Gambling Harm—Time for Action Contents

Chapter 8: Research, education and treatment

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Funding of research, education and treatment

542.We have referred a number of times to the need for reliable and independent research into all aspects of gambling-related harm. Education of the public, children in particular, about the potential dangers of gambling, and how to gamble (if at all) within one’s means, should be equally important for the prevention of problem gambling, while the need for treatment for problem gamblers hardly needs emphasising. But it all needs to be paid for—something other countries seem to appreciate better than we do.573

A mandatory levy

543.Chapter 32 of the Budd report looked in some detail at “Researching, Limiting and Treating Problem Gambling”, including the funding, and concluded: “We recommend that the industry should set up a voluntarily funded Gambling Trust. We recommend that the government should reserve powers to impose a statutory levy, possibly linked to gross profit, if such a Trust is not established or subsequently ceases to operate.”574

544.In the very brief White Paper setting out the Government’s policy for the new legislation, nothing was said about a voluntarily funded Gambling Trust, or what should happen if one was not set up. It was simply stated that the draft Gambling Bill would “make provision for … reserve powers for an industry levy to tackle problem gambling”.575 The draft Bill also said nothing about a Gambling Trust, and no more was heard of it.

545.The Bill did however include “reserve powers for an industry levy”, and these are what has become section 123 of the Act. That section allows the Secretary of State to make regulations requiring the industry to pay an annual levy to the Gambling Commission, which has wide powers to use it “for purposes related to, or by providing financial assistance for projects related to (a) addiction to gambling, (b) other forms of harm or exploitation associated with gambling, or (c) any of the licensing objectives.”576 The Explanatory Notes to the Act explain that the levy would be treated as if it was part of the annual fee, so that a licence would be revocable if the levy was not paid.

“The money raised by a levy would be used for alleviating problem gambling. Thus, the Commission could spend it on purposes or projects related to gambling addiction or other forms of harm or exploitation associated with gambling … Such projects need not be undertaken by the Commission itself, but the Commission could fund others (including other public sector bodies) who are undertaking projects connected with problem gambling.”577

546.The DCMS memorandum for the Commons post-legislative scrutiny of the Act578 stated: “Following the Gambling Commission’s RET Review in 2008 the Government decided that the voluntary levy should continue, and section 123 would not be enacted unless the voluntary approach failed to generate sufficient funding to sustain a programme of research, education and treatment.” This is a misunderstanding of the legislative process. The whole Act, including section 123, was “enacted” when the Act received Royal Assent on 7 April 2005. Section 123 was brought into force, along with the majority of the Act, on 1 September 2007.579 But it remains ineffective unless and until Ministers use their powers to make regulations imposing a mandatory levy. This is what successive Governments have refused to do.

547.For many years the industry has on a voluntary basis contributed 0.1% of its GGY to research, education and treatment. The amount has been subject to increasing criticism, as has the Government’s refusal to implement a mandatory levy. In their Strategy 2018–2021: Making Gambling Fairer and Safer,580 the Gambling Commission noted that the response by gambling operators to the voluntary levy had been “slow and insufficient”, and “continued failure in this would be unsustainable and unacceptable for the future.” The Commission therefore recommended a mandatory levy, which would “be a fair and credible way of addressing some of these weaknesses should they continue and indeed has support within the industry, including among the largest operators.” If there is indeed support for a mandatory levy among the largest operators, it has not been apparent to us.

548.On 11 March 2019 Mims Davies MP, the minister then responsible for gambling, said in a Westminster Hall debate that if the industry did not hit its voluntary target of £10 million a year then she did not rule out a mandatory levy. A month later the Gambling Commission published its National Strategy to Reduce Gambling Harms,581 which stated that:

“The Gambling Commission is committed to pushing industry to meet their responsibilities in this space, but we have also publicly stated our support for an appropriate levy as provided for in the Gambling Act 2005 which would be a significant part of providing a greater consistency of funding based on need.”

On 25 April 2019 the chairman of the Commission, presenting the National Strategy, said that the voluntary levy was not working, but moments later the minister contradicted him and said that the Government would not be bringing in a mandatory levy, a decision which attracted much criticism.

549.On 19 June 2019 the five biggest operators, perhaps sensing which way the wind was blowing, wrote to DCMS offering to increase their voluntary contribution from 0.1% of GGY to 1% over the next five years.582 This was formally announced on 2 July 2019 by the then Secretary of State, the Rt Hon Jeremy Wright MP, in a statement to the House of Commons,583 repeated by Lord Ashton of Hyde in the House of Lords:584

“Today five of the biggest gambling companies have agreed a series of measures which will deliver real and meaningful progress on support for problem gamblers. This announcement has been welcomed by the Gambling Commission, GambleAware and Gamban. These are companies which, together, represent around half the British commercial gambling industry.

At the heart of this package is a very significant increase in their financial contribution to fund support and treatment. Last year voluntary contributions across the whole industry to problem gambling yielded less than £10 million. Now five operators—William Hill, Bet365, GVC, which owns Ladbrokes and Coral; Flutter, formerly known as Paddy Power Betfair; and Sky Betting & Gaming585—have pledged that over the next four years they will increase tenfold the funding they give to treatment and support for problem gamblers. In this same period they have committed to spending £100 million pounds on treatment specifically. The companies will report publicly on progress with these commitments, alongside their annual assurance statements to the Gambling Commission.”586

550.The Secretary of State added:

“I know members across the House have argued for a mandatory, statutory levy to procure funds for treatment and support of problem gambling. I understand the argument but of course the House knows that legislating for this would take time - in all likelihood more than a year to complete. The proposal made this morning will deliver substantially increased support for problem gamblers this year. It may also be said that receipts from a statutory levy are certain, and those from a voluntary approach are not. But it is important to stress two things. First that these voluntary contributions must and will be transparent, including to the regulator, and if they are not made we will know. Second, the Government reserves the right to pursue a mandatory route to funding if a voluntary one does not prove effective.”587

551.In their written evidence, defending the Government’s decision not to impose a mandatory levy, Ministers stated: “The Act states that funds collected through such a levy are to be used by the Commission to fund projects related to addiction to gambling, other forms of harm or exploitation associated with gambling, or any of the Commission’s licensing objectives.” This of course is correct. But the Ministers continue: “It is unusual for a regulator to be the commissioner of support services and we are concerned that placing such a responsibility on the Gambling Commission risks broadening its remit too far.”588 It may be “unusual for a regulator to be the commissioner of support services”, and if the result of the mandatory levy was indeed that the Commission had itself to commission research and deal directly with treatment providers, we would agree that this should not be a responsibility of the Gambling Commission’s.

