Supplementary written evidence submitted by The Methodist Church (GA 96)

Summary and Key Points

The link between overall problem gambling levels and youth problem gambling is well established. Rises in the former are accompanied by rises in the latter, with the qualification that problem gambling (as a proportion of overall gambling) is generally higher among young people than the general population. Young males are at particular risk.

In the absence of a comprehensive study, it is not possible to give a definitive, current analysis of youth gambling in the UK, but the combined implications of recent rises in overall prevalence and problem gambling prevalence, and international research findings around the effects of liberalised gambling framework, give grounds for serious concern.

Internet gambling and advertising, including gambling advertising, are changing gambling patterns in ways that pose particular risks to children.

The changes to the regulatory framework and the Gambling Prevalence Survey threaten to make it harder to gather and act on the evidence the CMS committee rightly requires.

The Methodist Church and its ecumenical partners continue to query the appropriateness of Category D slot machines remaining legal for children to gamble on.

Context and Introduction

1. In the course of oral evidence given by representatives of the Salvation Army, Methodist Church, Evangelical Alliance, Quaker Action on Alcohol And Drugs and CARE, Mr Collins and Mr Sanders asked a series of questions relating to faith groups' and charities' views on gambling advertising.

2. Mr Sanders (Q478) stated "You do see the difficulty that we are having: you have raised the issue of advertising, but you cannot come up with a single example of an advert that has caused a problem, you cannot cite any evidence at all that states that it causes a problem, and we have to deal with evidence in order to reach conclusions".

3. The reply to this question set out two areas the CMS Committee would need to consider. The first, as mentioned, was the importance of drawing correct inferences from comparative studies of youth gambling and advertising. There was no opportunity in the oral evidence session to state the second point: the fundamental need to understand and question the normalisation of gambling, not just specific advertisements or industry practices, in making policy.

4. Over a decade of international research has established the nature of the links between gambling prevalence, youth problem gambling and advertising, and the way this research was conducted makes it clear that in its essentials its results are generally applicable irrespective of national boundaries.

The Effects of Gambling Advertising on Young People

5. The most recent (2009) and authoritative report is An Empirical Study Examining the Impact of Gambling Advertisements on Adolescent Gambling Attitudes and Behaviorsi

"Sixty-one percent of youth reported receiving spam gambling advertisements by e-mail and 96% had seen TV advertisements for gambling. The underlying perceived message is that winning is easy, the chance of winning is high and that gambling is an easy way to become wealthy. While most youth are dismissive of the messages and are aware of the risks associated with gambling, a large percentage of youth report that these messages prompt them to gamble. Rather than inciting non-gamblers to begin gambling, advertisements appear to serve the function of maintaining established gambling habits and were particularly problematic to youth with gambling problems."

6. The serious risks of gambling advertising for those who are liable to problem gambling are underlined by a US studyii which found that "gamblers who had urges triggered by advertisements also appeared to develop pathological gambling soon after the onset."

7. Research confirms that young people are particularly susceptible to gambling advertising. "Youth are particularly attuned to gambling advertisements and have high levels of recall for these ads (Derevensky, Gupta, Messerlian, & Gillespie, 2004)iii.

• Among other findings of a New Zealand studyiv were that "It was also reported that the younger the person, the more likely they were to remember some form of gambling advertising" (93% of those under 25 years; 76% of those over 65 years).

• A US National Gambling Impact Study Commission reported that lottery adverts target particularly vulnerable populations, specifically youth.

8. There has only been one survey that gave grounds for supposing that youth gambling in the UK (and youth problem gambling) may not be rising. The British Survey of Children, the National Lottery and Gambling 2008-09v found that problem gambling in youths, in the form of purchasing lottery tickets, had fallen since 2006. It also found that attempts to gamble and rates of gambling by other means including slot machines had fallen.

9. Despite the limitations of this survey, it is relevant because it shows that the regulatory effects of the Gambling Act 2005 - including limiting the availability of gaming machines in non-gaming environments like fish and chip shops - may have had the welcome effect of lessening youth gambling (and by implication youth problem gambling). However, the positive side of this message is more than offset by the much greater evidence that problem gambling is increasing, that youth problem gambling is consistently higher than problem gambling overall, as well as the overall context in which advertising and Internet gambling have spread substantially since the time the survey was conducted. This supports the argument that regulation is effective and needs to be rolled out more widely.

