10 pledge action plan announced

The Betting and Gaming Council (BGC), the new standards body for betting and gaming which covers betting shops, online betting and gaming businesses and casinos, has today announced a new 10 pledge action plan agreed with its regulated member companies, which sets out the standards expected of our members during the Covid-19 (Coronavirus) pandemic.

The 10 pledges build on actions and interventions that BGC members do as part of safer gambling operations, however the BGC will now require heightened monitoring, tailored responses and new action to address the unprecedented situation of social distancing and home working. Although overall gambling has fallen dramatically with the absence of sport and due to the closure of betting shop and casino closures, the BGC’s pledges will come into force immediately to help ensure that the highest safeguards are in place and action is taken to protect anyone betting online who may be more vulnerable as a result of the crisis.

The BGC supported the Gambling Commission, who this week demanded increased consumer protection and responsible marketing. The new pledges demonstrate the BGC’s determination to ensure the highest standards are implemented and cover the following areas:

1. Increase safer gambling messages across all sites and direct to all customers
2. Step up interventions if customers increase time and spend beyond normal pre-crisis patterns
3. Actively promote deposit limits
4. Action to ensure appropriate and responsible advertising including monitoring volume
5. Report all illegal, rogue advertising from black market online operators
6. One-strike-and-you’re-out policy where affiliates breach pledges
7. Signpost help to GAMCARE and the National Gambling Helpline and GamStop for self-exclusion
8. Commitment to ensuring funding for Research Education and Treatment (RET)
9. Welfare checks and well-being help for staff
10. Supporting the Government’s ‘National Effort’ with volunteers and facilities

Commenting on the 10 pledges, Michael Dugher, BGC chief executive, said:

“In this time of national crisis, with so many people self-isolating and social distancing at home, it is vital that we do everything possible to ensure safer gambling and to protect potentially vulnerable or at risk people.

“We all know that levels of gambling have plummeted not just because of betting shop or casino closures, but because of the absence of sport, which is also fundamental to online betting. Although gambling levels have dropped during the COVID crisis, our commitment to safer gambling is being stepped up. It is important that we help our customers stay safe and in control of their gambling during these difficult times. That’s why BGC members have developed a 10 pledge action plan that will help govern members throughout this crisis.

“Increasing safer gambling measures with more monitoring and customer interventions, stepping up safer gambling messages and measures like promoting deposit limits, together with a tough crackdown on affiliates and calling out rogue black-market operators, will make a big difference. We are also signposting professional help and are committed to funding Research, Education and Treatment (RET).

“The betting industry supports tens of thousands of jobs up and down the country, and we are equally determined to support the Government’s National Effort through helping with volunteers and facilities”.

The BGC Member Pledges:

Pledge #1: Members will increase safer gambling messaging across all sites, apps and channels including inbox messaging to all existing and new customers reminding them of the safer gambling tools available.

Messaging is a crucial method of nudging customers into taking actions to remain in control. Actions include using tools that offer customers an important way to set limits and raise awareness of their play. Their prominence in the customer journey should be emphasized during this period.

Operators provide hundreds of thousands of safer gambling messages year-round, from the time of account opening to play. These messages encourage safe play such as setting deposit limits or taking time out from betting. Members are stepping up their messaging including a direct communication to customers reminding them to set a deposit limit. We expect increases in volume and type of messages compared to other communications. We are reviewing with operators their safer gambling message changes as part of our data collection review. Safer gambling messages also appear on the home page of every website.

Pledge #2: Members will implement heightened monitoring and data collection in the knowledge that customers are required to abide by social distancing measures. Any change in customer play patterns, including any increase in time and spend, beyond normal patterns before the crisis, indicates potential markers of harm and operators must step up interventions.

While total gambling has reduced due to no UK sporting events taking place, internal tracking and customer protection systems should be adjusted where necessary to ensure that changes in customer behaviour are identified.

We are collecting data on advertising, patterns of play, behaviour responses to messaging and other measures (such as pauses in play) as part of our ongoing commitment to increasing safer gambling. Currently algorithms which monitor play can be calibrated to identify deviations from typical patterns. This takes into account factors like the payment type, time of play, length of play and product amongst others. Thresholds for interventions are varied but occur across the entire customer journey. Therefore, atypical patterns of play will get picked up by these systems and enable early intervention by the operator. There is no standard of deviation as the metrics must take into account a multitude of variables but operators do concentrate on overall spend. Increased spend levels trigger interventions, which range from messaging to mandatory deposit limits to account closure, dependent on rising risk levels associated with the markers of harm.

In addition, the Gambling Commission, at their request, are being supplied with additional customer and account information to assist with their scrutiny of the industry.

Pledge #3: Members operating heightened monitoring shall actively promote deposit limits and send a deposit limit message with link to the tool to any player exhibiting abnormal patterns of play that are a marker of harm.

The current crisis can lead to changing patterns of consumer behaviour, particularly online. Where companies are aware of customers increasing their play beyond their normal routine, they should ensure this triggers an appropriate response in establishing the customer’s welfare and being prepared to intervene with a deposit limit message or mandatory limit where appropriate.

Deposit limits cannot be removed without the request from the customer, following an intervention by the operator and/or a cooling off period.

