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March 2022 - Losing the information war


With the horrors of Russia’s barbaric attack on Ukraine filling our timelines, we will have all noticed that as well as a more traditional kinetic war, there also exists a conflict about information. Fortunately, it does seem that the Ukrainian’s are winning this, showing the world in video that they are literally sticking two fingers up to the invading neighbours and valiantly fighting on.


Every now and again you will find, even on this social media platform, Putin’s apologists, spewing the hogwash arguments that Russia was provoked by NATO’s expansion onto their borders and that the Ukrainian government are ‘drug taking Nazis’. These ‘useful idiots’ and ‘bots’ are trying to do their maniacal master’s bidding and convince the world’s hard of thinking that there is some justification for these war crimes being inflicted on the Ukrainian people. By using lies and half-truths and in some cases blatantly staged theatre, the Russians want to mangle the truth so they can appear to the deluded that they are in fact the defenders from aggression and on the right side of history. Luckily, the sheer weight of evidence shows this is just twaddle and that a long time in jail for war crimes is the least worst options for these ethno-nationalist terrorists.


It is incredibly trivial and hyperbolic to compare the awful bloodshed of Ukraine with the battle for Britain’s gambling industry’s future, but on the most basic level of information warfare there are unfortunately many similarities. Regrettably in this battlespace, it’s the bad guys that are winning and it doesn’t seem like the forces of light, the gambling industry, have even found out how to make a Molotov cocktail yet.


A prime example was the debate held in the House of Lords on the 1st March 2022 on gambling advertising. To continue with the war analogy, this was a skirmish on an important secondary front, overall victory here for either side could determine the outcome of the overall war.


While the politics of British gambling is primarily an executive decision, one made by the government of the day, with the gambling Minister mostly responsible for the strategic direction, the ability of either House (Lords or Commons) to amend proposed legislation or even worse, vote it down is a very real consideration. Let us not forget that it was the defeat in the Lords of the Gambling (Geographical Distribution of Casino Premises Licences) Order 2007 on 28th March 2007 that put an end to the Regional Casino licence for Manchester and it was the potential defeat in the Commons to the Statutory Instrument that set the stakes and prizes limits for Category B gaming machines (fixed odds betting terminals) that made the government go for a £2 stake that effectively abolished these machines in May 2018.[i]


To have a debate on gambling in the Lords where only one speaker could be considered in anyway supportive (albeit quite tenuously) shows us two things. First, it shows that gambling has little active support in the Upper House. That’s not to say that there are over a hundred Lords who would work tirelessly night and day to defend anything horseracing, just that the majority don’t see the linkage between gambling regulation and the fortunes of racing. If they could be educated then it would be a different story. The second thing it shows is that there is no co-ordinating going on behalf the industry on the red benches. While the debate was packed out by members of the Peers for Gambling Reform, indirectly financially supported by a foreign-based multi-millionaire who also similarly supports the All Party Group on Gambling Harms and much of the dubious research that we will discuss below, there appears to be a total absence of influence from those supporting the gambling industry, a lack of foreign based multi-millionaire companies defending the British industry.


It should be stated that this was only a short debate, 54 minutes to be precise. Its importance in the big scheme of things may have been considered not worth the candle. But I suspect from the conversations that I have had with Lords interested in gambling, that there was no one to motivate them or give them something to say to support our industry.


By way of contrast, Interel Consulting, an international public affairs company with offices in Europe, China and India, who don’t mention the work they do in the anti-gambling camp on their website, have been active in supporting the war against the FOBTs and are now helping the anti-gambling Peers with their campaign against online. They’re a bit like the mercenaries that Putin has used in Syria and Africa and who now have infiltrated into Kyiv. Experts, motivated by money, designing the attack lines that the anti-gambling brigade are using to try and convince the uninitiated and uninformed, i.e. the government and other Parliamentarians.


The weapons that they use are the falsehoods and mistruths that are the products of supposed research by supposed academics. We can be confident to mock the terms research and academics as they hold little resemblance to the expected meaning of the words. A bit like when the Russian Foreign Minister Sergei Lavrov states that the Ukrainians have been shelling themselves or that civilian escape routes that have been mined are ‘safe’. What we have are activist academics pedalling dodgy research as evidence. The problem for the gambling industry is that this ‘research’ goes very much unchallenged and thus becomes ‘evidence ‘ in evidence based policy making.[ii]


What Interel has most likely provided the Peers for Gambling Reform with is a list of key messages to hammer home their argument for prohibiting gambling. In politics, messaging is everything. As we know from Blair’s Education, Education, Education and more recently, Boris’s Get Brexit Done, the task of any campaigning politician is to keep the message simple and repeat it often. That is why the untruths and half-truths trundled out in this short debate will be repeated, and already have been, time and time again. We saw the same thing with the FOBT debate. The blatantly untrue statement that you could lose £15,000 in an hour was repeated by the anti-FOBT campaigners for years and it stuck.[iii] This is why we call them ‘Zombie memes’. They’re very difficult to kill, especially the gambling industry does next to nothing to decapitate them. Then, as now, those paid to defend the industry from such attacks, are allowing these lies to gain traction and become part of the accepted structure of any gambling debate.