10. To claim that advertising is not targeted at youths are at best disingenuous. The above quoted recent study from McGill University (see paragraph 5) states:

"The gambling industry maintains that ads for gambling products and services are not specifically intended for underage audiences; nevertheless, this study offers ample evidence that many ads can be assumed to have strong appeal to adolescents. Many of the themes described here are likely to have tremendous appeal to adolescents and young adults, even if they are not the primary target audience. Although in some cases, efforts have clearly been made to use older adults and adult references (such as office settings), there are many more examples of signifiers likely to have strong resonance with youth viewers, such as ironic humour, and the use of quasi-adolescent characters and cultural references."

11. There are numerous other relevant studies. If the CMS Committee requires further details and a more complete understanding of the causal relationships between advertising and youth problem gambling, leading authorities such as Professor Mark Griffiths of Nottingham Trent University or Professor Jim Orford of the University of Birmingham should be able to assist.

12. However the overall message is clear. These findings all underline the need to strengthen the use of the precautionary principle in advertising in view of its disproportionate effect on, and risk of harm to, on young people.

Social Media

13. The above would probably have applied to any substantial liberalisation of gambling advertising, even without the rise of gambling and gambling advertising online. But these developments pose additional risks for youths. There is an urgent need for more research around these areas: if the CMS committee requires further information, CARE has particular expertise in the area of online gambling.

14. One noteworthy development is the creation of gambling opportunities for social media. As found in Downs' 2008 pilot research in the Ukvi "there were 25 Poker applications on Bebo (and over 500 separate poker groups) and in excess of 100 poker applications on Facebook (and over 1,000 separate poker groups). These poker sites featured some with real prizes, some with cash-play options, and all easily downloadable by those under 18 years along with many free trial games. The largest of these poker groups had over several thousand members and in one group surveyed, 15% of those in the group declared they were under the age of 18 years. Furthermore, gambling applications typically contain sidebar advertisements and hyperlinks to real gambling sites."

15. Young people are usually at the forefront of uptake of innovative forms of social media, and the UK traditionally leads Europe in its engagement with new technology. As UK youth are disproportionately likely to come into contact with gambling and gambling advertising through the Internet and Social Media, the risk of continuing to allow children to gamble (uniquely in Europe) is clear.

The Global Context and the Relevance of Studies from Other Jurisdictions

16. In response to the growth of the gambling industry in recent decades, there have been various authoritative worldwide studies, with Canadian researchers playing a notable role. In oral evidence given to the CMS on 22 November 2011, Canadian and Australian studies were mentioned as particularly relevant because, while most of the studies were conducted in nations with broadly comparable national contexts and regulatory frameworks, lessons learned from Canada and Australia are likely to be more directly applicable in view of stronger cultural similarities.

17. It is important that the UK draw comparisons with research from other jurisdictions which have data on the effects of a liberalised regime and add to the international body of research by maintaining funding of and demonstrating engagement with, major studies. As mentioned, most if not all of the relevant studies are based on data from nations whose cultures are strongly comparable to that of the UK, and the research is generic enough to highlight those drivers which are likely to be shared by gamblers and problem gamblers of different nationalities and regulatory regimes.

18. There is no reason to suppose substantive difference or inapplicability of this research into the effect of advertising on youth gambling. The area where national difference is relevant may be around the prevention and treatment of problem gambling. Analysing and where relevant implementing findings from comparable jurisdictions should be prioritised while the UK develops its own research.

19. Two major US studies found that:

"Between 1984 and 1999 there was a significant increase in the proportion of youth who reported gambling within the past year as well as those who reported gambling-related problems (Jacobs, 2000)vii

"Clearly, adolescents represent a particularly high-risk group and are vulnerable to the development of gambling problems" (Derevensky & Gupta 2000)viii

20. The US study "Youth Gambling in the 21st Century: Prevalence,lmpact, and Interventions" concluded that "The data demonstrates that most young people engage in gambling at a younger age, and gambling may serve as an initiation to other risky behaviors such as drug and alcohol use."ix

21. Mr Sanders stated that "We know that in Australia, the liberalisation of gambling went far further than in this country, so it would not be a comparator" (Q479). This is true to the extent that the Australian experience cannot be used to argue in broad terms for or against liberalisation. However it is false to suggest that inferences about the overall effects of liberalisation or the causes of problem gambling among youths cannot be made. The scale may be different but the causal relationships must be acknowledged.