552.That however is not in our view the position. We see nothing in section 123(5) or (6) of the Act which suggests that if the Commission used these funds to enable another body to commission support services, that would be contrary to the rule against sub-delegation. The voluntary levy is currently paid mainly to GambleAware to be the commissioning body, and we see no reason why the mandatory levy should not similarly be paid to a commissioning body. If this is the Government’s reason for not imposing a mandatory levy, in our view it is a bad reason.

553.Another reason given by Ministers for not imposing a mandatory levy is that “A mandatory levy on operators would also be a hypothecated tax. Public services are not usually funded by such taxes as they risk raising too much or too little for the purposes for which they are intended.”589 This may be unusual, but the possibility has been on the statute book for 15 years, and this is no reason for not giving effect to the intention of Parliament. The Horseracing Betting Levy, which can also be regarded as a hypothecated tax, has been in force since 1961, and the rate is set by statute.590 If the mandatory levy raises too much or too little money, the rules for calculating the levy (to which we refer in the following paragraphs) can be amended. The Commission in any case has power under paragraph 12 of Schedule 4 to the Act to pay money into the Consolidated Fund.

554.Yet another reason given by the Secretary of State for not imposing a mandatory levy was that “legislating … would take … in all likelihood more than a year to complete”. Later he added: “I said it would take at least a year; it may in fact take nearer to 18 months because any of these changes will need to begin at the start of a tax year.”591 Why this should be, he did not explain. He would have to consult the Gambling Commission,592 and no doubt he would also consult the industry. The Regulations would need affirmative resolutions of both Houses.593 They would be fairly complex since they would have to set out the amount of the levy and the basis on which it is calculated. Section 123(2) provides five options for calculating the levy. Three are based on a percentage of the licence holder’s receipts, profits or annual fee, a fourth is “according to a specified formula”, and the last is “in some other way”, giving DCMS and the Gambling Commission complete discretion in negotiations with the industry. With goodwill, there is no reason why this should take anything like a year, let alone more.

555.It is not for us to recommend which of these options should be used for calculating the levy, but we emphasise the importance of certainty. We mention below the problems caused by a fluctuating voluntary levy. A mandatory levy dependent on receipts or profits will not be fixed; in these uncertain times there may well be major short-term changes in receipts and profits. It would not be possible to plan long-term research, education and treatment on that basis.

556.Ministers concluded their reply on this issue by saying: “Our focus to date with regard to gambling addiction treatment has been on ensuring that we have the right level and forms of support available for those who need it, rather than the mechanism by which this provision is funded.”594 We see no reason why Ministers should not focus on both, rather than seeking ever more excuses for not taking action which all, other than the Government and the industry, think is highly desirable.

557.We recommend that Ministers should forthwith exercise their powers under section 123(1) of the Act to require the holders of operating licences to pay to the Gambling Commission an annual levy sufficient to fund research, education, and treatment, including treatment provided by the NHS.

558.Those involved in setting the levy should consider whether the companies responsible for those forms of gambling which cause a higher degree of harm should pay correspondingly more for a levy which will to a great extent be used to fund treatment: what has been called a “smart levy”, based on the “polluter pays” principle.595 The Lotteries Council rather naturally took this view:

“We believe that any voluntary or mandatory levy related to problem gambling should be based on causation, not on Gross Gambling Yield or other measure. We are concerned that levying charity lotteries in the same way as bookmakers and casinos, who have a significantly higher prevalence of problem gambling, means that the lower-risk charity lottery sector is effectively subsidising the higher risk sections of the gambling sector.”596

559.The wide discretion given to Ministers in choosing the option for calculating the levy would allow for a “smart levy”. It has a precedent in New Zealand, where the problem gambling levy is set by Order in Council and reviewed every three years.597 The following table shows that significant changes can be made as a result of a review.

Table 14: New Zealand Problem Gambling Levy

Gambling operators

Income liable

Rate % 2016–19

Rate % 2019–

Casino operators

Casino wins

0.87

0.56

Non-casino gaming machine operators

Gaming machine profits

1.30

0.78

New Zealand Racing Board

Betting profits

0.52

0.52

New Zealand Lotteries Commission

Turnover less prizes paid and payable

0.40

0.43

Source: New Zealand Inland Revenue, ‘Problem gambling levy’: https://www.ird.govt.nz/duties/problem-gambling-levy [accessed 27 May 2020]

560.When considering the options for calculating the mandatory levy under section 123(2) of the Act, DCMS officials should devise a formula requiring companies offering potentially more harmful gambling products to pay a correspondingly higher proportion of the levy.

Funding problems with a voluntary levy

561.Until our recommendation is implemented and a mandatory levy imposed, research, education and treatment will continue to be funded by the industry on a voluntary basis. This has a number of defects including the following:

562.Kate Lampard, the Chair of the Board of Trustees of GambleAware, explained why they supported a mandatory levy:

“We have an uncertain cash flow. We do not know from year to year what we are going to be receiving for our work. We are engaged in commissioning long-term treatment and prevention services that are extremely expensive and that have to be commissioned on a long-term basis to provide any sort of certainty.”602

This point, made in October 2019, is all the more valid now; the GGY of companies this year is unlikely to be close to what was anticipated only a few months ago, and so therefore will any voluntary levy based on a percentage of GGY.

563.Until this year a company could comply with the licence provision by making a payment to any person or body who or which appeared to meet the criteria. The relevant provision of the LCCP603 was amended from 1 January 2020 to require operators to make their annual contribution to one or more of the organisations approved by the Gambling Commission, and to report to the Commission in their regulatory return the destination(s) of their payments and the amounts that have been contributed. Of the 11 organisations currently listed, nine are charities. They include GambleAware, the only one which is listed for all three categories (research, prevention and treatment), GamCare (prevention and treatment), and Gordon Moody (treatment only).604

564.In 2017 the Gambling Commission conducted a full review of RET arrangements, and published its assessment in February 2018. This showed that the RET spend in Great Britain in 2016 was £8.26m or £19 per problem gambler. New Zealand spent £9.70m, more than Great Britain, amounting to £413 per problem gambler. Victoria (Australia) spent £636 per problem gambler.605 The position has since improved, but it is still the case that other countries spend vastly more per head than Great Britain. The situation will be improved by the increase in the money to be paid under the voluntary levy between now and 2023, but a mandatory levy remains essential.

