Gambling

Written evidence submitted by the Salvation Army (GA 82)

The Salvation Army is an international Christian church working in 125 countries worldwide. As a registered charity, The Salvation Army demonstrates its Christian principles through social action and is one of the largest, most diverse providers of social welfare in the world.

The Salvation Army appreciates the invitation to respond to this consultation process. We have worked closely on the issue of Gambling Policy with the Department of Culture Media and Sport and subsequently with the Gambling Commission over several years.

The Salvation Army is particularly concerned that the current trend towards the societal normalisation of gambling could lead to an increase in the number of people experiencing the highly damaging consequences of problem or pathological gambling, either directly or indirectly.

The Salvation Army has a long history of working with those whose lives are damaged by addictions, most notably to alcohol and drugs, and a number of those with whom we work also cite gambling among their addictions.

The Salvation Army welcomes that The Salvation Army The Culture, Media and Sport Committee has launched a new inquiry into gambling, looking in particular at the implementation and operation of the Gambling Act 2005.

The Committee has invited written submissions and has requesting views on the following issues:

· How effective the Act has been in its core objectives to:

- ensure that gambling is maintained crime-free and conducted in an open and fair manner,
- protect children and vulnerable people from the adverse effects of gambling,
- update the legislative framework with regards to online gambling;

· the financial impact of the Act on the UK gambling industry;

· the effectiveness of the Gambling Commission since its establishment, and whether it represents good value for money;

· the impact of the proliferation of off-shore online gambling operators on the UK gambling sector and what effect the Act has had on this;

· why the Act has not resulted in any new licences for casinos or "super" casinos;

· the effectiveness of the classification and regulation of gaming machines under the Act;

· What impact the Act has had on levels of problem gambling.

How effective the Act has been in its core objectives:

The Salvation Army believes that only by the intervention of civil society groups was the original Act saved from causing excessive social harm through the introduction of super casinos.

Since the Act has been introduced successive Governments have further liberalised stakes and prizes. The practice of online Gambling has never been adequately covered by the Act.

The financial impact of the Act on the UK gambling industry:

The UK Gambling Industry remains wealthy and successful. Despite the ongoing debate about what the Act might or might not have done to its revenues it remains a disgrace that the voluntary industry donations to cover research into gambling and treatment of problem gamblers take so long to be collected and never seems to reach the target requested. The Gambling Industry can well afford the implementation of a compulsory levy. This would avoid the waste of time fundraising by who are tasked with tackling the social consequences of problem gambling.

The effectiveness of the Gambling Commission since its establishment, and whether it represents good value for money:

The Salvation Army has always supported the Gambling Commission in its difficult work of holding a socially harmful industry to account. We would argue that now is not the time to be cutting the resources of the GC nor merging it with the National Lottery Commission. The Gambling Industry can be compelled under the Act to pay a compulsory Levy and that ought to be used to fund whatever work the GC needs to do to help protect children and the vulnerable.

The Salvation Army as a member of the of the GC’s community liaison group would however also like to express concern that the GC has on occasion not been clear enough about its own position when the Industry has been found wanting. For example when the GC issued a tepid response to the large increase in problem gambling revealed by the most recent Gambling Prevalence survey it seems to have failed in its duty to stand up to the Industry and speak the truth that gambling proliferation is leading to higher levels of problem gambling.

The impact of the proliferation of off-shore online gambling operators on the UK gambling sector and what effect the Act has had on this:

The Act did not deal effectively with online gambling as a problem area and seemed to place it in the ‘too hard’ tray. We would maintain that measures such as blocking urls, enforcing regulation with banks regarding spending limits and breaks in play and the banning of credit cards so that no online gambling can be undertaken on debt would go some way to restoring control of this almost unregulated sector.

Why the Act has not resulted in any new licences for casinos or "super" casinos:

There are no super casinos because of a lack of public demand, a press outcry and lobbying by churches and community groups. We have no wish for future super casinos and furthermore we would point out that the new ‘small’ and ‘large’ casinos that have been permitted under the Act have not gone unnoticed and they will be held to the highest level of scrutiny.

For example a new Casino recently granted permission to open at Westfield Shopping Centre near the Olympics is clearly in close proximity to major retail and shopping outlets and certainly does not fulfil the ideal of ‘a dedicated trip to gamble’ or promoting a separation between casinos and other leisure facilities.

While The Salvation Army does not endorse prohibition in its attitude towards gambling Salvationists refrain from gambling themselves and urge those who do gamble to follow some simple steps to protect themselves. Gambling is as a leisure activity, not a means of making money. We urge gamblers to set a budget before gambling, to set a time limit to their gambling and to set time aside to gamble away from other leisure pursuits. ‘Casual gambling’ can too easily become habitual gambling, particularly if it is easily to slip into due to geographic proximity to other regularly visited locations such as shops or entertainment complexes.

The effectiveness of the classification and regulation of gaming machines under the Act:

This has been the Act’s most obvious shortcoming with machines being one of the most addictive forms of gambling and yet machine stakes and prizes being further liberalised since the Act became law. Most recently the regrettable decision of the Government to go ahead with liberalisation of B3 machines even AFTER the rise in problem gambling exposed by the most recent Gambling Prevalence survey.

What impact the Act has had on levels of problem gambling:

Tessa Jowell the Minister responsible for bringing in the Act said that any increase in problem gambling would be a failure.

The initial Gambling Prevalence survey set a baseline. The subsequent survey did not show a rise as the full effects of the Act had not taken hold. The most recent survey showed a marked increase in gambling and a corresponding increase in problem gambling. Problem Gambling is now up from 250,000-300,000 in the 2007 Gambling Prevalence Survey to 360,000-450,000 in the 2010 GPS.

The 2005 Act has resulted in an increase gambling and a subsequent increase in problem gambling. The Government need to take urgent action to address this situation and increase provision for treatment of problem gamblers forthwith.

The Salvation Army endorses the responses from:

CARE: Christian Action Research and Education

EA: The Evangelical Alliance

QAAD: Quaker Action on Alcohol and Drugs

The Methodist Church

The Salvation Army warmly thanks the Committee for the opportunity to respond to this inquiry.

July 2011

Prepared 1st August 2011