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21 June 2018

Engagement on gambling policy: a retrospective

Engagement on gambling policy: a retrospective

“Therefore, whilst we welcome some of the increased protections that are likely to be offered through legislation, we are concerned that the potential increase in problem gambling and the need to prevent proliferation of negative anti-social consequences should remain as a matter of priority at the forefront of the committee's deliberations.” 

This is from the Evangelical Alliance’s submission in 2003 to the parliamentary committee scrutinising the draft gambling bill. Before that, the Evangelical Alliance had contributed to the Budd Review of gambling legislation published in 2001, which recommended widescale deregulation of the gambling sector.

Why this long-standing engagement?  

When we were contacted by our members around the turn of the millennium, who were worried about new casinos opening in their community, we realised few people were speaking out on this policy area. 

So, we stepped up to fill the gap, together with the Salvation Army and the Methodist Church initially. As time went on, a Quaker campaign group, the Church of England, CARE, several church denominations, and expert academics joined our drive to promote gambling policy that protects the vulnerable and recognises the ethical and moral dimension to this area of public policy. This involved giving evidence to the parliamentary committee, scrutinising the draft bill, responding to consultations, taking part in advisory groups, and speaking out to the media. 

At the time of the Gambling Act going through parliament in 2005, our primary focus was on proposals for super-casinos. Although permitted in the original legislation, the final proposal in 2007 for a single super-casino in Manchester was criticised by the Evangelical Alliance. In a statement to the Telegraph, we said it was a, “poor choice for the poor. The area is deprived and the Evangelical Alliance is on record as saying that Manchester is not well enough equipped to deal with the social impacts of problem gambling”. 

After restricting plans for super-casinos from up to 30 to a single trial during the passage of legislation, this final remnant of the original damaging proposal was killed off in one of Gordon Brown’s first moves as prime minister. 

 Fixed-odds betting terminals  

Over the last decade focus has shifted to the debate around betting shops in local communities and two linked problems. First, the impact of high-stake machines located in betting shops, and the huge losses that could be accrued very quickly – thousands of pounds in under an hour. Second, the clustering of betting shops in poor communities as a perverse consequence of restricting each shop to four machines. The machines became increasingly important for the commercial sustainability of betting shops, with revenue from the machines outstripping over-the-counter bets in recent years. The fixed-odds betting terminals (FOBTs) found in bookmakers represented two thirds of all gambling machine revenue in 2016/17. 

In successive reviews, consultations, and meetings with ministers, civil servants and officials at the Gambling Commission, we pressed our case for action to tackle these twin problems. For many years this fell on deaf ears. We made our case to the parliamentary select committee, examining the 2005 Act following its implementation; in our written submission we called for the FOBTs to be completely removed from betting shops. 

This suggestion was rejected, moreover, the committee, in what was the high-water mark of a trend to ever-greater gambling liberalisations, called for removing the cap on machines to address the clustering problem, but with no regard to the impact on people’s gambling losses and the potential effect on their lives and the lives of those around them.  

When stakes and prizes for gaming machines were reviewed in 2013, there was a glimmer of hope in the Government’s approach, which called for evidence of harm caused by gaming machines, and particularly focused on the debate surrounding B2 machines – the terminals found in betting shops. In our response to the consultation we joined with different faith groups as well as newly established campaign organisations to call for a £2 stake on these machines, matching the stake level allowed on other machines in pubs and bingo halls. 

 Slow, but eventual, government action 

Five years ago, the Government deemed that there was insufficient evidence for a change in legislation, but called on the industry to improve its player protection procedures and required staff approval or registration for staking over £50. At this stage we were far from the only voices involved calling for government action, and the number of politicians recognising the damage huge losses were causing to individuals and communities grew, as did the column inches in the media that called for a policy approach that protected people rather than prioritised profit (and revenue for the exchequer). 

When the 2017 review came around there was an expectation of government action to address FOBT stake levels, and the consultation documents expressed an intent to lower the stake, but with a number of options ranging from the de facto status quo of £50 down to £2. Unsurprisingly, the betting shop companies pushed back with considerable force, making much of the prospective job losses if this key revenue component was cut, but neglecting to consider the cost to those losing vast sums on their machines. 

As much as a tussle between the industry campaigning to maintain its income and campaigners looking to protect people from addictive machine and the consequence of huge losses, this was a battle between government departments, with those in the Department of Digital, Culture, Media and Sport advocating a significant cut, and the Treasury, which did not want to lose the tax income from bookmakers. 

After significant briefings suggesting the review would go this way or that, the Government announced that it would cut the stakes to £2. The issue isn’t fully resolved as recent media coverage suggests the industry has won backing for an extended implementation period – one which they surely would not need if the stakes were permitted to rise. 

 What lessons can we learn? 

 As we reflect on more than 15 years of engagement on gambling policy, what are the key lessons we can learn? 

1. Long-term engagement matters. By being involved over many years, and the baton successfully passed between different staff members over that time, we were able to maintain involvement in key discussion forums, and connection to government channels.  

2. Sticking to a policy ask over a number of cycles of consultations, reviews and government responses, pays off. While we explored several options for mitigating the harmful effect of FOBTs, we and others focused on and stuck to the ask to reduce the stake to £2. 

3. Working with others makes a difference. We have worked with a wide range of Christian groups and denominations, each with its own focus, but working together on a common cause. We have also worked with academics, medical professionals and other campaigns to strengthen our case.  

4. Engaging with official bodies provides opportunities. Through involvement in formal and semi-formal bodies such as the Gambling Commission, the government department and the Responsible Gambling Strategy Board, we have not only been able to make our case, we have learnt more about the policy environment, built expertise and developed relationships. 

5. Expertise matters. We committed to becoming well informed and precise in what we knew and what we asked for. When we spoke to government we made sure we had done our homework, and when we engaged in the media we were careful to know what we were saying, what others might respond with, and how we could make our case to have the greatest influence.