565.We however agree with the Gordon Moody Association that more money, however it is funded and whatever its source, is not always the answer:

“Any requests for further funding, whatever the mechanism for raising it, should be supported by hard evidence that it is going to make a genuine difference. Far too many people and organisations cast around arbitrary numbers that the Gambling Industry should be contributing to RET without any factual support. This does not help those in genuine need of our help.”606

GambleAware

566.The charity GambleAware is central to the collection and distribution of funds raised by the voluntary levy. Its charitable objectives are:

567.GambleAware told us that they commission integrated prevention services on a national scale and in partnership with expert organisations and agencies, including the NHS, across three areas of activity:

They have £45 million committed to these objectives.607

568.GambleAware sent us full written evidence about its structure and activities,608 and we took oral evidence from Marc Etches and Kate Lampard.609 We asked Mr Etches for further details of the structure and staffing, and he wrote to us on 3 April 2020.610

569.At the date of that letter we had finished taking written evidence, and Mr Etches will have seen that it included a considerable amount of criticism of GambleAware on a number of fronts. He therefore updated some of the information in the written evidence they had given in September 2019 and the oral evidence he and Ms Lampard had given on 29 October 2019. He explained that GambleAware have “expanded significantly over the past two years in response to a doubling of both funding and commissioning activity.”611 In fact, as will be seen from the following table, over the last five years the income has almost doubled, the expenditure trebled and the number of staff quadrupled.

Table 15: Income, expenditure and staffing of GambleAware

2015–16

2016–17

2017–18

2018–19

2019–20

Income £m

7,632,371

8,621,499

14,507,455

18,441,553

14,953,624

Expenditure £m

6,350,697

8,262,328

8,299,321

15,650,056

18,400,000

Staff

6

7

9

13

23

Source: Supplementary written evidence from GambleAware (GAM0128)

Funding by GambleAware

570.One of the criticisms of GambleAware related to funding. Anna Hemmings of GamCare, which provides education and prevention and is the largest provider of treatment for gambling-related harms, and Matthew Hickey, the Interim Chief Executive of Gordon Moody, which also provides treatment services, gave evidence to us on 10 March 2020. Both said that they had good relations with GambleAware, but our questions on funding revealed a strange picture. Under an agreement which ends in March 2021, GamCare receives about 80% of its funding from GambleAware (which in turn receives it from the industry through the voluntary levy); if GamCare receives funds from alternative sources to fund treatment, GambleAware will reduce its funding by the same amount, pound for pound.612 GamCare therefore has no incentive to seek additional funding from other sources, nor has it done so.

571.Gordon Moody has similar but not identical restrictions on raising funds. Mr Hickey explained that GambleAware “is funding us to deliver certain services in certain locations and we are not allowed to go out and ask for additional funds to support those services … but we are allowed to go out and secure additional funding to deliver other services if we so wish.”613

572.Mr Etches referred to this in his letter of 3 April 2020:

“The Committee also spent some time discussing the Grant Agreements that GambleAware has with treatment providers, and there seemed to be a concern these agreements are being used to enforce monopsony. I want to reassure you that this is not the case. As an independent charity, GambleAware needs to be able to account for its expenditure. Trustees would be failing in their duty if GambleAware was giving money to a particular activity that was simultaneously being funded from another source, i.e. ‘double-funded’.”

573.We do not understand this last point. What is at issue is not funding the same activity twice, but a procedure which prevents new activities from being funded at all by ensuring that in practice no additional funds can be raised.

574.GambleAware must correct the current anomalous system of funding treatment so that charities providing treatment are free to raise money from other sources without imperilling their current funding.

Independence of GambleAware

575.An issue which was raised on a number of occasions was the perceived lack of independence of GambleAware, and its links with the industry. Certainly this has been a problem until recently. It was only in September 2018 that the GambleAware Research Commissioning and Governance Procedure was updated to provide: “No-one with a background in the gambling industry is or can be a member of GambleAware’s Research Committee or Board of Trustees.”614 Prior to that, Neil Goulden was chair of GambleAware (then called the Responsible Gambling Trust) between 2011 and 2016, despite being simultaneously CEO and Chairman of Gala Coral Group from 2001–14, chairman of the Association of British Bookmakers (ABB) between 2012 and 2014,615 and chairman of the Horseracing Betting Levy Board from 2015–17.616 Brigid Simmonds, whose appointment as Chair of the BGC was announced on 3 July 2019, had for three years until October 2018 been one of the trustees of GambleAware.617 Until then, other trustees also had links with the industry.

576.In views which were generally supportive of GambleAware, Ministers confirmed: “A good deal of the criticism that GambleAware faces relates to a perception that industry funding undermines its independence. However, GambleAware is a fully independent charity which has had no industry representation on its board since 2018.” We are glad to say that none of the current trustees seems to have an industry background; but it is more than strange that the major charity whose object is the prevention and treatment of gambling harm should not only be funded by the gambling industry but, until recently, had persons with very close links to the industry among its trustees.

Research

577.It is in the context of the commissioning and funding of research that the lack, or perceived lack, of independence of GambleAware comes to the fore, and this distrust looks set to continue for as long as GambleAware is responsible for raising and commissioning research while being funded by the industry through a voluntary levy. There was no shortage of witnesses, mainly from the academic community, prepared to tell us that any research paid for from the voluntary levy, and hence any research commissioned by GambleAware, was automatically tainted. Professor Orford told us that “There is really good evidence … on the way the current system, with the voluntary levy going to GambleAware, has influenced the type of research that is done and the way the findings of the research are interpreted … ”618 Dr van der Gaag, now the chair of the Advisory Board for Safer Gambling but speaking in a personal capacity, raised similar concerns: “What I observe is a lack of trust and credibility in the quality of research. We have a research community at the moment that is very divided. The issue is over funding and where that funding comes from. … It is critical to take all research out of that current voluntary system.”619

578.Professor Bev John and Professor Gareth Roderique-Davies thought that there was a perception (rightly or wrongly) among many academic researchers that GambleAware was not truly independent, and that many researchers would therefore not apply for funding.620 Dr May van Schalkwyk wrote:

“The UK’s leading institutions and academics are unlikely to accept industry funding as they may see the act of accepting and working with such funds as a threat to (1) their reputation (current and future), (2) the integrity of the research process, and (3) their aim of, and role in, protecting public health.”621

Dr Wardle made the same point:

“I now work at the London School of Hygiene and Tropical Medicine’s public health and policy faculty, and some of my colleagues, who are experts in prevention in other areas that we would want to learn from, absolutely would not take funding from GambleAware. That pattern is repeated in other public health policy units in other institutions, including the University of Sheffield.”622