22. In addition, if the argument that UK regulation is about right involves a claim that Australian deregulation proceeded too quickly, then the Australian data should be considered to consider what excessively fast deregulation might look like and combine that learning with the maintenance of the precautionary principle.

23. In answering Mr Sanders' Q479 by saying "Some of the studies are quite technical, but our first task is to make sure that the data and findings reflect the UK situation where research has not been done", the intention was to encourage the CMS Committee to study the international evidence which is massive and to which I can only refer in this document.

24. On the assumption that the grounds for comparability - from a public health perspective - are so strong that the general points should be regarded as non controversial, the Methodist Church would invite the CMS Committee to accept existing findings around the causes of problem youth gambling, recommend prioritising studies capable of capturing any differences relevant to prevention and treatment of problem gambling in the UK, and advocate caution in policy making and investment in research, prevention and treatment targeted at problem gambling in youths.

25. It is also important that work that has already been done on this subject is not lost. We would call the committee's attention to/attach a paper produced by the Responsibility in Gambling Trust (RIGHT) in 2006, which was Responsible Gambling Fund's predecessor. Its review (which includes relevant parallels between alcohol and gambling) and many of its conclusions are still valid.


26. The gambling industry has a strong incentive to normalise gambling and advertising inevitably plays a central part in this. The McGill study mentioned above states:

"From a marketing perspective, the gambling industry, like the tobacco and alcohol industries, must ensure that a next generation of gamblers will emerge to replace the old one. Gambling corporations require continuity to maintain and increase their market share, and this can only occur with consistent and continuous normalization of gambling as enjoyable and benign entertainment. Moreover, evidence suggests that brand recognition is even more effective when it is introduced to children at a very young age (Buijzen & Valkenburg, 2004).

For these reasons, it is critical to learn the lessons of the tobacco and alcohol awareness advocacy movements, which have had several more decades' experience crafting effective guidelines to protect youth from potentially risky messages for those products. An argument that alcohol advertising targets youth simply because it is in so many ways undistinguishable from all other advertising that targets young people can be extrapolated here....(Austin & Hust, 2005)

...of critical concern in advertising any product that is potentially risky to the end user is the social climate of normalization that surrounds it, theoretically heightening audience's receptivity to the product. A study of adolescents found that non-drinkers who showed high receptivity to alcohol advertising messages were more likely to try drinking than their peers (Henriksen, Schleicher, & Fortmann, 2007)"

27. This shows that gambling advertising, as practiced, is hard to separate from the attempt to normalise gambling. Contra Mr Collins' assertion during oral evidence on 22 November 2011, churches and charities in the UK have no blanket desire to ban gambling advertising, though shades of opinion exist around what might constitute appropriate advertising.

28. But before general criteria around advertising can be established or specific adverts considered, there needs to be a serious discussion of normalisation. And if, as the above research suggests, recent trends in advertising are inseparable from the attempt to normalise, and this in turn is likely to impact on youths disproportionately, then the normalisation agenda is itself in question.

29. Any industry policies with definite potential to cause harm to vulnerable communities are of deep concern to the Methodist Church. Just as the clustering of betting shops with hard gaming machines in deprived areas should be guarded against, advertising must guard against causing a serious increase in problem gambling among youths.

30. It may be argued that these two requirements would pose serious challenges to parts of the UK gambling industry. But this challenge must be met if the gambling industry is to demonstrate its social responsibility and comply with Objective 3 of the 2005 Act.

Summary and Conclusions

31. For this reason, particular extreme gambling advertisements are less of a current concern than the question of the means by which normalisation is being achieved. Socially responsible industry growth must aim at meeting legitimate demand whilst avoiding affecting the vulnerable adversely. Current trends gambling offer little assurance that this is the case and in the mean time, the presumption should be caution, not liberalisation by default.

32. In addition to the detailed evidence presented in this document, it is vital that Government recognise certain facts and wider threats:

Children are at high risk of becoming problem gamblers and harms to children gamblers are particularly worrying, not least the risk of becoming an adult problem gambler.

