APPENDIX 10
Supplementary memorandum submitted by GamCare
1. GAMBLING AND CHILDREN
1.1 All gaming machines have the potential to cause problems for the gambler. GamCare does not say that children are "safe" when playing AWP machines but we acknowledge two important factors:
— encouragement to sample an adult activity under responsible adult supervision generally provides a positive learning experience;
— the Amusement Centre has traditionally provided AWP machines with stakes as low as a penny. Whilst all reel based machines have a potential to induce addictive behaviour there is little evidence that these low stake AWP machines are a cause of significant harm to the younger age group.
1.2 GamCare, in discussion with the Gaming Board, Home Office/DCMS, and the machine sector of the industry have taken a pragmatic stance with regard to AWP machines. The charity has accepted that machines with a maximum 10p stake and £5 cash prize could be classed as "trivial". However, in order that they remain very low stake/payout machines we see it as important that these levels remain frozen.
1.3 In our written evidence we addressed this issue at 6.4.6 and 6.5.17 drawing a clear distinction between siting AWP's in an unsupervised retail outlet as against the comparatively well supervised Arcade. We also referred to adult supervision having an affect on spend.
1.4 Government Proposals should reinforce the social responsibility requirement on operators of Amusement Centres that will also be expected to comply with Local Authority and Trade Association guidance. For example many Local authorities demand children be excluded from these establishments during the school term which goes further than BACTA's exclusion during school hours. It would not be possible to place a similar entry exclusion on children going to a fish and chip shop.
1.5 It is true that the majority of problem gamblers develop the habit whilst children and this age group are in general particularly vulnerable. However, it is not possible to prevent children experimenting with gambling as there are many opportunities to place private bets, play "penny up the wall", join a game of cards etc. These are uncontrolled and, therefore, potentially more dangerous to young teenagers. As children understand and are adept with modern technology they are attracted to machines and means of communication such as the Internet. As it is not possible to prevent access entirely it is better to restrict it to supervised environments, enforce controls and put the onus on the industry to act responsibly. Alongside such measures should be education to better inform children and disabuse them of the notion that gambling is "easy money". Demonstrating that a formal code of social responsibility has been introduced should become a licence requirement for an Amusement Centre operator as well as for someone who runs a Gaming Centre.
2. PARENTAL INFLUENCE
A distinction is needed here between problem gamblers and social gamblers. Certainly the evidence suggests that a significant number of family members of problem gamblers had a problem themselves. This is part of a common dysfunctional pattern and quite different from the majority of parents, who may or may not gamble socially, who can safely teach their children how to gamble for enjoyment in moderation. Restricting the opportunity for a child to gamble will not prevent a parent or relation introducing them to the activity if they are determined to do so.
2.2 It is crucial that the promotion of responsible gambling and the dangers of uncontrolled gambling be included in the curriculum of secondary schools and tertiary colleges. GamCare undertakes this task with some success but funding constraints limit the extent of this work at present. We strongly believe that this harm prevention education is interdependent with treatment and should not be given a lower priority. We are, therefore, concerned that the Gambling Industry Charitable Trust (GICT) has given this essential aspect of a healthy approach to gambling less emphasis than treatment. The importance of education is supremely important not only to highlight dangers but to inform young people how they can enjoy gambling without problems.
3. VOLUNTARY FUNDING
3.1 The demand on GamCare's services is already beyond its incoming resources. The GICT has made a good start but the amount it has given GamCare for this financial year (April 02-March 03) at £311,250 only represents 43 per cent of the expenditure forecast of £726,000. This is similar to the percentage raised from direct industry donations prior to the formation of the Trust. If the industry are serious about responding to the government proposal of an annual, initial, figure of £3 million overall, we would expect a greater contribution from this source.
3.2 GICT has recently said that it expects to raise £800,000 and that 90 per cent has already been committed. A point that needs to be clarified with the Trust is whether the period referred to for raising this amount is twelve or eighteen months. If the former the Trust is clearly finding it hard to meet the target and if the latter, it is clear that the Trust are not able to attract sufficient support from the gambling industry to achieve required levels. Should this prove to be the case there appears little hope that the voluntary funding scheme will raise sufficient money to properly support social impact initiatives. GamCare is, therefore, increasingly of the view that a statutory, or obligatory "voluntary" levy will be necessary and should be introduced at the start of new regulations if not before.
3.3 GamCare endeavours to respond to the social impact of all gambling products but focuses more on those hard gambling activities. Our care service provision makes no distinction and will respond to everyone affected by a gambling dependency regardless of what activity(ies) has caused the problem. Financial constraints are currently restricting care service delivery in a number of ways, the most serious of which are:
— the inability to reduce the number of missed calls to the national helpline because the number of lines we can keep open is currently restricted to two;
— delay in developing face to face family counselling, attracting female problem gamblers to counselling, and developing work within Young Offender institutions; and
— improving the control and response to problem gambler need with our addiction agency partners across the UK.
3.4 Increasingly there is a need to focus on e-gaming developments as problems through gambling on the Internet are beginning to show in our statistics and because GamCare is endeavouring to set standards of social responsibility in this area. Currently the Education Officer is also addressing e-gaming matters thereby restricting the development of both key areas of harm prevention. Greater resources would enable us to increase staff levels to develop both areas more effectively.
3.5 A further area of restriction is that of training for counsellors. GamCare, as the largest provider of counselling services for problem gambling in the UK, wishes to develop a programme that would become part of a standard course for counselling.
3.6 We are working with the Chinese community but need to extend our work with other significant ethnic groups. Further funding would accelerate this process.
4. BACTA MEMBER CONTRIBUTION
4.1 GamCare is very concerned by the small number of companies that have contributed as it only represents 3.6 per cent of the total. It reflects our concern, expressed above, of the ability of the gambling industry to encourage a sufficient number of commercial operators to contribute enough to a voluntary scheme. Whilst GamCare does not believe any particular sector should necessarily pay more than another, it is the case that gaming machines account for over 50 per cent of calls to the national helpline and globally are known to be a major problem activity.
5. ADVERTISING HELPLINE NUMBER
5.1 GamCare is not convinced by the assertion that calls to the helpline are because the telephone number is widely advertised in BACTA member premises. It is the case that a good number of Centres do display the number but, as GamCare's Care Services Report for 2001 clearly shows (chart 19, page 15) only 1.5 per cent of all referrals identified this source as against 4.1 per cent for the Betting Office leaflet and a massive 66 per cent from telephone directories/yellow pages. In similar fashion to donations, some operators are conscientious about displaying the notices and leaflets and others are not.
6. CAMELOT CONTRIBUTION TO GICT
6.1 Clearly, if the Trust is to be fully effective all commercial gambling operators should contribute. Camelot have consistently been the single most generous direct donor to GamCare. They agree with us that harm prevention and education programmes are as important as treatment. As their products are not a significant direct cause of problem gambling it is understandable that they have a broader focus on social impact initiatives. The GICT has clearly indicated that treatment is its priority at the present time despite the fact that we argue its interdependence with harm prevention. In view of the fact that GamCare has only received £311,250 of the Trust's £800,000 for this financial year, which is 39 per cent of what the industry have contributed to the fund, we are grateful to Camelot for their direct contribution of £50,000.
6.2 Until such time as a effective value for money alternative service is available we would argue in the strongest terms that GamCare should be properly resourced to develop, what evidence supports is, an excellent service to the community.
June 2002
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