And Dr John McAlaney, a trustee of the Gordon Moody Association, went further: “As an academic, if you accept funding from certain operators, you will not be invited to certain conferences and will be excluded from certain things.623

579.Tim Miller, an executive director of the Gambling Commission, made the point that it is not only the industry connection that can affect the validity of research; the activities of some researchers can also be criticised:

“the independence of research can equally be challenged when you have researchers who are starting to get into that kind of campaigning space. We want proper independent research and there is a space around gambling and a need for researchers, campaigners and policymakers. We have had too many examples of them wearing interchangeable hats.”624

We agree; a bias against the industry is no less liable to taint research than a bias in its favour. As the BGC rightly say, there is no appetite to conduct research on consumer benefits because of the stigma attached to industry involvement in any form of research: “it seems likely that academic experts will continue to feel intimidated about engaging in such work for fear of criticism, particularly on social media.”625

580.We think it likely that if GambleAware were now starting from scratch with its current structure and trustees it might, even though funded by the industry through the voluntary levy, be seen as sufficiently independent to be able to commission reliable high quality research. But that is not the position. It has to live with the reputation it has acquired. Some of the best researchers will not apply for funding because they believe their research would be seen as tainted; and this has become a self-fulfilling prophecy. It has now reached the stage that GambleAware “would wish to undertake only research that underpinned and supported our work in treatment and prevention, and we believe that other research is better commissioned through an independent research institution and not ourselves.”626

The Chadlington Committee

581.In an attempt to resolve the issue without having a mandatory levy imposed, in August 2019 the five major operators commissioned Lord Chadlington:

“to establish an independent Committee to recommend how to direct, monitor and evaluate the administration of any funds raised for safer gambling initiatives … We are committed to implementing any reasonable recommendations the Committee may make”.627

Lord Chadlington asked Lord Carlile to be the Deputy Chair of the Committee. Liz Ritchie, the co-founder of Gambling with Lives, was a member, and so for a brief time was Tracey Crouch MP, the former DCMS Minister who resigned over the delay in implementing the lowering of the stake for FOBTs.

582.The Committee reported in December 2019. Their recommendation was to establish a charity, Action Against Gambling Harms (AGH), which would be a “totally independent vehicle” and “insulated from any influence of any kind from the gambling companies and all interested parties”.628 Nevertheless, like GambleAware it would be entirely funded by voluntary contributions from the industry unless Lord Chadlington obtained contributions from other sources. Industry funding would include the salaries of the CEO and all the staff, and of course all the research commissioned.

583.The Committee’s Summary of Conclusions states:

“The Charity is, however, administering the gambling companies’ money. Therefore, it is perfectly reasonable that the gambling companies should share with the Charity the priorities which they believe are important, the research they think the industry needs, the treatment they think is urgent and the educational steps which they believe should be taken.”629

584.The report goes on to state that to ensure any contact between the industry and AGH is transparent, all communications will be published online. Any proposal from a company encouraging AGH to fund a specific supplier will result in that company being blacklisted.

585.AGH was registered as a charity on 7 February 2020. When Dr Moyes and Mr McArthur gave evidence for the Gambling Commission on 11 February we asked whether in their view there was a sufficient degree of separation between AGH and the gambling industry. Dr Moyes replied:

“That is something we have raised with Lord Chadlington and Lord Carlile in correspondence and in discussion. We are open to persuasion. At the moment, we slightly wonder whether the organisation is as insulated from the industry as Lord Chadlington believes it is, but we are definitely open to persuasion.”630

586.This prompted Lord Chadlington and Lord Carlile to write to our Chairman a letter631 setting out in great detail all the steps they had taken and concluding: “… we did not wish your committee to be left in any doubt that our insulation from the gambling industry is not some add-on option but, on the contrary, it is at the centre of our philosophy and key to our very existence.”

587.It is certainly the intention that AGH should be seen to be more insulated from the industry, and we are impressed by all that Lord Chadlington and his Committee have done to attempt to resolve the problem. Yet, like Dr Moyes, we continue to entertain doubts as to whether research commissioned by AGH will be trusted any more than research commissioned by GambleAware. The industry funding is still voluntary, the charity will itself be funded by the industry, and the gambling companies expressly retain the right to share with AGH their views “on the research they think the industry needs, the treatment they think is urgent and the educational steps which they believe should be taken.”632

588.We are not in any way suggesting that the trustees or staff would be biased in favour of the industry, or indeed against it; but we do believe that the perception of bias that has so inhibited high quality independent academic research will linger.

589.We do not believe that the grant giving charity proposed and set up by Lord Chadlington’s Committee, largely funded by the industry on a voluntary basis, will be seen to be sufficiently independent for its research to be any more trusted than research commissioned by GambleAware.

590.Lord Chadlington was commissioned to establish a new independent body, and that is what he has done, but we question whether a new body is needed. Dr Wardle made this important point:

“There needs to be a proper research infrastructure and a strategy where the research questions contribute to the questions in the strategy. It needs to be completely independent. If it was up to me I would be running it partially through the research councils, because that infrastructure is already set up. You do not need to set up a new centre for gambling studies when that infrastructure already exists.”633

591.We agree. We do not believe that there is necessarily a need for a completely new body to be set up for the commissioning of research. Such reputable and trusted bodies already exist in the shape of the research councils, in particular the Economic and Social Research Council (ESRC) and the Medical Research Council (MRC). We accordingly spoke to Professor Jennifer Rubin, the Executive Chair of the ESRC, and we are very grateful to her for her assistance.

592.As Ministers have pointed out to us, researchers are already free to direct proposals for gambling focussed research to the research councils; “the Economic and Social Research Council and the Medical Research Council have funded research into gambling in the past and we would welcome them funding more such projects in the future.”634 Professor Rubin indeed told us that they had very recently allocated £580,485 for research into the impact of the Covid-19 lockdown on gambling.

593.Professor Rubin suggested that an independent commissioning body linked to the regulatory body would be able to fund research from a wider range of researchers than ESRC eligibility requirements currently allow, and might help ensure that research findings are well linked in to the organisations best placed to act on them. She told us that the ESRC would welcome the opportunity to advise on how independent commissioning might best be taken forward, and what part UK Research and Innovation (UKRI), the umbrella organisation of the seven research councils, could play. She acknowledged the Committee’s point that researchers and others do not perceive as independent research which is funded by the voluntary levy or commissioned by a body in which the industry play any part.