These Zombie memes are specifically chosen for their emotive appeal. The prohibitionists understand that most Parliamentarians know nothing of the gambling industry and care even less. This monumental industry lobbying failure allows for the prohibitionists to focus on those subjects any human being understands, using faulty research to suggest that gambling is the cause and then allow the Parliamentarian to come to the ‘obvious’ conclusion. Let’s take  biggest emotional ‘weapon’ that of gambling related suicide as an example, mentioned numerous times in the Lords debate.


[i] The government announced their £2 decision in a document published in May 2018 by DCMS called Government response to the consultation on proposals for changes to Gaming Machines and Social Responsibility Measures. This was implemented by Statutory Instrument 2018:1402 The Gaming Machine (Miscellaneous Amendments and Revocation) Regulations 2018

[ii] Regulus Partners appear to be the only organisation that consistently calls out the disinformation in academic research on gambling.

[iii] It was only possible to lose £15,000 in an hour if you a) never won anything, and b) could physically feed the amount of money into the machine in time. No one, to my knowledge has ever proven it possible.

Firstly, the very term gambling related suicide needs critiquing. The Samaritans, the country’s experts on the topic quite clearly state in their media guidelines that ‘Suicide is extremely complex and most of the time there is no single event or factor that leads someone to take their own life.’[i] By allowing the prohibitionists to make the case that gambling is a cause of suicide and not that some people who have severe mental illnesses unfortunately take their lives makes it seem that every gambler is susceptible. Then we need to look at the numbers being used to suggest there is a suicide epidemic due to gambling.


The anti-gambling group, Gambling With Lives, have in the past stated that 700 deaths a year are due to gambling. Although they were never questioned where they got this number from and they have never revealed it. It is thought that they were referring to research on gambling related suicides in Hong Kong in the 1970s where gamblers in hock to Triad gangs preferred suicide to the terrible retribution these gangs sought. They now state that between 4% - 11% of suicides are caused by gambling, the equivalent of 250 – 650 suicides per year and cite UK and international research.[ii] The only actual UK research they reference is a 2017 University of Manchester report that states that 4% of suicides by 20-24 year olds had recently suffered financial problems caused by gambling.[iii] What they fail to point out is over half had previously self-harmed, over two-thirds had a diagnosis of mental disorder and ideation of suicide and nearly half had alcohol and /or drug use issues. Nowhere does the report suggest that gambling was a primary cause of suicide. The international research is one paper on Hong Kong suicides from 2010.[iv] The study looked at 150 suicides and 150 controls, and found 17 suicides who could be stated to be pathological gamblers at the time of death, 82.4% had other associated psychiatric disorders. If Gambling With Lives argued that those with severe mental illness that in part focuses on gambling have in the past, in a very small number, committed suicide, they would be reflecting the truth.


Another number is 409 per year coming from the methodologically flawed report, The economic and social cost of harms associated with gambling in England, 2019 to 2020 published by the now defunct Public Health England. This number is based on purely Swedish figures, themselves just estimations, and extrapolated to the UK. Anyone who has worked in Scandinavia knows that their cultural response and acceptance to suicide is much higher than in the UK and to suggest that this number has validity, like other bits of the report (see below) is simply fatuous. Especially as the suicide rate per 100,000 people in Sweden in 2019 was 14.7 and in the United Kingdom it was 7.9.[v] But the prohibitionists know that arguing that gambling causes suicide is all that Parliamentarians will hear.