Pledge #4: Members shall commit to an immediate and ongoing review of their marketing and advertising – in volume, content and targeting – and will act to ensure it is both appropriate and responsible given the increased risk.

Members should ensure that that gambling is not portrayed as a suitable or desirable response to those experiencing boredom or frustration during self-isolation.

Telephone, text and e-mail contact should not be increased from normal patterns during this period with the exception of promoting safer gambling messaging.

The industry is acutely aware of the risks arising from potential new patterns of work and leisure caused by the current lockdown. As such the industry is determined to ensure that marketing and advertising is appropriate and sensitive to these potential risks.

We have recently introduced a series of measures aimed at advertising including trialling de-targeting technology, creating an industry-wide list for suppressing advertising around certain subjects and a 25+ age-gating function for social media platforms.

Our members are stepping up safer gambling messaging, interventions and initiatives across the board to ensure that any customers betting online are doing so safely. We are also working with our members to examine how safer gambling messages can be given more prominence in all adverts across all channels.

Pledge #5: Members will report to the BGC instances of illegal rogue and inappropriate advertising and the BGC will report these to the regulator.

Illegal offerings and their advertising can be found on the web and are unethical where they seek to take advantage of a customer’s vulnerability. BGC members should report such advertising to the regulator or the BGC who will inform the regulator. This is part of the overall effort to clean up any advertising which is irresponsible and accessible to the UK public.

Recently we have reported inappropriate advertising from illegal operators taking bets as well as affiliates advertising offerings which make false claims about their domicile. The BGC aims to play its part in assisting all action against illegal and rogue advertising.

Pledge #6: These Pledges will fully apply to all affiliates. Members will enforce a strict one-strike-and-you’re-out policy for breaches of these Pledges.

Affiliates provide an important role in providing messaging and responsible advertising to customers. This means affiliates must in no way mention or use the words associated with COVID-19 such as ‘’bored’’, ‘’isolation’’, ‘’stay at home’ ’amongst others. The BGC will collect and provide a list of key words and phrases to members, affiliates and social media platforms to prevent their misuse.

This Pledge covers inappropriate advertising related to Covid-19 which goes beyond regulatory restrictions.

The BGC is also going further in producing a Code for Affiliates which will cover areas such as content responsibility, deeper screening of affiliate advertising and incentives for affiliates.

Pledge #7: Members will sign-post to GAMCARE advice and the 24-hour free to call National Gambling Helpline and GamStop for self-exclusion in their safer gambling messaging, particularly where issues around anxiety or isolation are apparent from monitoring systems or customer interactions.

The industry provides safer gambling messaging to all customers. At this time, it also needs to address issues arising directly from the current crisis. To this end members shall incorporate additional information for customers requiring intervention as part of our corporate responsibility.

The BGC is also highlighting the National Gambling Helpline as part of or messaging around safer gambling. We are consulting with charities to provide us with any data which will inform changes in normal call patterns so we can identify any areas of concern and address them in real-time.

We fully support a mandatory requirement for all UK licensed online operators to sign-up to GamStop and believe that those operators that refuse to do so should undergo an immediate licence review by the Gambling Commission. We are pleased that the Gambling Commission has recently taken action recently against those who refuse to sign up to GamStop. All BGC members have implemented the recent changes (since 1st April) to GamStop requirements which have further strengthened player self-exclusion.

Pledge #8: Members re-state their commitment to maintaining the vital flow of important funding for Research, Education and Treatment (RET).

There are a great many companies and people reliant on our members, many of them small organisations that may lack the resilience to navigate this crisis. This is even more important for charities and organisations that deliver the crucial Research, Education and Treatment services which need to stay available to customers.

We can assure you that we are firmly committed to increasing funding for research, education and treatment (RET), despite the severe financial pressures that our members are under during the covid-19 crisis. While such contributions are voluntary in terms of magnitude, we remain committed to increasing RET contributions over time. Last year the largest operators committed to increasing RET to 1% of GGY, up from 0.1% as provided by guidance of the Gambling Commission.

What is most important to us is that we direct this help to where it is needed as soon as possible. Therefore, our largest members are looking to make this commitment to those organisations that are already approved by the regulator and that are able to quickly scale up existing delivery of safer gambling research, education and treatment.

Over £10 million has been committed to safer gambling education as well as our continued support this year for the BetRegret the public awareness campaign who have received over £3.8 million.

Pledge #9: Members shall conduct welfare checks on employees during this crisis.

Our employees are similarly affected by the same challenges and emotional risks as others. Companies should ensure that they have the mechanisms in place to make regular welfare checks on employees and fulfil their duty of care to ensure their safety and wellbeing.

Pledge #10: Members should play a full part in supporting the Government’s ‘National Effort’ by encouraging staff to volunteer for community service, as well as offering premises where possible for use by those supporting the effort to tackle COVID-19.

For those companies with large retail businesses on the high street, many employees know their customers and for those customers that are elderly, live alone or unable to fully support themselves during this crisis, staff are encouraged to assist where possible. The NHS also has a volunteer service which we encourage employees to volunteer for.The 10 pledges build on actions and interventions that BGC members regularly do as part of the BGC code of conduct; the Licence Conditions and Codes of Practice (LCCP), the 22 new safer gambling commitments set out last year by the BGC and each operators’ own safer gambling operations.