594.We recommend that the Government should work closely with UKRI and ESRC who can advise on a structure for the commissioning of gambling-related research, funded by the mandatory levy, which would be independent of industry involvement and would be understood to be so by researchers and others.

Availability of data for research

595.One of the main problems for researchers in this field is the lack of data available to them. There is no shortage of data—the gambling companies have made clear on a number of occasions that they have very full and detailed data, especially in relation to online gambling. Bournemouth University told us:

“The scope and richness of data that flows between the gambler and the operator in online gambling has increased substantially since the publication of the Act, as has the ability of the operators to use data analytics predictive modelling to identify current and future problem gamblers … Greater transparency and access to this data (anonymised if appropriate) by researchers, public health bodies and regulators can substantially improve our understanding of how gambling harm is distributed. Online gambling data in particular can be used to map the demographics of gamblers, often also including an approximation of their physical location. This in turn can be used to make an estimation of factors such as socio-economic status.”635

596.Such data has however not normally been made available to researchers, but there are exceptions. GVC told us of a partnership they have with Harvard:636

“We believe that more research, in a variety of areas is needed to better understand the scale of problem gambling, and to identify the most effective way of reducing this. That is why key to underpinning our flagship Safer Gambling strategy, is a new partnership between GVC and Harvard University to produce cutting edge research on problem gambling. This 5-year partnership will see us invest $5 million with Harvard’s specialised Division on Addiction, providing them with access to our anonymised data sets, for independent and robust scrutiny, and to evaluate the effectiveness of our current systems and procedures. … These data sets will also be open sourced so that other academics and research institutions can utilise them for similar purposes. We are keen to extend the benefits of this collaboration with the rest of the industry, sharing our learnings and knowledge from the partnership.”

597.The research by Harvard will no doubt be “independent and robust”, but its purpose is to enable GVC to evaluate their procedures. It is important that the data should be made equally freely available to other researchers, not just by GVC but by all data holders.

598.Gambling companies should make freely available to researchers, and to those commissioning research, data sets with the information they have about those gambling with them online, and their communications with them (anonymised if necessary). Similar information in relation to those gambling offline should also be provided if it is available.

Education

599.In their written evidence637 the Government told us that they believe many of the factors that cause gambling addiction, or are a consequence of gambling, are already addressed in the school curriculum, which includes developing young people’s financial literacy through topics on the importance of personal budgeting, money management, credit and debt, and the need to understand financial risk. For the future, the subject of Health Education, which would be mandatory in all state-funded schools from September 2020, would include teaching young people about the risks relating to gambling including the accumulation of debt. The Government expected many schools to deliver the new subjects as part of their existing Personal, Social, Health and Economic (PSHE) education. DfE was working with schools and teachers to improve access to high-quality resources across the teaching requirements, including on gambling.

600.The Government also told us that DfE had published in June 2019 Teaching online safety in schools—new non-statutory guidance aiming to support schools in teaching pupils how to stay safe online within new and existing school subjects. This guidance is part of the Relationship and Sex Education which is to become compulsory in all state-funded secondary schools from September 2020.

601.The Government said: “The guidance addresses many of the online issues that are linked to gambling and online advertising.”638 And this is true, but if one looks at the guidance,639 in the space of 30 pages there are only two specific mentions of gambling. The first deals with the reasons for age restrictions and age verification in a number of contexts, of which gambling is only one. The second suggests that the health education content could cover “the risks related to online gambling including the accumulation of debt”, and that teachers could explain “that the majority of games and platforms are businesses designed to make money. Their primary driver is to encourage users to be online for as long as possible to encourage them to spend money (sometimes by offering incentives and offers)”. This is very welcome as far as it goes.

602.GamCare told us that “education delivered to young people across Great Britain, whether in formal or informal settings, is a vital way to increase understanding and strengthen resilience regarding gambling and the risks of gambling-related harms developing in later life.”640 In oral evidence Ms Hemmings, said:

“Young people receive education about other risky behaviours such as smoking, drinking and sex. However, they have not often received education around gambling. Our youth education programme goes into schools and has trained over 16,000 young people over the past couple of years, as well as youth-facing professionals.”

She added: “We have had the youth education programme that we run externally evaluated to ensure that it is raising young people’s awareness, knowledge and understanding of what problem gambling might look like.”641

603.Plainly she, and GamCare, believe that money spent on education is money well spent. Of our witnesses, they are almost alone in thinking this. The Royal College of Psychiatrists said:

“Acknowledging the superiority of tangible interventions will remove the need for large investment in educational projects that Public Health England or the World Health Organisation have deemed to be less successful than interventions at a more societal level. Availability of gambling rather than education is an area on which to focus far more.”642

Gambling with Lives thought that, while education does have a place, it should not be considered as the major preventative measure and should only be considered alongside other initiatives.643

604.Professor Orford went further, suggesting that education might even be counterproductive:

“Unfortunately education is one of the weakest forms of prevention. The results are very much the same as those found in the case of alcohol and drugs–it can have an immediate effect on knowledge and attitudes but its longer-term effects on behaviour are minimal. In the case of gambling it can be successful in reducing misconceptions about gambling, increasing knowledge of problem gambling, and changing attitudes towards gambling, but it meets with limited success in reducing subsequent gambling behaviour. At best it is naive. Worse, gambling education may well be counterproductive. The encouragement to gamble sensibly or responsibly actually contains two messages: one, the apparent surface message, encouraging behaving sensibly or responsibly; the other, the latent message, that to gamble is acceptable and normal. Educational approaches, particularly in a developing or expanding market, may actually be making matters worse not better, contributing inadvertently to increasing normalisation of gambling. Education has its place but needs to be planned with care and should not dominate.”644

605.Before further substantial sums are committed to educating children and young people about gambling-related harm, an assessment is required to discover whether education is effective in reducing the risk of harm in later life, and to provide an evidence base for developing an effective education intervention in schools. These should ideally be evaluated with a field study methodology, where children either receive some type of gambling education, or some children are put in a control condition with no gambling education. Gambling behaviour is then tracked over a period of time and compared across the conditions in order to deduce gambling education’s causal effects.

606.The Government should commission an assessment of the long-term impact of teaching secondary school children about the risks related to gambling. When visiting schools, Ofsted should consider whether they have an adequate policy on the teaching of gambling-related harm.