Of most recent interest will be the Coroner’s report of the suicide of Jack Ritchie, whose suicide in Vietnam in 2017, led his parents to set up the Gambling With Lives campaign group mentioned above. The report states Jack had been struggling with gambling addiction since he was 17. It states that at the time of his death there wasn’t the information available to inform him where to seek help. One can only suspect that he was gambling on non-UK sites as every UK licensed site has had to provide this information since online gambling licensing started in 2007. It goes on to state that the ‘treatment available and received by Jack was insufficient to cure his addiction this in part was due to a lack of training for medical professionals around the diagnosis and treatment of gambling addiction’. This unfortunately is due to the NHS only recently setting up clinics for gambling addiction and GPs not being sufficiently trained. Gambling addiction has for many years been dealt with by charitable organisations like Gamblers Anonymous, the Gordon Moody organisation and GamCare, the gambling industry  being the main source of funding for many of these organisations. The Coroners final complaint is that ‘The evidence was that young people were the most at risk from the harms of gambling yet there was and still appears to be, very little education for school children on the subject’. YGAM, The Young Gamers and Gamblers Education Trust, has been working for a number of years to provide such education, in part funded by the gambling industry, but have found it very difficult to get gambling onto school curriculums.


No-one is suggesting that we refute the fact that a tiny number of people with severe mental health issues that have, in part, focussed on gambling may have unfortunately ended their own lives. But what we need to first look at this emotive issue in context. In 2020 there were 8,974 deaths related to alcohol-specific causes registered in the UK and 4,561 deaths related to drug poisoning registered in England and Wales.[vi] Alcoholics and drug addicts get treated either as medical emergencies or in therapy to hopefully end their addiction by the NHS. School children get taught about the dangers of drink and drugs as part of their personal, social, health and economic ( PSHE ) education. The fact that gambling addiction has only started being treated by the NHS and gambling is not on the curriculum is quite simply the fault of the Departments of Health and Education and not of the gambling industry who would very much like it to be so.


The fact is that many activities that humans indulge in come with an element of risk, a social externality. There have always been drug addicts, alcoholics and gambling addicts. Gambling addicts are more likely to take their own lives as ‘rock bottom’ for them is a financial affair, where they are looking at losing everything they own and very often looking at prison due to the money they have stolen. Drug addicts and alcoholics end up in hospital when they reach rock bottom. In 2018/19 there were 358,000 estimated admissions to hospital where the main reason for admission was attributable to alcohol.[vii] In 2017/18 there were 18,053 admissions to hospital for poisoning by drug misuse.[viii] Alcoholics and drug addicts tend not to attempt suicide as their ‘fix’ kills them more directly. No one is suggesting that these numbers are acceptable and that nothing more can be done to prevent such deaths. But unlike the Betting & Gaming Council’s blatantly ridiculous statement that one problem gambler is one too many, we have to accept that unfortunately there will always be a number of people with severe mental health issues that in part focus on gambling  who then commit suicide. Obviously the industry does what it can, but there is a limit to the level of regulation that can be imposed before it starts to impact on the 99.7% of the population without a problem and who will be driven to the black market where they will receive no help at all if they have a problem.


There were 119,850 casualties of all severities on Britain’s roads in the year ending June 2021. No one is suggesting that we ban cars. No one is suggesting that we set the speed limit at 5mph. No one is marching on the streets when speed limits are dropped from 30mph to 20mph because science shows that it saves lives. Restrictions on gambling are acceptable if they a proportionate and properly evidence based.


[i] The Samaritans, Media Guidelines for Reporting Suicide, p.4


[iii] Suicide by children and young people. National Confidential Inquiry into Suicide and Homicide by People with Mental Illness (NCISH). Manchester: University of Manchester,

[iv] Wong PW, Chan WS, Conwell Y, Conner KR, Yip PS. A psychological autopsy study of pathological gamblers who died by suicide. J Affect Disord. 2010 Jan;120(1-3):213-6.


[vi] &



Gambling related suicide

The next myth, equally as emotive is the suggestion that there are tens of thousands of children addicted to gambling. This is based on the annual Young People and Gambling surveys conducted by IPSOS MORI on behalf of the Gambling Commission. The latest survey is from 2020 and is disregarded because of Covid.[i] The 2019 report states that 1.7% of 11-16 year olds surveyed are classified as ‘problem’ gamblers.[ii] The report extrapolates this to be 55,000 children in the national population. In the Lords debate, this figure is given as 60,000 by Lords Foster and Griffiths and 55,000 by the Baroness Chisholm.[iii]


There are a number of issues with how this number is achieved. Firstly, the methodology behind it. In the survey, IPSOS MORI asked a sample of 2,943 children aged 11-16 a number of questions about their gambling. A number of these questions include a psychological screening designed by Dr Sue Fisher called DSM-IV-MR-J. This is an adaption of a similar screen designed for adults. It involves a series of questions to which the child has a multiple response answer. Depending on the answer chosen, a score is given. The questions and possible scores are:


  1. In the past 12 months how often have you found yourself thinking about gambling or planning to gamble?


Never (Score 0) Once or Twice (Score 0) Sometimes (Score 0) Often (Score 1)


  1. In the past 12 months how often have you gambled to help you escape from problems or when you are feeling bad?


Never (Score 0) Once or Twice (Score 0) Sometimes (Score 1) Often (Score 1)


  1. In the past 12 months have you felt bad or fed up when trying to cut down on gambling?


Never (Score 0) Once or Twice (Score 0) Sometimes (Score 1) Often (Score 1)


  1. In the past 12 months have you needed to gamble with more and more money to get the amount of excitement you want?


Never (Score 0) Once or Twice (Score 0) Sometimes (Score 1) Often (Score 1)


  1. In the past 12 months have you ever spent much more than you planned to on gambling?


Never (Score 0) Once or Twice (Score 0) Sometimes (Score 1) Often (Score 1)


  1. Have you ever taken money from any of the following without permission to spend on gambling:


Dinner money or fare money (Score 1)

Money from family (Score 1)

Money from things you’ve sold (Score 1)

Money from outside the family (Score 1)

Somewhere else (Score 1)


  1. In the past 12 months has your gambling ever led to the following?


Arguments with family/ friends or others

Never (Score 0) Once or Twice (Score 1) Sometimes (Score 1) Often (Score 1)


Telling lies to family/ friends or others

Never (Score 0) Once or Twice (Score 1) Sometimes (Score 1) Often (Score 1)


Missing school

Never (Score 0) Once or Twice (Score 1) Sometimes (Score 1) Often (Score 1)


  1. After losing money by gambling, have you returned another day to try to win back the money you lost?


Never (Score 0) Less than half the time (Score 0) More than half the time (Score 1) Every time (Score 1)


Based on the scores children achieve they are judged as:


Score of 0-1 – non-problem gambler

Score of 2-3 – at-risk gambler

Score of 4+ - problem gambler


As can be clearly seen with such benign tasks and low threshold, the potential for a large number of problem gamblers is huge. Let us take the example of a child who on one solitary day of madness decides to lie to their teacher in order to play truant from school and spend their dinner money on gambling, maybe a game of Penny Up with his or her mates. Rather than being considered just a naughty child, they are now categorised as a problem gambler.


Such methodological problems have been critiqued in the scientific literature. They comment:


  • At Risk Problem Gambling instruments for youth have not been rigorously evaluated yet.[iv]

  • It is critical that these instruments demonstrate evidence of reliability, validity and accuracy. It is recommended that the field adopt testing standards for the development and use of adolescent problem gambling scales, and generate a body of rigorous psychometric research that demonstrates reliability, validity, and classification accuracy.[v]

  • Previous studies have shown that prevalence rates among youths may be inflated due to a problem in understanding the questions of the SOGS-RA [another form of screen] and DSM-IV-MR-J.[vi]


The main criticism of the DSM-IV-MR-J screen is, apart from the glaringly obvious low thresholds and benign activities, that if there is a 1.7% problem gambling rate amongst children, how is an adult problem gambling rate of 0.3% explained?[vii] How do you explain an 82% decrease in problem gambling just by the advancement into adulthood, especially as the only legal gambling 11-16 years olds can participate in are, as categorised in the survey:


  • National Lottery (16 year age limit at the time of the survey)

  • Placing a private bet for money (e.g. with friends),

  • Playing cards for money with friends,

  • Any other gambling – thus any other gambling game such as Penny Up


While and adult not only has far more financial means but can access a panoply of hard gambling games. The answer is either a flaw in the survey design/methodology as mentioned in the scientific literature and/or the other salient fact, children are notorious for being bad survey respondents. In other words, they lie.


To give an idea of the possible issues with the veracity of the results of the survey, it states that:


  • 2% of children (64,705 children) had played games at a land-based casino, including 2% of 11 year olds

  • 2% of children (64,705 children) had played bingo at a bingo club, including 2% of 11 year olds

  • 2% of children (64,705 children) had visited a betting shop to play a gaming machine, including 2% of 11 year olds

  • 3% of children (97,058 children) had visited a betting shop to place a bet, including 3% of 11 year olds.[viii]


This means that either the nation’s land based gambling venues are full of children, even though local councils check regularly, it is severe licensing offence which no operator would countenance and there has been no known reports ever of large numbers of children in these venues, or there are serious issues with this survey.


