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December 2022 - Six years on and they still hate us

Six years ago, in a gambling publication I wrote:

"We need to mobilise our supporters, our staff and our customers and show our detractors that what we do is a part of our culture, our heritage and our future. Gamblers are happier people than non-gamblers."

Six years on and where we are:

Since 2016, British politics has changed dramatically. We have had five Prime Ministers in six years whereas the previous five Prime Ministers were collectively in office for 33 years. We’ve had Brexit, we’ve had Covid and we’re in the middle of a European war after Russia’s invasion of Ukraine.


From a gambling perspective, we’ve had seven Ministers responsible for gambling and the first effective abolition of a legal gambling product due to Ministerial decree, Fixed Odds Betting Terminals (FOBTs). The April 2019 reduction is stakes, brought in by the anti-gambling Minister, Tracy Crouch MP, against the advice of the regulator and of any evidence, saw the average number of B2 (FOBT) machines go from 32,798 in 2019 to 84 (-99.74%) in 2021 and consequently the number of betting shops went from 8,304 in in 2019 to 6,462 (-22.2%) in 2021.


The victory of the anti-FOBT lobby, mostly funded by a Vegas-based casino games salesman multi-millionaire was to my mind the tipping point in the British gambling debate. Not only did it show that an evidence base could be bought and paid for, as could Parliamentary groups in both Houses and that grieving parents can sway Ministers with false claims about gambling related suicide, all so that moralistic newspapers could whip up a fervour of discontent with our industry. The outcome being that gambling has become an intensely toxic topic in Westminster and Whitehall. The FOBT debate also showed that our industry was found incredibly wanting, displaying amateurish lobbying skills which left it unable to fight its corner. This was also hindered by certain industry sectors who were too naïve to realise that by attacking FOBTs they would create political blowback. Never forget that an attack on one bit of gambling is an attack on all – politicians don’t discriminate between sectors and the constant cycle of ever increasing regulation effects everyone.


Where we are now is waiting for a much delayed White Paper which looks like being a watered down version of the prohibitionist manifesto that was being put forward in the Summer under the equally anti-gambling Minister, Chris Philp MP. I have been arguing for a couple of years now that this legislative consultation exercise, what a White Paper is, is almost irrelevant to the future of the British Gambling industry as the biggest change to British gambling and the seeds of its very destruction has already happened. That is the adoption of the Public Health approach to gambling (PHAG).


As has happened in academia and many public organisations in the English speaking world during this timeframe has been the rise of ‘Woke’ ideology. By this I mean specifically a Marxist Post-Modernist approach to social sciences that emphasises conflict between groups, promotes subjective self-truths over facts and lived experience over science based evidence. At the same time there has been the evolution of a new form of Public Health, which is no longer about curing disease and vaccinating people but is about changing personal behaviours in the pursuit of perfect health, regardless of the choices of the individual. Both methodologies demand that academics no longer remain politically neutral, seeking just the facts for others to decide policy, they demand that academics become political activists and that facts are no longer of primary importance when pursuing a policy objective. PHAG in the UK has been adopted wholesale from New Zealand, Australia and Canada, ignoring the completely different regulatory, socio-cultural and gambling histories specific to these countries and irrelevant to the UK.


The Responsible Gambling Strategy Board, now the Safer Gambling Advisory Board argued for PHAG from 2016 and the Gambling Commission adopted it from 2018. This is a strategy that I believe goes against the very ethos of the Gambling Act 2005 and has meant that the government’s gambling policy has been changed significantly by just a handful of activist academics and ideological regulators without recourse to Parliament. Sir Alan Budd’s solution to the ‘Central Dilemma’, liberty to gamble versus protecting the vulnerable,  in his White Paper that led to the Act, has been undemocratically dismissed at a time when problem gambling rates have never been lower.


What PHAG argues is that the problem with problem gambling is not mostly to do with the mental health issues of the gambler. Instead it is to do with the culture and social processes that people live with and the actions of the gambling industry, in supplying gambling, advertising it and the design of the gambling products. In effect, the gambler has no agency, is infantilised and forced to gamble purely due to the commercial activities of the gambling industry and the, although never mentioned directly, working class culture that permits gambling. Advocates of PHAG believe that everyone suffers harms from gambling in some way, directly or indirectly and everyone can, and probably will have problems with their gambling, even though there is no evidence  for this. For them, this totality of harm outweighs any benefit gambling can bring and justifies all actions to prevent and reduce gambling harm. Their stated belief is that gambling harm can only be reduced by reducing the overall amount of gambling and this should be done via restrictions on access, availability and marketing to the extent of prohibition. Make no mistake, the academics involved in the gambling debate, like the anti-gambling groups they cross-pollinate with, state they don’t want gambling banned, just want it prohibited to the extent that it is effectively.


The irony of this is upon a lengthy investigation into practically all the academic literature supporting PHAG is that there is no evidence to support any of it. Yes, there is evidence that problem gamblers suffer serious harm as do their immediate family. But there is no evidence that communities suffer. There is no evidence in the UK that increased gambling exposure has increased problem gambling nor that gambling advertising and sponsorship has done anything more than increase cravings in problem gamblers. There is no evidence that gambling related suicides are statistically significant in the UK and most of all there is no evidence that the gambling harms they think are suffered by the majority of the population are anything more than inconveniences at worst. PHAG advocates have designated flatulence, over eating, not going to the cinema and not attending church as gambling harms. One of the key academic papers they cite, Browne et al (2016)[1] compares the harms a ‘low risk gambler’ as suffering as comparable to having an ‘arm amputated, with or without treatment’. Their academic arguments are an example of amateur academia, citations that cite themselves more often than not or cite papers that don’t support their arguments and when they finally cite a paper that supposedly supports their argument, its about the use slot machines in a Bush town of Australia in the 1980s. It is all academic sleight of hand purely promoting a political ideology.


The issue for British gambling industry is that it is PHAG that created Affordability and its more insane cousin, Vulnerability. It is PHAG that will keep the Gambling Commission consistently coming up with regulations to reduce the number of problem gamblers to zero. It is PHAG that will cause a massive explosion in Black Market, which we are already seeing, as British gamblers refuse to undertake the massive personal intrusion that these new regulations will bring and operators will follow unable to have a profitable business when they have to undertake psychological/medical/socio-economic test on their customers just so they can bet £20 on Arsenal on a Saturday.


The Betting & Gaming Council may well be in line for applause when the White Paper shows that the threat of across-the-board Affordability tests at miniscule thresholds has been averted but so far they have done nothing to stop the influence of PHAG. Their problem is that in calling for an evidenced-based approach to gambling policy, they have failed to realise that the academics supplying it are anti-gambling ideologues simply on the grift for more grant funding.


The industry needs to wake up, put its hands in its pockets and start fighting the influence and misinformation of PHAG, before its too late. In New Zealand, the PHAG has meant that slot machines can only be operated by not-for-profit organisations or, if operated by a for-profit organisation, only if 40% of GGR is given to charity. Prof. Jim Orford, the elderly statesman of UK activist academia has campaigned for the nationalisation of the British gambling industry. It wont be long before the incoming Labour government is more receptive to a PHAG approach than the current Conservative one is.


[1] Browne, M., Langham, E., Rawat, V., Greer, N., Li, E., Rose, J., Rockloff, M., Donaldson, P., Thorne, H.,

Goodwin, B., Bryden, G., & Best, T. (2016). Assessing gambling-related harm in Victoria: A public health

perspective. Melbourne: Victorian Responsible Gambling Foundation,

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