Treatment

607.Since it is agreed by most people involved, including the Secretary of State for Health, that “gambling addiction is a mental health issue,”645 the NHS has the same duty to treat it as to treat any other disorder. Yet until recently NHS involvement has been minimal, and even now it is only beginning to get off the ground. The Government told us:

“The NHS Long Term Plan includes a commitment to expand geographical coverage of NHS services for people with serious gambling problems, and work with partners to tackle the problem at source. As set out in the Long Term Plan Implementation Framework, NHS England and Improvement (NHSE/I) has allocated up to £1m for gambling harm services in 2019/20. This includes targeted funding to develop a hub and spoke model for problem gambling from 2019/20. This hub and spoke model will comprise of central clinics which have satellite clinics in neighbouring populations. Specialist face-to-face NHS treatment for gambling addiction has only been available in London but the Long Term Plan is making treatment available across the country. Up to 15 NHS clinics are being opened by 2023/24.”646

608.The critical words here are “long term”. On 24 June 2019 the NHS announced that the first NHS gambling clinic for children would open that year as part of a new network of services for addicts being rolled out as part of the NHS Long-term Plan.647 The announcement stated:

“Up to 14648 new NHS clinics are being opened—starting with the NHS Northern Gambling Service in Leeds this summer [2019], followed by Manchester and Sunderland. The National Problem Gambling Clinic in London will also offer specialist help for children and young people aged 13 to 25 as part of an expansion which will also ramp up treatment for adults.”

609.Sir Simon Stevens, the chief executive of NHS England, said:

“This action shows just how seriously the NHS takes the threat of gambling addiction, even in young people, but we need to be clear—tackling mental ill health caused by addiction is everyone’s responsibility—especially those firms that directly contribute to the problem. This is an industry that splashes £1.5 billion on marketing and advertising campaigns, much of it now pumped out online and through social media, but it has been spending just a fraction of that helping customers and their families deal with the direct consequences of addiction. The sums just don’t add up and that is why as well as voluntary action it makes sense to hold open the possibility of a mandatory levy if experience shows that’s what’s needed. A levy to fund evidence-based NHS treatment, research and education can substantially increase the money available, so that taxpayers and the NHS are not left to pick up a huge tab.”649

610.We can well see why Sir Simon is anxious that “the NHS are not left to pick up a huge tab” for these developments. No doubt it was not open to him to argue that a mandatory levy should be more than a “possibility”, but it seems to us that the argument for one is irrefutable. For the future, this is a very welcome development. For the present, we are left with “up to” £1 million allocated in the year 2019–20, and the money expended by those currently supplying treatment services, mainly funded by the voluntary levy.

611.Problem gambling is a common mental health disorder, and the NHS has the same duty to treat it as to treat any other disorder. It should establish the proposed 15 new clinics before 2023 and a comparable number within the following few years. This will require national leadership and a national training programme.

The National Problem Gambling Clinic

612.Until the NHS Clinic in Leeds was opened last year, the only clinic specialising in the treatment of gambling disorders was the National Problem Gambling Clinic in London, which is part of the National Gambling Treatment Service and is jointly commissioned by GambleAware and NHS England.

613.The National Problem Gambling Clinic employs psychiatrists, clinical psychologists and counselling psychologists trained in the treatment of a range of mental health disorders and addictions. The core clinical team have a combined 30 years of experience in the management and treatment of gambling disorders. The clinic has also served an essential training function: since opening, over 100 psychology and psychiatry professionals have worked in the clinic, going on to work in other mental health areas. The clinic offers a number of different services for problem gamblers, including individual psychological support, support groups, psychiatric reviews, medication for problem gambling and aftercare. Psychological support takes the form of cognitive behavioural therapy (CBT), a form of therapy that can be used to help people identify and manage the triggers to their problem behaviour, challenge irrational thinking and find ways to better cope with feelings, thoughts and urges that may precede a gambling episode.

GamCare and Gordon Moody

614.Apart from the National Problem Gambling Clinic, most of the treatment is provided by GamCare, Gordon Moody, and the eight other charities and organisations which can be the recipients of funding from the industry, either directly or through GambleAware. The industry can choose how much, and to whom, it will contribute its voluntary funding. We have already commented on the defects of these funding arrangements.650

615.GamCare sent us full written evidence in September 2019, but we received more up to date information when Ms Hemmings, gave evidence to us in March 2020. She told us that GamCare has been in existence for 23 years, and is the largest provider of treatment for gambling-related harms. The figures from the National Gambling Helpline, which they operate, show that they received over 35,000 calls to their helpline from April 2019 to the end of February 2020. Of callers, around 55% gamble online and 45% offline. The online group was mainly a combination of sports betting, casinos and slots. Offline gamblers were people in betting shops, with very small cohorts in casinos and other offline venues. They had more than 10,000 people in their treatment system.651

616.Ms Hemming conceded that this was not a representative group of gamblers, since it consisted only of those who phoned the National Gambling Helpline when they were concerned about their gambling. She compared the 3% of problem gamblers with the 17% or 18% of dependent drinkers accessing treatment, and a still higher proportion of drug users. She referred to “the stigma that people often feel about having those sorts of issues. It is hard to come forward for treatment, a bit like how it is hard to talk about mental health problems more generally”.652 In their written evidence GamCare told that they hoped that the 3% of problem gamblers seen in treatment would over five years increase to 10%, and hopefully to 15% over the longer term.653

617.Gordon Moody, which has been operating for nearly 50 years, provides:

618.Mr Hickey explained that Gordon Moody supported those most in crisis, who were beyond breaking point: 99% of the people they supported were “on the cusp of committing suicide.” In the past year they had supported 650 people.

“If you came in and asked them about their gambling addiction, they would all say that it is the hidden addiction. They have got away with nobody knowing about it for a very long time, some of them for 20 years or more. The difference between gambling and drug or alcohol addiction is that you can see a physical change in somebody with the latter.”655

619.There is no point in spending money on treatment unless that treatment is effective. GamCare explained in their written evidence that they use the Problem Gambling Severity Index (PGSI) and Clinical Outcomes in Routine Evaluation 10 (CORE-10) measures to assess treatment outcomes. Their Annual Statistics 2018/19 shows the improvement in both PGSI and CORE-10 brought about by its treatment programmes in recent years. According to the PGSI, clients who were gambling problematically when entering treatment showed an average improvement of 16.1 (significantly reduced risk) upon successfully completing their treatment plans.656