Worthy of note is the survey’s comment that ‘In 2019, 67% of 11-16 year olds who have ever spent their money on gambling last did so with their parents or guardians. In contrast, 2% say they were alone at the time’.[ix] This could suggest that many children are either confusing being with their parents while their parents gamble as them gambling or are actually gambling themselves facilitated by their parents. This is an issue, especially for online operators – if parents give their children access to their gambling accounts, how are operators supposed to know and prevent it?


It is also an issue for policy makers and regulators as there has been a view for decades that children should not gamble. What there is for some parents though is a ‘grey area’ where a little gambling is OK as seen by the above statistics. Be it the occasional small bet on their favourite football team, their lucky numbers on the National Lottery or playing the Category D slots at the seaside amusements. Some parents think, like those who let their children have a small glass of wine when on holiday, that the occasional flutter is harmless. This was a turbulent debate during the passing of the Gambling Act 2005 when a number of MPs, many from seaside constituencies argued against the government who wanted to ban children from playing gaming machines and stated that playing on the amusements as kids didn’t make them addicts. They won and to this day children have access to category D machines.





[iv] Edgren R, Castrén S, Mäkelä M, Pörtfors P, Alho H, Salonen AH. Reliability of Instruments Measuring At-Risk and Problem Gambling Among Young Individuals: A Systematic Review Covering Years 2009-2015. J Adolesc Health. 2016 Jun;58(6):600-15

[v] Stinchfield R. A critical review of adolescent problem gambling assessment instruments. Int J Adolesc Med Health. 2010 Jan-Mar;22(1):77-93.

[vi] Jacques C, Ladouceur R. DSM-IV-J criteria: a scoring error that may be modifying the estimates of pathological gambling among youths. J Gambl Stud. 2003 Winter;19(4):427-31.



[ix] Young People and Gambling, Survey 2019, A research study among 11-16 year olds in Great Britain, October 2019, p.22

Children gambling

This takes us nicely to our next meme, that of gambling advertising and sponsorship of football matches. The argument of the prohibitionists being that children, the emotive hot button, are fans of football and so by attending or watching football matches and seeing gambling brand names, they will in some way become problem gamblers. In the Lords debate, the most eminent politician to speak, Lord Butler of Brockwell, said ‘I am not against advertising, and I am certainly not against football, but I do not think that we should endanger our youngsters in order to support Premier League football clubs’.[i]


Arguably the campaign against gambling companies sponsoring football was properly started by GambleAware (now BeGambleAware), a charity set up the gambling industry to distribute the semi-voluntary levy that gambling companies pay for problem gambling research, education and treatment. Marc Etches, GambleAware’s then Chief Executive, stated on the launch of their #CanWeHaveOurBallBack campaign on the 26th November 2018, ‘We recognise that gambling-related sponsorship and advertising are important sources of funding for both professional football and grass-roots community participation in the sport. However, there is growing public concern about the nature and extent of the relationship between football and betting. In particular, whether the extent of betting-related marketing around football is contributing to the normalisation of gambling for children’.[ii] They wanted to start a ‘conversation’ about gambling advertising and sponsorship. Since then it’s become one of the prohibitionists attack points.


The two most prominent activist groups are The Big Step, which is an offshoot of Gambling With Lives (see above) who seem to spend their time trying to convince minor league teams not to accept gambling advertising. Making a slightly more educated approach, based purely on their website, is the Coalition Against Gambling Advertising (CAGA), which includes the Big Step and Gambling With Lives and also Clean Up Gambling, the new vehicle for sacked Corbyn press advisor, Matt Zarb-Cousins, once of the Campaign for Fairer Gambling, both funded by the same foreign-based multi-millionaire who funds the All Party Group on Gambling Harms and Peers for Gambling Reform.


As with the ‘loony left’ of British politics, there are a myriad of prohibitionist groups, under different names, with miniscule memberships, many of which overlap and many funded by a foreign sponsor. Add to this the Royal Society for Public Health which has set up its own Gambling Health Alliance, thus counting as two campaign groups, which includes the aforementioned groups. Why they do this is because whenever there is a consultation, call for evidence, Select Committee inquiry etc. they can turn up representing a large number of groups – the fact that the actual membership is tiny and includes people in more than one group is irrelevant, what it means is that the gambling industry, represented by the Betting & Gaming Council will X number of minutes to state their case while the prohibitionists will get 5X minutes.


