, in those moments of vulnerability that present us with an opportunity to act, we need to have the information, the tools, and the skills to do that. The missed opportunities from the experiences of those with lived experience are many and it is important we learn from them.
MENTAL HEALTH
Gambling also takes its toll on peoples mental health. At the severe end of gambling harm, the majority of people who apply for treatment at Gordon Moody will have a pre-diagnosed mental health condition. This could be depression, anxiety, bipolar disorder, but many more who experience gambling harm will have a mental health issue that is yet to be diagnosed.
Celebrated physician, addictions expert and author Gabor Mate claims there is no addiction without trauma and that we should not ask why the addiction but why the pain. This is something we need to take note of and the language we use is massively important. We have fantastic technology at our disposal to identify harm, or even the potential of harm, but it is our language and how we interact and how we allow someone the safe space to be vulnerable that will ultimately bring results.
Gambling is a problem if it causes a problem, not the person. We see often that those who seek help for gambling addiction with Gordon Moody have used gambling to self medicate or to distract them from another issue in their life, we need to be sensitive to this.
IDENTIFYING RISK
Identifying those that are at risk and may be vulnerable to gambling harm is not easy but we have our eyes on it. We have our eyes on it and we need to keep that focus to ensure we are minimising gambling harm and protecting those who may be vulnerable. It is not sufficient to say that everyone can be vulnerable, by taking this approach and moving the needle so far over we are moving a problem that we are capable of tackling somewhere else. Addiction will find a way either through unregulated gambling or through another outlet or substance that people will use to self medicate or take away their pain.
RESTRICTIONS
Restrictions on our freedoms or on our choices, unless absolutely necessary in the interest of public health, have an impact on the mental health, wellbeing, and indeed the vulnerability of the population. The impact of the pandemic taught us that this had a huge negative effect on our wellbeing. When the lockdowns first began our most vulnerable group where those in recovery. Our ex-service users spoke of the feelings of anxiety and concern that their recovery collateral had been compromised. Activities that they would enjoy to support their recovery or in person visits with people who supported them became prohibited and their fear was that they would relapse.
Being able to express these feelings, to be able to be vulnerable, allowed us at Gordon Moody to take action. Regular groups were set up, a network was built to support one another because we were able to have our eyes on the issue and react.
CURRENT CLIMATE
Further to the pandemic, we really have been rolling with the punches when it comes to issues and crisis in our society, the impact of Brexit, political turmoil, strike action, war in Europe with people fleeing their homes for a place of safety, the fuel crisis leaving people with the desperate choice of staying warm or eating, the spiraling cost of living limiting our freedom due to financial means, and although for some not having that meal out or that holiday is small beer compared to those in poverty. the impact across the population is profound. Less choice and restrictions on our freedom all contribute to our combined wellbeing, making us more vulnerable as a society.
WHITE PAPER
So what can we do? We need to be aware of the issues around us, we need to be sensitive to the needs of our customers, and we need to understand the sector that we work in which is gambling. Not tobacco, not alcohol but gambling and as a regulated sector, we collectively need to have our eyes on it. Taking that list into consideration, it is understandable how the review of the gambling act remains delayed but at a time when we can clearly see the risk of increased vulnerability across our population, it is vitally important that the white paper is released so we can move on.
Already since the initial call for evidence in 2020, we have moved on and learnt so much about vulnerability and how it relates to gambling harm. At Gordon Moody we only started reporting on suicidal ideation, mental health, dual addiction and criminal activity in 2020 and already we have seen changing trends from the rise in mental health diagnosis of those that apply, to a spike in alcohol misuse during the pandemic and the recent rise to 40% of our applicants being involved in the criminal justice system as a result of their gambling.
New services have been set up such as our complex case pathway in collaboration with GambleAware and Adferiad recovery, which has seen people finally get the support they need when battling multiple addictions and severe mental health issues. We have launched a women’s residential programme which has addressed other vulnerabilities that we had not encountered before such as domestic violence and sexual abuse.
Evidence that as a sector we are moving on and acting on these issues because we see them. Our women’s residential programme will be fully commissioned from April such was the success of the pilot but up until then this project has been fully funded by contributions from the operators and we thank the BGC and their members for their support.
MAKING PROGRESS
Data is telling us we are making progress. The record low figure of 0.2% of the population experiencing moderate and problematic gambling issues should be celebrated but instead, and rightly so, it is met with skepticism. This is because we don’t talk about how we got to this figure and this is a huge missed opportunity. We need to evidence the journey and show our working out otherwise the data has no meaning.
The number of those accessing treatment has fallen in the past couple of years according to NGTS data but we must take into account the last year will not include some of the NHS data with them pulling away from the national gambling treatment service. We are seeing more complex cases and have created provision for them and as a percentage based on the prevalence of gambling harm, the percentage of people accessing treatment has increased from 2% to 5%. This is on the assumption that everyone who scores moderate to problematic on the prevalence survey needs treatment – which I do not believe to be true – but in relevant terms we are seeing an increase in those that need treatment accessing it and the provision of treatment being made available for those who had little to no treatment option before. This should be celebrated.
LOOKING TO THE FUTURE
Let’s go back to Wolverhampton. We have identified vulnerable groups in challenged areas, do we simply turn off gambling in these areas? Would those people find other ways to gamble and would we just be moving the problem elsewhere? I think as a sector we can do better than that.
I recall during the lockdown of 2020 I was called by my local radio station, which is in Hull East Yorkshire, asking me for my comment on the fact that Hull had the highest Google searches for online gambling – at a time when offline gambling was unavailable due to the restrictions. So there was some truth in the premonitions that online gambling would increase during the pandemic but it was not the disaster that was predicted by some parties.
So, do we need to restrict the freedom of choice in the interest of public health when it comes to gambling? Or, with our eyes on the problem can we continue to work collaboratively to reduce gambling harms. In which direction would you move the needle?