Table 16: GamCare clients’ PGSI from assessment to treatment

2015/16

2016/17

2017/18

2018/19

PGSI at assessment

19.0

19.3

19.6

19.5

PGSI at treatment end

4.1

3.7

3.6

3.4

PGSI

difference

14.9

15.7

16.0

16.1

Source: GamCare, Briefing Paper - GamCare Annual Statistics 2018/19 (January 2020): https://www.gamcare.org.uk/app/uploads/2020/01/Briefing-Paper-GamCare-Annual-Statistics-2018–19.pdf [accessed 28 April 2020]

620.Ms Hemmings explained: “We and our partner network, Gordon Moody and the NHS clinic all use the same measures at the start of treatment, as well as throughout and at the end of it … We find that 75% complete that treatment episode successfully. When they finish it, they have significantly reduced gambling and improved quality of life.”657 Mr Hickey added:

“[Of the people we support] 74% of people complete the programme and 91% would recommend it to a friend, which are very comparable results to GamCare. The key thing with us is that we also run a number of sessions for ex-residents: they can come in and support the current residents through peer-to-peer support.”658

621.What seems to be lacking is any significant research to identify the strengths, weaknesses and relative effectiveness of these forms of treatment, and whether some treatments are more effective with certain cohorts.

622.We recommend that the National Institute for Health and Care Excellence (NICE) conduct an independent assessment of the various treatments available, and prepare guidelines showing which are the most effective.

623.Increasingly, the existing providers of treatment will find themselves working with a growing number of NHS clinics. Ministers wrote:

“The NHS will continue to work with the charity sector going forward, as it opens more clinics to meet its NHS long-term plan commitment of up to 15 specialist clinics. What is important is that the NHS and charity sector work together, learning and sharing information to make the best use of resources and to realise the benefits of delivering aligned and complementary services.”659

We entirely agree, but differing working methods and different sources of funding may lead instead to a culture of competition. This cannot be allowed to happen.

624.The Government should develop a strategy to ensure that the NHS clinics and services work together with the existing charities to provide treatment, and to determine how resources will be allocated and patients referred between services.

625.Those drafting the written evidence of GamCare seem to us to have been at pains to present their organisation in the best possible light; and there is nothing wrong with this, if there is nothing wrong with the organisation. Frank evidence which casts a more critical light on the organisation is sometimes more helpful. On the all-important subject of training, the written evidence said: “Our practitioners are specially trained and can give clients the safe, confidential space they need to discuss how gambling affects them, and our team work with each client to find strategies to help them move forward in a positive way.”660 This does not entirely accord with what Ms Hemmings told us: “There is no specialist training to work in gambling treatment. Over time, that will need to change with specific qualifications. We provide staff with the training that they need to deliver our model of care depending on their role, and we require them to have qualifications in related fields.”661

626.We particularly mention the issue of training because that was one of a number of matters which Ms Ritchie criticised when she gave us oral evidence, saying:

“We have heard a lot of concerns about GamCare counselling, and we have raised them over the years … I was shocked to come across job advertisements that said that counsellors were given two days’ training. They have a generic person-centred training, then two days’ training. Recently, I came across a job ad that did not require any clinical qualification at all.”662

627.Ms Ritchie criticised GamCare on other fronts. She alleged that “GamCare have industry people on their Board;”663 she said: “As far as we know, there is no proper suicide risk assessment, certainly not at the point of triage and referral, because the people on the phones are not clinically qualified, so they cannot be doing it;” and she added: “GamCare owns the only referral point, effectively, because it runs the helpline. As there is no training for GPs, there is no pathway through to the clinics, so in effect there is a conflict of interest, because, as far as we understand it, they refer to their own partner providers.”664

628.These are serious allegations, made at a public evidence session, and it is hardly surprising that when GamCare sent us supplementary evidence following their own oral evidence sessions, they took the opportunity to include in it four pages of what they call “factual clarifications”.665 Gambling with Lives “thought it would be helpful to respond to each of the points in [the] supplementary evidence,” and their response takes the form of an eight-page letter to Ms Hemmings, copied to our Chairman. This is not evidence to the Committee, but simply the latest instalment of “a long exchange of meetings, emails and letters between Gambling with Lives and GamCare over the last two years.” We have to accept that, whatever its defects, GamCare is, and for some time will remain, the largest provider of treatment for those suffering gambling disorders. It would be more helpful to adopt a constructive approach towards improving the service GamCare is able to offer.


573 In paragraph 564 we look at how funding of research, education and treatment in the UK lags behind other countries.

575 Department for Culture, Media and Sport, Modernising Britain’s Gambling Laws: Draft Gambling Bill, Cm 5878, July 2003, para 5.2: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/272068/5878.pdf [accessed 28 April 2020]

576 Gambling Act 2005, section 123(5)

578 Department for Culture, Media and Sport, Memorandum to the Culture, Media and Sport Select Committee on the Post-Legislative Assessment of the Gambling Act 2005, Cm 8188, October 2011: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/238137/8188.pdf [accessed 28 April 2020]

579 Gambling Act 2005 (Commencement No. 6 and Transitional Provisions) Order 2006 (SI 2006/3272) Article 2(4)

580 Gambling Commission, Strategy 2018–2021: Making gambling fairer and safer (November 2017) p 12: https://www.gamblingcommission.gov.uk/PDF/Strategy-2018–2021.pdf [accessed 28 April 2020]

581 Gambling Commission, National Strategy to Reduce Gambling Harms (25 April 2019): https://www.reducinggamblingharms.org/asset-library/national-strategy-to-reduce-gambling-harms.pdf [accessed 28 April 2020]

582 Simon Jack, ‘Bookmakers pledge £100m to avoid gambling crackdown’, BBC News (19 June 2019): https://www.bbc.co.uk/news/business-48690743 [accessed 28 April 2020]

583 HC Deb, 2 July 2019, col 1071

584 HL Deb, 2 July 2019, col 1344

585 Paddy Power Betfair is a division of Flutter Entertainment plc. Sky Betting and Gaming is a wholly owned subsidiary of The Stars Group, which is listed on the Toronto stock exchange. On 5 May 2020 Flutter Entertainment plc merged with The Stars Group. Paddy Power Betfair and Sky Betting and Gaming are therefore now part of the same group, though they were not at the date of the Minister’s statement.

