Joint Committee on the Draft Gambling Bill Minutes of Evidence

Supplementary memorandum from the Royal College of Psychiatrists (DGB 128)

  1.  The Royal College of Psychiatrists is the statutory body responsible for the supervision of the training and accreditation of psychiatrists in Great Britain and for providing guidelines and advice regarding the treatment, care and prevention of mental and behavioural disorders.

  2.  The Royal College of Psychiatrists submitted evidence to the Joint Committee on the Draft Gambling Bill in December 2003. As requested by the Committee, The Royal College now presents this further submission regarding the proposed changes in the legislation controlling gambling in Britain and their likely impact on the incidence of pathological gambling.


  3.  The Royal College of Psychiatrists is concerned that the recently released documents and the evidence presented to the Joint Committee by the Government highlight once again the fact that the Government has failed to address a specific issue. In so far as commercial considerations are given pre-eminence in the formulation of public policy on gambling, social aspects will go by default.

  4.  This is well illustrated by the document dealing with the "Competition Assessment—The Casino Market" in paras 52 to 54 on "Effects of proposed regulation on competition—Market Structure". In this, an attempt is made to justify the proposal that larger casinos will be allowed unlimited numbers of gaming machines as follows:

    "Because of the profitability (Our emphasis) of operating machines this proposal, taken together with the question of the planning system, will favour the establishment of large casinos which may be part of a wider entertainment or holiday destination offer. It is known that large foreign companies have already expressed an interest in establishing such facilities in Great Britain."

  5.  It is significant that, in relation to this, reference is made in a footnote to MGM Mirage, an American company that is hoping to develop casinos in Great Britain. The CIO of this company was reported by CNN on 3 July 2001, advocating loyalty cards and saying,

    "Our target is mass-producing a high-roller experience for the common person. We want to provide you with the best experience imaginable, so that you'll want to come back."

  6.  Yet, the Minister, in comments at the Joint Committee Hearing on 16 December 2003, commended loyalty cards because he thought that they

    ". . . could be helpful in the control of problem gambling (our emphasis); it could be helpful in identifying the effects of gambling on individuals and communities". (Q42)

  7.  "The profitability of operating machines" (para 4) is directly related to the fact that gaming machines are the most likely form of gambling to lead to excess. Nevertheless, larger casinos are to be allowed to have unlimited numbers of gaming machines to attract promoters. The situation is then compounded by suggesting that loyalty cards, which are a device to stimulate gambling, can help to control "problem gambling".

  8.  The Royal College of Psychiatrists is concerned that the Government's prime considerations in these matters are clearly commercial ones, with no serious thought for the social consequences.


  9.  In reply to a question (Q111) at the Joint Committee hearing on 16 December 2003 "about the `anomaly' of under-age gambling on machines in Britain", the Minister said,

    ". . . most Category D amusement (our emphasis) machines could be classified as machines in which there is a substantial element of skill. For example, a few months ago we agreed that crane machines could be classified as machines with a substantial element of skill."

  10.  The Minister clearly chose to concentrate on the dubious concept of "amusement-with-prizes" (AWP), which is not used in the Draft Gambling Bill and omitted to mention that in the "Explanatory Notes" (Cm 6014—II), in para 108, it states that,

    "Children and young persons may both use the category of gaming (our emphasis) machine with the lowest stakes and prizes (category D)."

  11.  He went on to say,

    "I think those who want to abolish what has existed for many years would have to do a bit of research and show what harm they are doing before we will be convinced that we should cut out this business."

  12.  The Minister's reply therefore was quite clearly disingenuous. As far as research showing the harm that results from children playing any type of gaming machine is concerned, this was established in the 1980s (Moran, E. Report on fruit machine gambling among schoolchildren, 1987). There has been substantial research evidence since then ro confirm this.

  13.  It has been firmly established that all gaming machines, regardless of the size of the stake or the amount of prize money, are unsuitable for children and young people. The Royal College of Psychiatrists strongly recommends that they should cease to be made legally available to them.


  14.  The Government has adopted a rather simplistic attitude to remote gambling. Once again, its preoccupation is with the need for commercial organisations to be allowed to maximise their revenues, at the expense of social issues.

  15.  The draft legislation clearly recognises that many of the facilities for remote gambling emanate from outside Great Britain and, under para 16 of Policy Note 6 Advertising of Gambling, advertising such facilities will be prohibited. However, there is no provision for even attempting to control access to such overseas web sites, interactive television programmes and mobile phone promotions, many of which fleece the punters. This seems to be based on the notion that the Internet and other similar types of technology, such as interactive television and mobile phone messages originating from abroad, cannot be controlled.

  16.  However, the Government is fully conversant with the fact that these technologies can be and are being directed from abroad in a very destructive manner by those involved not only in promoting gambling but also in advertising, junk emails, pornography, hate campaigns, paedophilia. Eventually, supranational bodies will be obliged to grapple more realistically with the regulation of these technologies.

  17.  In the meantime, the matter could be dealt with by placing greater responsibility on the conduits for remote gambling. This would include Internet Service Providers and interactive television and mobile telephone providers.

  18.  The details of this need to be worked out by the Gambling Commission, but the basis must be incorporated in the legislation. Otherwise, the increase in pathological gambling from remote gambling is likely to be considerable. It will not be dealt with by "warning" messages or advice about "treatment" for excess (see para 21 below).


  19.  The Government clearly recognises that commercial gaming, with its rapid turnover, is the most likely form of gambling to be taken to excess. It is therefore appropriate that the proposed legislation maintains the ban on credit for gaming in casinos and prohibits the use of credit cards in gaming machines.

  20.  It is therefore highly anomalous that the use of credit cards will be allowed for remote gambling. This way of dealing with the situation is wholly undesirable since payments should be made by dedicated smart cards.


  21.  There is no doubt that, if the proposed changes are implemented, there will be a considerable increase in pathological gambling. The suggestion that this can all be dealt with adequately by setting up treatment facilities is a chimera. The draft legislation clearly envisages major expansion in all types of gambling with inevitable increased participation throughout the community. In such a setting, it is unrealistic to expect "treatment" to deal with all the harm resulting from this activity, which by its very nature is liable to be taken to excess. This is especially so if, as is likely to be the case, commercial pressures will encourage continued and increased participation.

  22.  It is vital that social considerations should be given much higher priority than is provided in the Draft Gambling Bill.

February 2004

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