Memorandum submitted by the Methodist Church, supported by Churches Together in Britain and Ireland, The Salvation Army and the United Reformed Church (Church and Society)
SUMMARY
This submission is made on behalf of the Methodist Church, and is supported by Churches Together in Britain and Ireland, The Salvation Army, and the United Reformed Church (Church and Society). Other denominations will be making similar submissions.
Many of the Government's proposals are welcomed, including proposals for a single regulatory body, the strict regulation of British on-line gambling, and the centrality of social responsibility to the deregulation of the gambling industry.
However we have a number of concerns regarding the social impact of other proposals, particularly on children and other vulnerable people.
We are particularly concerned by:
(a) the proposal to allow the continuation of ambient gambling for children
(b) the definition of "amusement" machines as safe for children without evidence to support this claim
(c) the proposal to allow alcohol to be served at gaming tables
(d) the dropping of membership requirements at casinos and bingo clubs
(e) the potential for the speed of deregulation to outstrip the regulatory capabilities of the new Gambling Commission
(f) the apparent understanding of social responsibility as being primarily reactive rather than preventive
INTRODUCTION
The Methodist Church has welcomed a number of the changes proposed by the Government. After 30 years of piecemeal legislation and significant advancements in technology, it is only sensible to bring the regulation of gambling together under a single regulator. Given the phenomenal growth in online gambling sites, we feel that the licensing of British online sites with high standards of operation will provide better protection for players.
The Methodist Church has around 330,000 members and 6,100 churches across Britain. It has traditionally taken the lead amongst member churches of Churches Together in Britain and Ireland (CTBI) on issues around the social impact of gambling, and was part of a CTBI delegation to give evidence to the Budd Review. The Methodist Church also made a substantial response to the Gambling Review Report. Whilst some Methodists refuse to take part in gambling, the Church as a whole is concerned not with general prohibition but effective regulation to minimise the harm that gambling can cause for some people.
Therefore, although we discuss issues such as gaming machines and casinos in this written evidence, this is in the context of the last of the Committee's terms of reference — the social impact of the changes proposed.
CHILDREN AND SLOT-MACHINES
Slot-machines have been shown to be a very addictive form of gambling. They are highly interactive, they involve rapid re-staking and therefore there is a temptation to chase losses. GamCare, the gambling concern charity, states that over half of the calls to their helpline come from people whose problems relate to gambling on slot-machines. And yet we allow children to play on them.
Research by Sue Fisher, formerly of the University of Portsmouth, has suggested that a worrying number of 12-15 year olds — around one in 20 — already demonstrate behaviour which classifies them as "problem gamblers" on slot-machines. Their behaviour — which includes lying and stealing, disrupted relationships at home, and distracted behaviour at school — impacts on the children, their families and those around them.
Both the Gambling Review and the Government have taken on board the concerns about children and slot-machines. We welcome the principle behind the proposal that premises to which children have access (such as areas of pubs to which children are admitted) should not have the higher value gaming machines, although we wonder how this will be supervised in practice. We welcome the proposal to submit clubs with high value machines to inspection and regulation. We are also pleased to read that the Gambling Commission and local authorities will be required to ensure stricter enforcement of minimum gambling age limits, but point out that sufficient resources will be needed to allow this to be effective.
However we still have grave concerns about the Government's proposals for children and slot-machines. We warmly welcome the commitment that children should not be allowed to use the 30p stake/£25 prize machines, and that lower stakes and prizes should be frozen. However we are nevertheless disappointed firstly that the Government is intending to allow "ambient" gambling by children to continue, and secondly that it is attempting to create an artificial distinction between higher and lower value slot-machines.
The Gambling Review proposed that children should be prohibited from using most slot-machines, the removal of slot-machines from unlicensed venues such as fish and chip shops, and that there should be a review in five years time with a view to banning the use of slot machines by all under 18s. We believe that existing research (eg 3.2) already suggests the extent of the dangers posed by slot-machines, and argued in our response to the Gambling Review that the situation therefore merited an immediate review. Depending on the results of this research, a ban on the use of slot-machines by children should then follow.