586 The Government departments whose officials gave evidence on 16 July 2019 subsequently gave further details: “This will involve an initial increase from 0.1% to 0.25% in 2020, rising to 0.5% in 2021 and 0.75% in 2022 until it reaches 1% by 2023, estimated to amount to an annual contribution of approximately £60 million at that point … the five companies have committed to spend most of the funding on expanding treatment services, amounting to a cumulative total of approximately £100 million over the four year period.” Supplementary written evidence from the Department of Health and Social Care (GAM0020)

587 HC Deb, 2 July 2019, col 1072

588 Supplementary written evidence from HM Government (GAM0135)

589 Ibid.

590 The Horseracing Betting Levy Board was set up by the Betting Levy Act 1961, and is now governed by sections 24-29B of the Betting, Gaming and Lotteries Act 1963 as amended by, inter alia, the Horserace Betting Levy Regulations 2017, (SI 2017/589). The Betting, Gaming and Lotteries Act 1963, section 27(1A) sets the levy at 10% of a bookmaker’s profits above the exempt amount of £500,000.

591 HC Deb, 2 July 2019, col 1076

592 Gambling Act 2005, section 123(7)

593 Gambling Act 2005, section 355(4)(f)

594 Supplementary written evidence from HM Government (GAM0135)

595 HC Deb, 4 July 2019, col 1337

596 Written evidence from The Lotteries Council (GAM0030)

597 New Zealand Inland Revenue, ‘Problem gambling levy’: https://www.ird.govt.nz/duties/problem-gambling-levy [accessed 24 May 2020]

598 Gambling Commission, ‘List of organisations to which operators may direct their annual financial contribution for gambling research, prevention and treatment’: https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/General-compliance/Social-responsibility/Research-education-and-treatment-contributions.aspx [accessed 28 April 2020]

599 Gambling Commission: Reviewing the research, education and treatment (RET) arrangement (February 2018) para 24: https://www.gamblingcommission.gov.uk/PDF/Review-of-RET-arrangements-February-2018.pdf [accessed 28 April 2020]

602 Q 73 (Kate Lampard)

603 Licence conditions and codes of practice, Part II: Social responsibility code provision 3.1.1

604 Gambling Commission, ‘List of organisations to which operators may direct their annual financial contribution for gambling research, prevention and treatment’: https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/General-compliance/Social-responsibility/Research-education-and-treatment-contributions.aspx [accessed 28 April 2020]

606 Written evidence from the Gordon Moody Association (GAM0032)

607 Supplementary written evidence from GambleAware (GAM0128)

608 Written evidence from GambleAware (GAM0014)

609 QQ 71–79 (Marc Etches and Kate Lampard)

610 Supplementary written evidence from GambleAware (GAM0128)

611 Ibid.

612 Q 216 (Anna Hemmings)

613 Q 216 (Matthew Hickey)

614 Gambling Commission, Responsible Gambling Strategy Board and GambleAware, Research and Commissioning and Governance Procedure (November 2018): https://consult.gamblingcommission.gov.uk/author/copy-of-national-strategy-to-reduce-gambling-harms/user_uploads/research-commissioning-and-governance-procedure.final.nov-2018.pdf [accessed 28 April 2020]

615 ‘GambleAware board becomes entirely independent of industry’, iGamingTimes (10 October 2018): (https://www.igamingtimes.com/2018/10/10/gambleaware-board-becomes-entirely-independent-of-industry/ [accessed 18 July 2019]

616 Gamesys group, ‘Board of directors’: https://www.gamesysgroup.com/about-us/board-of-directors/ [accessed 28 April 2020]

617 GambleAware, ‘Announcement: GambleAware announces new trustees’, (4 October 2018): https://about.gambleaware.org/media/1807/2018–10-04-new-trustees.pdf [accessed 28 April 2020]

618 Q 21 (Professor Jim Orford)

619 Q 29 (Dr Anna van der Gaag)

620 Written evidence from Professor Bev John and Professor Gareth Roderique-Davis (GAM0023)

621 Written evidence from Dr May van Schalkwyk (GAM0094)

622 Q 22 (Dr Heather Wardle)

623 Q 218 (Dr John McAlaney)

624 Q 31 (Tim Miller)

625 Written evidence from the Betting and Gaming Council (GAM0068)

626 Q 77 (Kate Lampard)

627 Lord Chadlington’s Committee, Action Against Gambling Harms (December 2019)

628 Ibid.

629 Ibid.

630 Q 152 (Dr William Moyes)

631 Not treated as evidence to the inquiry, and not published.

632 Action Against Gambling Harms

633 22 (Dr Heather Wardle)

634 Supplementary written evidence from HM Government (GAM0135)

635 Written evidence from Bournemouth University (GAM0001)

636 Written evidence from GVC Holdings Plc (GAM0042)

637 Written evidence from HM Government (GAM0090)

638 Ibid.

639 Department for Education, Teaching online safety in school: Guidance supporting schools to teach their pupils how to stay safe online, within new and existing school subjects (June 2019): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/811796/Teaching_online_safety_in_school.pdf [accessed 28 April 2020]

640 Written evidence from GamCare (GAM0063)

641 QQ 212 and 214 (Anna Hemmings)

642 Written evidence from the Royal College of Psychiatrists (GAM0091)

643 Written evidence from Gambling with Lives (GAM0098)

644 Written evidence from Professor Jim Orford (GAM0019)

645 Rt Hon Matt Hancock MP, Secretary of State for Health and Social Care, Speech at the Reception for Gambling with Lives, Houses of Parliament, 26 February 2020

646 Written evidence from HM Government (GAM0090)

647 NHS, The NHS Long Term Plan (January 2019) para 2.36: https://www.longtermplan.nhs.uk/wp-content/uploads/2019/08/nhs-long-term-plan-version-1.2.pdf [accessed 28 April 2020]

648 Written evidence from HM Government (GAM0090); the number given is 15.

649 NHS, ‘NHS to launch young people’s gambling addiction service’, 24 June 2019: https://www.longtermplan.nhs.uk/nhs-to-launch-young-peoples-gambling-addiction-service/ [accessed 28 April 2020]

650 Paragraphs 570–574

651 Q 210 (Anna Hemmings)

652 QQ 211, 217 (Anna Hemmings)

653 Written evidence from GamCare (GAM0063)

654 Written evidence from the Gordon Moody Association (GAM0032)

655 Q 210 (Matthew Hickey)

656 Written evidence from GamCare (GAM0063)

657 213 (Anna Hemmings)

658 Q 213 (Matthew Hickey)

659 Supplementary written evidence from HM Government (GAM0135)

660 Written evidence from GamCare (GAM0063)

661 Q 215 (Anna Hemmings)

662 Q 179 (Liz Ritchie)

663 Q 176 (Liz Ritchie)

664 Q 180 (Liz Ritchie)

665 Supplementary written evidence from GamCare (GAM0124)




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