The case put forward by CAGA is that due to gambling advertising and sponsorship of football children suffer high levels of exposure and therefore have high levels of brand awareness and  perceive gambling positively. They make the bold statement that ‘The more people are exposed to gambling advertising the more likely they are to gamble’.[iii] They continue ‘Advanced statistical analysis has been used to determine the extent to which exposure to gambling marketing is associated with future gambling activity in young people, compared with other factors such as age, gender and parent’s gambling. This showed the likelihood of a current non-gambler spending their own money on gambling in the near future increases significantly among those who have been exposed to a high volume of gambling advertising over the past month’. They cite GambleAware’s 2020 report, The effect of marketing and advertising on children, young people and vulnerable people - Quantitative Research Report by MacGregor et al.


What the report actually says is:


These results demonstrate that the factors associated with gambling susceptibility and current gambling among those aged 11-24 years are complex and multifactorial. It is also important to emphasise that these are the results from a cross-sectional, not a longitudinal, survey and as a result we cannot demonstrate causality.[iv]


MacGregor does state that a ‘high level of awareness of gambling marketing is associated with increased susceptibility to gamble among non-gamblers, and higher brand awareness was also found to be associated with current gambling. More active engagement and participation with the marketing is, in turn, significantly associated with gambling susceptibility and current gambling’.[v]  But unlike the emphasis CAGA give it, MacGregor points out that ‘the results also suggest that this is only one part of a complex narrative, in which increasing age, parental attitudes which are favourable to gambling and the presence of parental gambling itself, as well as the influence of peer gambling behaviour, also have a major impact on the gambling of 11-24 year olds.’[vi]


What we are seeing is that marketing does, like with any product, have an element of influence with customer behaviour. That is after all why companies spend their money doing it. Gambling companies are indulging in marketing and some customers, most likely the ones from a gambling positive culture, respond. They respond by indulging in a legal activity and there is no evidence that this marketing behaviour causes problem gambling.


CAGA go on to state ‘There is good evidence that, for a considerable number of people, gambling advertising substantially contributes to disordered gambling’.[vii] This is where they, like other prohibitionist groups, cite research into Australian gambling in the obvious belief that it has relevance. This is understandable as many of the anti-gambling activist academics in the UK have taken their lead from anti-gambling activist academics in Australia. The fact that the UK and Australia have very different gambling industries, cultures and regulations means any comparison is tenuous. None of the reports cited or anywhere state that gambling advertising causes problem gambling. As you will notice from the word use, CAGA say it contributes to problem (disordered) gambling and that is true, or at least there is some evidence to show that problem gamblers who are exposed gambling advertising may gamble. It’s a similar phenomenon to when drug addicts get exposed to pictures of drug taking paraphernalia or other things they associate with their drug taking, they get cravings for drugs. Unfortunately it is very difficult to isolate addicts from exposure to imagery that gives them cravings unless we ban advertising on a whole raft of products.


Lord Foster, Chair of the Peers for Gambling Reform also made the mistake of mixing up that there is no evidence that gambling advertising causes problem gambling with gambling advertising can cause problems for problem gamblers. In his speech opening the debate on the 1st March 2022 he states:


I want to concentrate on the claim that there is no evidence of a causal relationship between gambling advertising and harm. To make this claim, the industry has frequently called in aid—as did John Whittingdale when he was Gambling Minister—the very limited survey of relevant research carried out by Per Binde in 2014, from which he concluded that none showed a causal link between gambling ads and harm. Yet the operators fail to mention that, more recently, in 2019, Per Binde produced a further study that concluded:


“Gambling advertising may contribute to problem gambling, and problem gamblers are more sensitive to advertising impact than non-problem gamblers.”[viii]


Per Binde’s 2019 research Self‑Reported Negative Influence of Gambling Advertising in a Swedish Population‑Based Sample asked a sample of gambling Swedes whether adverts for big jackpots, bonuses for online gambling and gambling advertising in general had influenced them to gamble more often or for more money than you intended to. As the research title states it is looking at Sweden.[ix] Sweden has a large black market due to its over regulation of gambling, this means that much of the advertising, explicitly that advertising for bonuses,  is illegal and so does not have to conform to the same standards as in the UK. Binde recognises the influence of illegal advertising in his research.[x] What Binde did find was that ‘few gamblers—only about 2%—reported repeated negative influence of gambling advertising’.[xi] Those who reported negative influence of gambling advertising were at risk and problem gamblers. Binde states quite categorically:


There is no evidence in this study that gambling advertising in mass media substantially contributes to gambling problems.[xii]


What is obvious is that this type of attack, collapses under closer scrutiny. There is no evidence of gambling advertising and sponsorship causing problem gambling. Yes, there is evidence that children and young people have been exposed to gambling advertising and sponsorship although none of the research cited incorporates the most recent regulations imposed on what can be advertised, especially on social media.