The Government however has decided to allow the continuation of "ambient gambling" with regard to slot machines — gambling in places where it is incidental to the core business activity. Subject to local authority agreement, unlicensed venues such as take-away restaurants can continue to have lower value slot-machines and these can be used by children.
The Government has justified this move by attempting to make a distinction between "amusement" machines with a maximum stake of 10p and maximum prizes of £5, and "gambling" machines with higher stakes and prizes. It argues that, since the "amusement" machines barely involve gambling, they are suitable for children. There is clearly a distinction of scale between the two categories, but the argument that this makes gambling "safe" for children is erroneous. Even with a 10p stake a child can get through £6 in 10 minutes. And for a child with a few pounds pocket money a week, £5 is an appealing prize. "Trivial" amounts for adults may make gambling attractive for children. The Gambling Review specifically rejected the argument used by the Government saying "The stake and prize may affect the degree of financial harm caused to the player, but the game is the same as gambling for bigger stakes and prizes, and for some children it will be addictive." We are concerned that the positive measures proposed by the Government in other areas will be undermined by the disingenuous attempt to present small-scale gambling as safe for children.
In A Safe Bet for Success, the Government states "gaming machines and children should not mix". Despite having accepted this principle, the Government creates its own definition of what constitutes a gaming machine without indicating any evidence. The Government should not argue that slot-machines are "safe" for children when there is no research to back this up. The research that has been done suggests the opposite. We believe very strongly that children should not have access to slot-machines.
Some people argue that slot-machines are necessary to the survival of the traditional arcade, and that children can learn about gambling within these safe, family environments. Firstly arcades already contain many games which do not involve gambling — including machines which test racing, dancing or physical skills. Few arcades are truly "family" environments, but rather places where children can be left. Children do need to learn about the pressures and potential harm of gambling, but arcades are not the place to do this. This learning is better encouraged within a structured environment such as a school or youth club and using resources such as those produced by GamCare.
Research carried out for the Gambling Review showed that the general public disapproves of "ambient gambling" and of the machines that the Government wishes to redefine as "amusements". Two-thirds of people surveyed for the Gaming Review Report said they would like to see none or fewer fruit machines in places like cafe«s and taxi cab offices. In a MORI survey 42 per cent of people disapproved of children playing on the £5 prize machine, and a further 41 per cent only approved of children playing on them if accompanied by an adult. The Government seems to be going against the public will.
Gambling is an adult activity. As Sue Fisher argues, "Controlling one's response to gambling requires certain life skills which are likely to be underdeveloped in children and young people."
ALCOHOL AND GAMBLING
Both the Gambling Review and A Safe Bet for Success rightly make much of the importance of social responsibility within the gambling industry. We warmly welcome the proposal that the Gambling Commission should produce formal codes of social responsibility, as well as the start made by the industry in setting up the Gambling Industry Trust.
However social responsibility has to be about the proactive prevention of harm, rather than just picking up the pieces after the damage has been done. It is about the policies and procedures that minimise the harm that gambling does to some people. We are concerned that some of the proposals may actually increase the addictive nature of gambling.
One of the principles of gambling regulation is that alcohol and gambling should not be mixed. The Gambling Review stated "We believe that these risks [of increased or excessive gambling] justify our conclusion that the opportunities to mix gambling and alcohol should not be increased". The Review and the Government have both confirmed the intention not to allow gambling in pubs or alcohol in betting shops.
However it is proposed that casino customers should be allowed to be served drinks at the gaming tables. Customers may already consume alcohol in casinos, but are required to remain at the bar. We are concerned that this proposal will reinforce problem gambling.
Casinos rightly say that it is not in their interests to have customers who are drunk. But inhibition is lowered well before drunkenness is apparent. Alcohol makes people gamble more, and gamble less wisely, and serving alcohol at gaming tables is not likely to encourage either wiser gambling or more responsible drinking.
Secondly requiring casino customers to go to the bar if they want to drink forces people to take a break from gambling. This can act as a "reality check", pulling people out of the trance-like state that can occur during a gambling episode, and giving them the chance to decide more rationally whether they wish to carry on gambling. If they remain at the table during this time, this reality check is less likely to occur. The people most likely to be damaged by this measure are not the hardened gamblers, but those who are on the cusp, who have the potential to become problem gamblers.
