Memorandum submitted by the Evangelical
"In the world of sport all men win alike
but lose differently; and so gamblers are rated,
not by the way in which they win,
but by the way in which they lose.
Some men lose with a careless smile,
recognising that losing is a part of the game;
others curse their luck and rail at fortune;
and others, still, lose sadly; after each
experience they are swept by a wave of reform;
they resolve to stop gambling and be good . .
Those in the first class are looked upon
Those in the second class are merely commonplace;
while those in the third are regarded
James Weldon Johnson, The Autobiography of an
Ex-coloured Man, 1912.
The Evangelical Alliance, which was founded
in 1846, is the umbrella body which brings together Britain's
one million plus Evangelicals. The Alliance exists to promote
unity and truth among these churches, individuals and evangelical
organisations, and to represent their concerns to the wider world
of the Church, State and society.
The Evangelical Alliance broadly welcomes the
Government proposals to reform gambling regulation in this country
and in particular the measures to protect young people from opportunities
The Christian Church has traditionally taken
a dim view of gambling. Although there are no specific Biblical
references to gambling, the practice itself and the effects that
it can have are incompatible with several Biblical principals.
Many point to the casting of lots in the Bible as justification
for gambling. However the casting of lots was a decision making
process that was believed to be inspired by God, and therefore
cannot be used in this context. These underlying Biblical principles
are not only relevant to the Christian community, but to society
as a whole, since they deal with issues of responsibility, concern
for others and causing harm to vulnerable individuals and families.
These principles are as follows:
is not a thoughtful use of money but simply profits those who
win through artificially created chance. As such it represents
acceptance of undeserved gain. The Bible also teaches that "the
love of money is the root of all kinds of evil" (1 Timothy
6 v10). That is not to say that money is the root of evil, but
the love of money. Since gambling encourages the love of money
we believe it may lead to many kinds of other undesirable secondary
effects and should therefore be discouraged. The most significant
effects, we believe are the added pressures to family life when
one member gambles. The report itself points out some of the other
dangers such as depression, serious suicide thoughts, divorce,
debt, poverty and crime.
Concern for othersAny profit gained
by gambling depends on someone else's arbitrary loss. This does
not express the concern we should have for our neighbours' welfare.
Gambling is also an activity which is known to harm some individuals
and their dependants. Not only does it have economic cost on families,
it also has a social cost, as time that would otherwise be spent
with children is spent in casinos or in bingo halls.
part of the money gambled, for example, in the National Lottery,
is reclaimed by the Government as tax. This is an unfair way to
raise money for public spending as it is exploiting the human
weakness for wealth rather than being a legitimate mechanism of
redistributing wealth for the greater benefit of all society.
Figures have shown that the poor spend a greater proportion of
their income on gambling than the more well off. Thus gambling
could be said to be a regressive tax on the poor.
The Government in their White Paper, "A
Safe Bet for Success", seem to view the deregulation
of the gaming industry, and the expansion of gambling in this
country, as a matter of economics. The Evangelical Alliance reject
this assumption in the strongest possible terms. This is not only
a matter of economics but clearly has massive social implications
that we do not believe the Government have considered fully. Gambling
resorts may revitalise the economy of our seaside towns, but the
social cost have not been calculated. Indeed in the United States
the social cost of gambling has been estimated at a minimum of
$3 for every $1 of economic revenue generated. Similar studies
ought to take place in the UK. The social effects on our communitiessuch
as more problem gambling, increased crime figures, greater family
breakdown, and an increase in associated crime such as drugsnone
of these issues appear to be taken into account by the Government.
Instead the focus seems to be entirely on the economic benefits.
The Evangelical Alliance demands that the Government count the
social costs, rather than the economic benefits, of increased
gambling and resort-style casinos before any deregulation takes
Young people are at risk when they begin to
gamble at a young age. Yet education in schools rarely touches
on the dangers of gambling. It is seen as a fun, or a leisure
activity and the worst side of gambling is seldom seen or discussed.
The Evangelical Alliance would like to see the Gambling Commission
make representations to the Department for Education and Skills
to include some recognition of gambling, and the consequences
of gambling, in the National Curriculum.
Young people may be facing problem gambling
in the home and are unsure how to deal with it, or how to tackle
it. It is important to ask the question how can young people be
supported so that they do not fall into the same traps? The Budd
Report states that adult gamblers are more likely to have started
gambling in their youth. Although measures to prevent such a pattern
are not within the remit of the current consultation it is important
that some responsibility is recognised for tackling this situation.
The Alliance is concerned that the Government
have not taken up the proposals outlined in the Budd Report that
would completely restrict access for young people to gaming machines.
The Government proposes that children would have access to a new
AWP machines allowing a 10 pence bet and £5 jackpot. The
Evangelical Alliance strongly condemns such a move. Given the
evidence shown in the Budd Report that early gambling leads to
problem gambling we are amazed that the Government can take this
decision. The Evangelical Alliance recommends that the Government
take on board the recommendations of the Budd Report in this area
and remove all opportunities for young people to have access to
The Budd Report states that Problem Gambling
is defined as "gambling to a degree that compromises, disrupts
or damages family, personal or recreational pursuits." Yet
the Report also says that little is known of problem gambling
and the risk factors that can lead to problem gambling. The Government
White paper states gambling does "represent a particular
risk to children and the vulnerable which other forms of leisure
do not. Too early exposure to gambling can be harmful; and for
some people the temptation to gamble to excess is very hard or
in practice impossible for them to control." It goes on "there
is not yet a reliable figure on the level of problem gambling
but it is estimated that there are still between 275,000 and 370,000
problem gamblers at any time." (Paragraph 7.2, "A safe
bet for success".)