What this is really about is the moral condemnation of gambling. The idea that gambling should be seen as tobacco and so should not be in the public sphere, even though tobacco is poisonous for everyone and gambling is benign for 99.7% of the population. The description of children being endangered by exposure to gambling brands at a football match is laughable and ahistorical. Children have been walking past gambling brand names on the high street for sixty years, Littlewoods Pools was the most common form of gambling on football for about 70 years and their coupons were in the home of millions. The very game of football had its rules formalised for gambling purposes. Why is it that with all the expansion of gambling marketing the problem gambling rate has dropped to its lowest rate ever?


It is because this is not about evidence, it’s about the prohibitionists seeking another front to attack the industry on, as per usual using emotive imagery – the allusion that children can be harmed and using half truths about research to suggest there is evidence.





[iv] p.51

[v] Ibid p.53

[vi] Ibid p.51



[ix] Binde, P., Romild, U. Self-Reported Negative Influence of Gambling Advertising in a Swedish Population-Based Sample. J Gambl Stud 35, 709–724 (2019)

[x] Ibid p.716

[xi] Ibid p.720

[xii] Ibid p.22

Football sponsorship & advertising

The next meme is that of the cost of gambling harms.


The economic and social cost of harms associated with gambling in England, 2019 to 2020 published by Public Health England (PHE) should go down in history as one of the most flagrant attempts to attack the gambling industry under the cover of so called academic research this decade. It is little wonder that PHE would be shut down a few months later.


The report estimated the annual economic burden of harmful gambling to be about £1.27 billion (in 2019 to 2020 prices). This included £647.0 million (51%) of direct costs to government and £619.2 million (49%) of wider societal costs associated with suicide.[i]


In the Lords debate, the Lord Bethell mentions this figure as an unacceptable cost and Baroness Bakewell mistook problem gambling with gambling when paraphrasing the report: ‘the six harms caused by gambling. These are: financial, relationship breakdown, mental and physical health, employment and education, criminal and anti-social behaviour, and cultural’. [ii] We can be certain that as the war over Britain’s gambling progresses these memes, like the others examined above, will be repeated ad infinitum and, if the gambling industry’s representatives continue their current strategy, go almost completely unchallenged.


Anti-gambling activist academics have used the ploy of undertaking cost benefit analysis of gambling in the past. In America in the 1990s and early 2000s, when land-based casinos were opening up in many states, a number of overtly anti-gambling academics published research papers that argued that the social costs of gambling far outweighed the benefits.[iii] The usual methodology was to create a list of all the social woes possible that could be linked to gambling, however tenuously, and then allocate an enormous cost to them through the most generous estimation possible, regardless of evidence to the contrary. This would then, if benefits were even considered, be pitted against a desultory figure of the benefits of gambling, usually just reduced to employment and tax revenue which is then heavily caveated by statements about how better jobs and more taxes could be gained from alternative enterprises than gambling.


The late Professor Bill Eadington, the father of gambling policy studies stated:


many of the studies conducted to date have resulted in reporting a single number or a range of numbers—i.e. “. . . the cost to society is $15,000 per problem gambler per annum,” or “. . . the range of costs to society is from $9,000 to $50,000 per pathological gambler per annum,”—on the basis that such numbers should—indeed must—be measured and reported, regardless of their lack of context, difficulties in conceptualization and measurement, or the ease with which such reporting can be misinterpreted or misunderstood.


One problem that sometimes occurs is when researchers approach their analysis with preconceived biases, hoping for a higher (or lower) number because of their beliefs with regard to the seriousness (or lack of seriousness) of the issue.[iv]


Dr Douglas Walker, one of the most sane academics dealing with gambling, points out in his paper from 2008 that one of the biggest issues with measuring the social costs of gambling is co-morbidity.[v] This is the concept that problem gamblers have pre-existing problems other than gambling. Walker states:


Examples include alcohol and drug problems, and mood and anxiety disorders. If pathological gambling is simply a symptom of some more basic disorder, then, it is the more basic disorder rather than gambling itself that is the underlying cause of the adverse consequences and social costs of the pathological gambling.[vi]


Walkers argument is that given we know that a high proportion of problem gamblers have other conditions, how do researchers allocate costs? and why do activist academics allocate 100% of the social costs due to a co-morbidity, such as alcoholism, to problem gambling? This is very pertinent to the PHE report.