Therefore we would argue that areas where drinks are permitted should be sited well away, not only from gaming tables, but also from slot-machines, where reality checks are also vital. This is equally true of the proposal to install ATM machines. Requiring people to leave the game in order to withdraw more money gives them a chance to reassess their position.
HARD GAMBLING/CASINOS
Casinos are one of the "hardest" forms of gambling, and therefore it has traditionally been accepted that they require more rigorous regulation. The Government accepts that some regulation is still necessary, but opens the way for significant growth in the casino sector.
The perception of gambling within society has certainly shifted during the last few decades from toleration to mass participation. Much of this, however, has come about because of the role of the National Lottery. We would question whether wider participation in a lottery means that people are ready for the proliferation of "hard" gambling. The Gambling Review stated that a growth in gambling was likely to lead to a growth in problem gambling. We believe that this is unacceptable. Until there is clear evidence of the impact of increased gambling opportunities, deregulation should proceed with caution, and with regular monitoring.
The removal of the casino regulations concerning permitted areas and the demand test is likely to result in an unprecedented growth in the number of casinos. The quantity of new casinos must not outgrow the capacity of the embryonic Gambling Commission's ability to regulate them effectively. The current proposal to restrict this expansion by only allowing casinos above a certain floor space is not guaranteed to achieve the aim of controlled growth, and indeed the minimum proposed may need to be increased. Therefore there should be some mechanism to restrict the proliferation of new casinos in the first few years.
The Government proposes the removal of the "24 hour rule" which requires people to become members 24 hours before attending a casino or bingo club. The aim of this relaxation is to allow casinos and bingo clubs to become far more accessible places. However we have concerns about encouraging impulse gambling, which removes the delay during which people can reflect on their condition and what they can afford to lose. The Government has said that casinos will still be required to request positive ID from customers. It is important that this ID should also show a proof of age. We also believe that casinos should still be required to run a membership scheme, whereby people's details are registered. We feel that this would be a deterrent to under-age play and to money laundering, and would help people aware of their gambling problems to register a self-ban on themselves. The same should apply to Bingo clubs.
We are also concerned that there should not be a proliferation in the number of high value slot machines in casinos. This is particularly necessary as technology becomes more sophisticated, and games involve "harder" gambling. We agree that they should be in ratio to the number of tables. For multi-player games, each player should count as a machine place.
There has been much talk about the introduction to Britain of so-called "resort casinos". We do not believe that the true economic and social impact of such resort casinos has yet been understood. Evidence from the States and Australia suggests that whilst such enterprises boom, the impact of an effective "walled economy" on existing businesses and infrastructure is less positive, even being called "a black hole sucking money out of a local economy" by one researcher. We would encourage funding to be provided to study the economic and social impact of resort casinos prior to their introduction to this country. If they are to be introduced, national and local government will need to consider creatively the tax structure and planning requirements needed to offset the social impact of deregulation.
ONLINE GAMBLING
We welcome the proposal to regulate tightly the British operators of online gambling sites. The proliferation of such sites even over the past year is dramatic. Research by GamCare has demonstrated flaws in the operation of many gambling sites in terms of allowing under-age play and encouraging excessive play. Sites seeking regulation by the Gambling Commission should not be allowed to proceed until they have demonstrated that they meet various social responsibility targets.
It will never be possible to be totally sure of eliminating under-age play, but requiring registration alongside checking of positive ID, accepting only bank cards available to over 18s, and checks on credit-worthiness would be a good start.
Players should have the facility to ban themselves from certain sites or limit the amount they wish to stake during a certain period. Reality checks, such as clocks, counters, pauses between games or requests for confirmation to continue should be prominently displayed, alongside information about problem gambling and links to helplines.
People with an online addiction of any kind often find that they receive constant email reminders from sites they have visited which can hinder their attempts to conquer their addiction. Sites should be required to have the permission of a registered customer before contacting them. Offers of "free bets" are often made to attract new custom but without confirmation of the age of the person who owns the email address. To avoid promoting under-age play, we hope the Gambling Commission will recommend that online gambling sites should only contact existing customers.
The technology of online gambling is advancing exponentially. It is vital that the Gambling Commission is as technologically competent as the industry.
