The UK Gambling Commission (UKGC) is seeking input on how to minimize the excesses of VIP gambling programs as it gets some tough input on gambling advertising from its critics.
On Friday, the UKGC issued an update on the challenges it issued to the gaming industry last October to make gambling a safer product for consumers. That challenge included tasking a number of UK operators with heading up ‘working groups’ on certain areas of concern.
Gambling critics likened this to putting foxes in henhouses, so the UKGC also sought input from ‘Experts by Experience,’ a self-described group of individuals “who have suffered a wide range of gambling harms, including recovering gambling addicts, family and partners of addicts, and those who have lost children to gambling suicides.”
The three areas of focus in the UKGC’s update are VIP incentive programs, game & product design, and the use of Ad-Tech to ensure youths and vulnerable individuals weren’t exposed to online gambling promos. Much of the info below was previewed in April, but here goes nothing.
HIGH-VALUE, HIGH PROBLEMS
The VIP incentive working group led by GVC Holdings and the Betting & Gaming Council (BGC) industry association crafted a list of industry commitments, including limiting VIP incentives to gamblers 25 years or older, as well as ensuring that operator teams that oversee VIP programs don’t receive commission or bonuses based on customer spending and/or losses.
The other recommendations are fairly standard, including greater scrutiny of customers’ spending sustainability and other KYC components. Operators will also have to maintain full VIP audit trails of info gathered and decisions taken, and assign a senior exec or board member who will be accountable for VIP program operations.
Understandably, the ‘Experts’ took a harsher stance, suggesting VIP programs should be banned outright. Short of that, the Experts want to see a ‘single-customer view’ solution in which a VIP’s activity would be shared with all UK licensees to ensure “a more informed and consistent interaction when appropriate.”
The UKGC said the issue of incentives was “complex” and required further consideration, but operators shouldn’t offer any tailored incentives or bonuses if they can’t ensure the perks are being offered “in a manner which is consistent with the licensing objectives.”
The UKGC said it will monitor the effectiveness of the working group’s new VIP code “through targeted compliance assessments and by monitoring the volume of enforcement casework.” The UKGC will also weigh VIPs’ share of operator revenue and monitor how many VIPs fail to clear the new KYC hurdles.
The UKGC has opened a consultation for the public to submit views on how operators’ interactions with high-value customers. (Make your views known here.)
GAME DESIGN
The UKGC established two working groups to consider both land-based and online game design, headed by Scientific Games Corp and Playtech, but COVID-19 put the kibosh on land-based gaming so the results focus on the online aspect.
The proposed changes involve imposing a minimum slots spin speed of 2.5 seconds, eliminating features that accelerate game play (quick spin, turbo play) as well as Slam stop or Stop reels. Split-screen games that permit multiple stakes on different slots are also verboten.
The BGC is drafting a code based on these results, but as the changes involve some serious re-engineering of a wide range of product, the BGC doesn’t expect to release its game code before September 30. The BGC also wants to establish a new working group to explore in-game features, but details are scant at present.
The Experts panel agreed that speed of play was a key factor in addictive behavior, so it wants to see all gaming products slowed down. They also want limits on stake and prize size, mandatory caps on time spent playing, and a classification system based on a game’s addictiveness.
The Experts strongly disagreed with letting the BGC or any other industry body run a ‘Testing Lab’ for new games, and believe both old and new games should be vetted by a body independent of the industry.
The Experts also agree with recent proposals to limit stakes per spin, but they’d like to see the proposed £2 limit cut in half (although some more open-minded types suggested £5 might also be appropriate).
The UKGC’s view was that the working group’s proposed code “falls significantly short” in a number of areas, including the proposal to increase the maximum stake per slots spin if a customer passes certain KYC checks. The UKGC similarly found fault with the group’s unwillingness to adopt a proposal to slow down slots play even further if a single gaming session exceeded one hour.
The UKGC also felt the September 30 timeline for the publication of the industry’s game code “does not seem fit for purpose” given the alleged transfer of gamblers’ affections from sports to online casino during the pandemic lockdown.
ADVERTISING
Sky Betting & Gaming, now part of the Flutter Entertainment empire, led the working group on advertising. Its recommendations include a common list of negative search terms (like “how do I quit gambling”) and suppression websites to shield vulnerable groups from gambling ads.
Most of the other recommendations involve applying technology to customer data to steer promos away from individuals under 25 years, particularly on social media platforms. Marketing affiliates will also be held to a code of conduct to avoid some of the excesses of the past.
The Experts largely supported these measures, but suggested “all general placements of online ads” be banned until the industry can demonstrate that today’s technology is up to the challenge. They also want to see regulation of gambling-style online social games.
The Experts were “very critical” of the industry’s responsible gambling slogans, such as the ‘When The Fun Stops, Stop’ campaign, suggesting “the gambling equivalent of ‘smoking kills’ would be more appropriate. The Experts also said responsible gambling ads need a “much tougher” message and shouldn’t allow operators to simultaneously plug their brand.
The UKGC said it was satisfied with the industry’s approach but suggested they focus on being more pro-active than reactive. The UKGC also recognized that the industry’s efforts were “limited by the extent of influence over third parties, such as platform providers” but urged ongoing engagement with these providers to realize their goals.