It therefore seems surprising that while recognising
that increasing availability will increase problem gambling deregulation
is continuing. The Evangelical Alliance believes that if the evidence
clearly shows that increasing availability of gambling will increase
problem gambling, then no deregulation should take place. Gambling
should not become more widespread. Instead it should come under
The lack of concrete evidence is a problem in
this matter. As the Budd Report argues more research must be done
to investigate the effects deregulation will have on problem gambling
prior to any such deregulation taking place. Past experience has
shown that once deregulation begins it is very difficult, if not
impossible, to reverse the process. Therefore the Evangelical
Alliance would support further research taking place into the
factors leading to problem gambling, prior to any deregulation
of the industry being undertaken.
We support the government calls to ensure that
more money is paid by the gambling industry into the research
and treatment of problem gambling, but this does strike us as
shutting the stable door after the horse has bolted. If we restrict
deregulation and do not introduce measures which are known to
increase problem gambling; such as the sale of alcohol, allowing
young people access to machines, and building large scale gambling
resorts, then there would be little need for more money to go
into the treatment of problem gambling. The Evangelical Alliance
are surprised that Government are planning to introduce a policy
when it knows it will cause harm to the vulnerable in our communities.
We would press the Government for clarification on this matter,
and if none can be given then these policies should be revisited.
This is another example of where proposed government
policy has surprising inconsistencies. Chapter 3, paragraph 3.21
of the Budd Report points out that there is ample evidence that
alcohol reduces inhibitions and impairs judgement about gambling,
and causes individuals to gamble more. Real experience in local
communities shows that many police forces are concerned about
the impact of the combination of alcohol and gambling on already
over-stretched resource. But the report recommends that the prohibition
on alcohol sale on the floor is lifted. A policy adopted by the
Government in the White Paper.
The Evangelical Alliance strongly believes that
this prohibition should not be lifted. The Budd Report and the
Government White Paper afford strong justification of our position
and we believe that given the adverse effects alcohol has on judgement
and self control it is imperative that this prohibition should
Internet gambling is undoubtedly on the increase.
In our submission to the initial consultation in July 2000 we
mentioned that a "simple search using the word "casino"
throws up 339,132 sites world-wide (Lycos 13 July 2000)."
The same search in October 2001 found 2,348,208
hits. (Lycos 19 October 2001). That is an increase of around 700
per cent in just over one year. This is a startling and troubling
Again the Budd Report points out that in Australia
a link was found between accessibility and problem gambling. Interactive
gambling will increase the opportunities for access to gambling
for young people.
We recognise the problems associated with regulating
on-line gambling and welcome the proposals in the report towards
monitoring of these sites. We also welcome government proposals
to regulate UK based sites and think the introduction of some
kind of "kite mark" is a useful way of achieving that
goal. Ideally we would like to see no on-line gambling at all,
but since it is clear that this is already widespread and growing
exponentially some regulation is needed, and needed quickly.
It is essential that those using gaming sites
should be positively identified to reduce laundering risks and
to prevent under-age play and we commend the report for specifying
The Evangelical Alliance believe that it would
be useful for warnings to be prominently displayed on the sites
about problem gambling, and on every page for there to be a contact
number for Gamblers Anonymous, or similar groups, and information
for problem gamblers.
More research must be undertaken as to the causes
and effective treatments for problem gamblers. The scale of the
problem must be understood before deregulation takes place. Once
deregulation occurs it may be impossible to reverse.
The comments we have made are based on a fundamental
belief that excess gambling is essentially a destructive activity,
not only for the individual involved but the family of the individual.
The report speaks a lot about the freedom to gamble, but with
that freedom comes a responsibility to dependants and society
in general. We would like to see more emphasis on the responsibilities
that gamblers have, and the responsibilities of the Government
to monitor and regulate this industry.
The Evangelical Alliance believes that the Government
White Paper is not a "Safe bet for Success",
but instead is a safe bet for more problem gambling, more children
gambling and increased crime in our sea side resorts where casinos
open; and will lead to, instead of economic benefits, a disproportionately
high social cost.
The Evangelical Alliance demands
that the Government count the social costs, rather than the economic
benefits, of increased gambling and resort-style casinos before
any deregulation takes place.
The Evangelical Alliance would like
to see the Gambling Commission make representations to the Department
for Education and Skills to include some recognition of gambling,
and the consequences of gambling, in the National Curriculum.
The Evangelical Alliance recommends
that the Government take on board the Budd Report recommendation
in the area of young people and gaming machines and remove all
opportunities for young people to have access to gaming machines.
The Evangelical Alliance believes
that if the evidence clearly shows that increasing availability
of gambling will increase problem gambling, then no deregulation
should take place. Gambling should not become more widespread.
Instead it should come under stricter controls.
The Evangelical Alliance would support
further research taking place into the factors leading to problem
gambling, prior to any deregulation of the industry being undertaken.
The Evangelical Alliance strongly
believes that the prohibition of alcohol sales on the casino floor
should not be lifted. The Budd Report and the Government White
Paper afford a strong justification of this position and we believe
that given the adverse effects alcohol has on judgement and self
control it is imperative that this prohibition should remain.
The Evangelical Alliance believe
that it would be useful for warnings to be prominently displayed
on internet sites about problem gambling, and on every page for
there to be a contact number for Gamblers Anonymous, or similar
groups, and information for problem gamblers.
The Evangelical Alliance believes
that the Government White Paper is not a "Safe bet for
Success", but instead is a safe bet for more problem
gambling, more children gambling, increased crime in our seaside
resorts where casinos open and will lead to, instead of economic
benefits, a disproportionately high social cost.
3 May 2002