SOCIAL RESPONSIBILITY
Social responsibility is about the industry taking responsibility for the fact that for some people gambling can be very harmful, and have a damaging impact on people's lives, jobs, relationships and families. It is about putting in place the kinds of policies and procedures that will prevent problem gambling, as well as about funding the treatment of the damage, and researching the causes of problem gambling. It is about business practices as well as about corporate giving.
The gambling industry will need to apply social responsibility both corporately through training and policies, and through the competence of individual employees in applying the standards. Concepts of "customer care" will be crucial and will include an awareness of the potential hazards to children and young people, and to a small but worrying percentage of adults who will develop addictive relationships to gambling.
We expect the Government to make the Gaming Commission responsible for licensing new games. As with the National Lottery Commission, it should ensure that games do not appeal disproportionately to vulnerable people or low income groups. Nor, using the marketing of "alcopops" as an example, should they appeal to children.
There is also the difficult question of the approach of gambling outlets towards problem gamblers. Undoubtedly information about problem gambling and helplines should be displayed in the venue. But while we appreciate that it might be difficult for croupiers to approach a heavy gambler and say "you have a problem", this is not an adequate reason for casinos and other establishments to ignore evidence of problem gambling. Pubs have a responsibility to refuse to serve people who have drunk too much, and banks face the same issue with the people who have the capacity to borrow more than is good for them. A good starting point might be to have staff who are trained to respond appropriately if approached by a problem gambler, or, in the case of large establishments, to have a counsellor on site.
We hope that the industry will work together with the Gambling Commission to examine the possibilities for good practice, which go beyond merely displaying the numbers of gambling helplines. Social responsibility has to become part of the culture of the gambling industry, from the floor to the boards of management.
GENERAL
The Government intends to allow advertising of gambling venues and products as it is hard to justify a total ban on a legal activity. Gambling advertising will have to meet a very strict advertising code. This should include rules against appealing to minors or playing on people's desire for financial reward, and adverts should contain a warning about the dangers of excess play.
The Government has indicated that it intends to follow through the 2001 Home Office consultation on methods of payment. The Methodist Church made a response to this consultation in which we pointed out the importance of compelling machines to require players to make a new "decision" to continue to play at strategic points. We also expressed a concern over the use of tokens and smart cards. Together with chips and bank cards these break the link in people's minds between the real value of the money and what they are spending. Psychologists call this the "suspension of judgement" which "temporarily disrupts the gambler's financial value system" and potentially stimulates further gambling. In the same way that it is easier to pay for a large purchase by "putting it on the plastic" rather than counting out the notes, it is easier to stake and lose large sums of money when you have broken the link with the value of that money. If smartcards are to be used, mechanisms will need to be introduced to ensure that this suspension of judgement is minimised.
We were pleased to see that the Government agreed with the Review Body that NHS mental health services should be prepared to offer assessment and treatment to those with severe gambling problems. However we note that people will have to take their place within mental health services which are already under significant demand. Treatment of problem gambling requires a broad approach blending medicine, therapy and social policy, and requires the training of counsellors and specialists in addition to the funding of "beds". Research into gambling behaviour and addiction is also vital, and this may be an area where NHS expertise could be used.
As the Government's proposals are introduced it is important that their impact is measured, through regular monitoring and a regular National Prevalence Survey. There is also much scope for independent research into gambling behaviour, problem and otherwise. Much of this may be funded by the new Gambling Industry Trust, but we are pleased to see that there will be a reserve power to impose funding requirements on the industry if voluntary efforts are inadequate.
CONCLUSION
There are many aspects of the Government's proposals that we are pleased to welcome. However we are concerned that other measures will not reach the level of player protection, particularly for children and vulnerable people, to which the Government aspires. We would like to see:
— immediate research into the impact of slot-machines on children with a view to taking action if required;
— the maintenance of a ban on alcohol at gaming tables;
— the maintenance of membership requirements for casinos and bingo clubs;
— mechanisms to prevent a proliferation of new casinos or high value slot machines;
— strict regulation of new online gambling opportunities to protect children and those vulnerable to problem gambling;
— a proactive understanding of social responsibility; and
— a demonstrable commitment to social responsibility as a pre-condition for licensing.
1 May 2002
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