Children are susceptible to peer pressure, example and advertising and are particularly at risk in online gambling which is a growth area, inherently attractive to 'Internet-savvy' youth, and advertised aggressively.

Young men are at particular risk, for reasons explained in the various studies mentioned, including a propensity to risk-taking behaviour and an overvaluation of supposedly specialised knowledge.

In this climate, the regulator must be empowered to limit industry reliance on business strategies which rely on profiting from risky forms associated with problem gambling and harm to vulnerable communities. These include but are not limited to clustering of gambling opportunities in vulnerable communities and advertising which will disproportionately affect youths

33. One area which requires particular scrutiny is thus sports advertising, and the association between sport and gambling. Unlike some other forms of gambling it offers real-time betting on an already appealing activity and appeals to the belief in specialist knowledge. It is unrealistic to suppose that children can be protected from intensive gambling advertising associated with sport (both at sporting events and on television) reaching their adult family members. The paper produced by RIGHT (noted in paragraph 25 above) discusses the relationship between sponsorship and sports advertising and should be reviewed.

34. As mentioned in the oral evidence session of 22 Nov 2011, the 2005 Act should have been followed by a consistent attitude of caution when potentially deregulatory measures or changes to stakes and prizes were discussed and the collection of sufficient evidence before any making any substantial changes. In worrying contrast, policy changes since the 2005 Act seem to have been introduced without any evidence whatsoever and have all been deregulatory moves in response to Industry pressure based on financial considerations.

35. The ultimate risk of the current direction of travel is that of treating the UK population as subjects in a risky social experiment through leaving basic presumptions towards liberalisation unchallenged. Contra this laissez-faire attitude, the Methodist Church maintains that:

Ø There are basic questions about gambling advertising, which go beyond objections to particular adverts. These include concerns about the normalisation of harmful forms of gambling; advertising likely to affect children disproportionately; and the relationship of gambling to the Internet and social media.

Ø As expressed in Objective 3 of the 2005 Act, youth gambling is a special category. Prevalence of problem gambling is higher in children than adults and protecting children from developing gambling problems should be at the heart of the regulatory framework and a prime concern in any new policy making

Ø There is every reason to believe that the key international studies are entirely applicable to the UK and that, sadly, liberalisation leads to rises in youth problem gambling. Understanding the grounds of comparability and analysing the causes of problem gambling are an important interim measure prior to conducting an adequate UK study,

Ø Rather than displaying limited engagement even with the existing studies and pressing on with liberalising policy willy-nilly, Government should return to the precautionary principle, following the letter and spirit of the 2005 Act. The 'data' should be not created artificially through inadvertently creating rises in problem gambling through a socially irresponsible deregulatory agenda.

36. There is sufficient evidence to support each of these claims, and the combined danger of not adopting them is that the evidence that the DCMS would consider adequate - a UK study - will not be done because it is not deemed important on a priori grounds and because funding is being withdrawn. Furthermore, even if it were done, the present direction of travel would be to keep liberalising until any measured changes were not just real and statistically significant, but serious enough to be unequivocal. But by then, the damage done by deregulation might be too serious to be met by normal policy measures.

37. The first policy to review, in the light of these principles, is the ongoing legality of children gambling on machines that involve financial stakes and prizes. In view of current concerns around youth problem gambling, there are strong grounds for bringing the UK in line with the rest of Europe and making Category D slot machines legal for adults only.


i Jeffrey Derevensky, Alissa Sklar, Rina Gupta and Carmen Messerlian, from The International Journal of Mental Health and Addiction Volume 8, Number 1.

ii Grant, J. E. & Won Kim, S (2001)

iii Canada - The McGill University "Way to Play" Study ( analysed 127 television, radio, print, and public-display ads in the year 2005-2006.

iv gambling survey of 1500 people in June July 2000 conducted by Amey (2001)°/020and%20conclusion.pdf

vi (Downs C. The Facebook phenomenon: Social networking and gambling. Gambling Social Responsibility Forum Conf, Manchester Metropolitan Univ, Manchester, Sep 2008.)

vii (See in Jacobs, 2000)

viii (See in Derevensky & Gupta 2000), and



November 2011

Prepared 11th January 2012