INSIGHT
SOCIAL RESPONSIBILITY:
WHY SHOULD AFFILIATES CARE?
With standards of social responsibility under political and media scrutiny in the UK, operators are
vulnerable to a change of sentiment that could reverse their freedom to advertise and develop bolder
new products. Affiliates however also need to also start seeing themselves as integral to industry efforts
to demonstrate improving standards, writes Ron Finlay of Senet Group.
‘THE SUICIDE OF the 25-year-old
son of a Government Minister has been
announced…it is thought he had a history
of depression and gambling addiction.’
Fictional, thankfully. But plausible, yes?
And would it be beyond the bounds
of imagination for the more scurrilous
sections of the media to link a tragic story
like this to an affiliate who had recruited
the boy in question through a pornography
or live streaming site? Most affiliates don’t
behave this way, but it only takes one for all
to be tarred with the same brush.
The consequences aren’t difficult to see.
Outcry over gambling-related harm and
a clamp-down on what has been a highly
liberal regime for the industry since the
2005 Gambling Act.
But if this is only fiction, why should
affiliates care about social responsibility?
The answer is that, while a shock to
the system like this would ratchet up the
political stakes, a change in the regulatory
regime is not dependent on it.
You have only to look closely at the text
of speeches by senior regulators or articles
they’ve written to catch the potential
direction of travel. For example, Sarah
Harrison, chief executive of the Gambling
Commission, speaking in November 2015:
“Social responsibility and consumer
protection is – and will continue to be – high
on the Gambling Commission’s agenda.
All sectors need to be mindful of the harm
that gambling can cause. It’s no good alone
blaming particular products in particular
environments…Greater freedom brings with
it greater responsibilities. As you strive for
greater freedom, you will have to be able
to demonstrate that you have placed good
consumer outcomes and social responsibility
at the heart of your thinking.”
Electronic gaming – whether on
machines or online – may not yet be in the
‘last chance saloon’, but the clock is ticking.
The online gambling industry – and
affiliates as a result – have been benefiting
from massive growth in the last 10 years.
But, even though gambling prevalence
surveys have not indicated a rise in the
rate of problem gambling, as the market
grows in size, more people are experiencing
harm and – even on a conservative
estimate – 250,000 problem gamblers in the
UK alone is a figure no government can
ignore. Media stories and lobbying by the
industry’s detractors add to the climate of
concern among law-makers, making the
whole industry vulnerable to a change of
sentiment that could reverse the freedom
that operators now have to advertise and
develop bolder new products.
“Affiliates are vulnerable.
A high-profile gamblingrelated tragedy, or even a
more measured evaluation
of risk of harm versus social
benefit, could be laid at
their door.
If the evidence in the Triennial Review of
stakes and prizes this year is that the risk of
harm of the present regime is outweighing
the benefits – for social pleasure, jobs and
the economy – rules will be tightened and
growth could be choked off. Contrary
to received wisdom in some parts of the
industry, regulators are not concerned only
about FOBTs. Politicians and officials are
all too aware of the casino that people carry
around in their pocket. History tells us that
after one issue is addressed, a new issue
appears on the horizon.
Affiliates are vulnerable. A high-profile
gambling-related tragedy, or even a more
measured evaluation of risk of harm versus
social benefit, could be laid at their door.
Why? Because of potential failures to act in
a socially responsible way.
Apart from recruitment methods, take
self-exclusion – a big focus for Government
and regulators right now, with a mandatory
multi-operator scheme for the remote sector
due for April 2017. What mechanism are
affiliates and operators putting in place to
ensure that marketing ceases to customers
who have self-excluded? If, for example,
an affiliate sends an HTML mailer and
the recipient, who has self-excluded,
complains, the operator should track
the link and ensure the email address is
removed from future mailings. If this does
not happen, affiliate and operator could
come under the spotlight and a whole new
can of worms will be opened.
It was to improve standards of social
responsibility that four big bookm akers –
William Hill, Ladbrokes, Coral and Paddy
Power – established Senet Group in 2014.
Further operators in remote gambling and
other segments of the market are expected
to join this year. The Senet Group has
built a code of conduct that goes beyond
existing statutory regulation to demonstrate
that its members are setting high standards
of social responsibility, and it is holding
them to account to keep to these pledges,
with sanctions available for any breaches.
A chain is only as good as its weakest
link. If in the process from customer
acquisition to operation to increased
revenue some players lose control and the
fault is down to the conduct of an affiliate,
the reputation of the whole industry
can suffer and a ton of bricks could fall.
Why should affiliates care about social
responsibility then? It’s plain to see.
RON FINLAY is chief
executive of gambling
watchdog Senet Group. It
was created in September
2014 by four of Britain’s
leading gambling companies
– William Hill, Ladbrokes, Coral and
Paddy Power – in response to public
concerns on gambling, and gambling
advertising in particular.
iGB Affiliate Issue 55 FEB/MAR 2016
79