Walker goes on to pose other challenges with calculating social costs. He identifies the use of surveys as problematic due to the fact that problem gamblers are very unreliable when it comes to correctly remembering how much they’ve spent on gambling, when and where they got the money from.[vii] This is important as such surveys are used when calculating social costs. Walker then points out that many studies make the mistake of extrapolating from the experience of the most serious problem gamblers (those who can be classified as pathological) to the general population of problem gamblers, which is obviously inappropriate and appears in the PHE report, although it provides the rather fatuous division between at-risk and problem gamblers, the term at-risk implying an imminent progression to problem gambling when evidence suggests this is just not the case .[viii]


Walkers final critiques are of government spending and the counter-factual argument.[ix] He argues that the point of trying to identify the social cost of problem gambling is to argue this is the additional cost to the nation of gambling due to its social externality, problem gambling. On top of the issue of co-morbidity, this implies that that the government services researchers have allocated to the cost of problem gambling would not be there if there were no problem gamblers. Would the number of police, hospitals and prisons be in anyway different if the number of problem gamblers was zero?


Up until very recently the cost of all treatment for problem gambling was paid for by the gambling industry itself. Now that the NHS has opened some clinics, this is just a tiny fraction of a state cost compared to what the NHS spends on alcoholics and drug addicts, which we all pay for out of our taxes.


And what does the social cost of problem gambling compare with? The cost of no problem gamblers? How would that be achieved given that evidence from countries such as the now defunct GDR (East Germany) shows that there was still problem gambling. This shows up the integral flaw in cost benefit analysis, especially one like the PHE report, is that what it ignores is the counterfactual. If there is no legal gambling, you have illegal gambling, this means massive amounts of crime and problem gambling as there aren’t the regulations and enforcement to prevent it. We have ample evidence of this from looking at Britain from 1850 -1960. Every cost benefit analysis should be conducted with a comparison with what the social externalities would look like with a massive black market.


A cursory critique of the PHE report is as follows:


Financial Harms

  • The financial data used came from the 2021 Lloyds bank report that didn’t include cash expenditure (e.g. practically all retail gambling), gambling purchases in non-gambling venues such as all of the National Lottery’s venues or include any winnings.[x] The report acknowledges that: we cannot tell if at-risk or problem gamblers were included in the sample, an important limitation in this costing exercise for our purposes.[xi]

  • They reference a survey from the Annual Statistics from the National Gambling Treatment Service which shows that gamblers reported spending a median of £1,000 and a mean of £2,102 on gambling in the previous 30 days before assessment. What they don’t mention is such behaviour is undoubtedly what led the gamblers to seek treatment as this was their low point – as is generally accepted, addicts have to hit rock bottom before they seek help. They do caveat that ‘caution is needed when comparing such figures as the populations are not the same across different analyses’.[xii]

  • PHE rightly conclude that ‘The limited evidence available meant that no costing analysis was possible for financial harms to the individual’.[xiii]



  • There is an acceptance that there is little UK based research on homelessness and problem gambling. Considering the financial consequences of problem gambling it is not illogical to suggest that it may be a contributing factor to homelessness.

  • Much of the analysis is based on a report that used a sample of just 72 homeless people to ‘establish if gambling is more commonly a cause or a consequence of homelessness’.[xiv] This report was based on an earlier report that had a larger sample (456) which asserted that that the rate of problem gambling was far higher in the homeless community than the general population.[xv] Both reports were based on samples from hostels in Westminster, London.

  • The main report states that 16 participants (61.5%) disclosed experiencing gambling problems prior to becoming homeless but does not give this as a reason for the homelessness. Witnessing violent acts, long term unemployment, losing a job and trouble with the police are the most reported negative life events by those considered some risk of problem gambling. This ‘some risk’ category is anyone with a PGSI score >0 which includes a large number of people having no negative consequences from their gambling

  • The homeless people sampled also had a high rate of comorbidity with substance abuse. Of the thirty participants that disclosed any drug use in the past month, the most common primary substances were cocaine/crack (36.7%), heroin (33.3%), and cannabis (20%).Twenty-six participants (36.1%) endorsed at least one DSM-IV alcohol item, and in that subgroup, the modal number of items endorsed was all nine items (30.8%).[xvi] All the report mentions is that problem gambling and substance abuse are not correlated even though a high proportion did both and that they had similar engagement patterns

  • What is not apparent from the research paper is evidence for the researchers claim ‘Data from the current study reinforces the assertion that problem gambling is a significant issue within the homeless population, and is more commonly a cause than a consequence of homelessness’. All we have is the data that shows that 61.5% (16 people who had a PGSI of >0) have suffered gambling problems prior to being homeless. There is no data of when or to what extent they suffered these problems and as stated the loss of employment would appear to be a more convincing cause. Two of the researchers have publicly anti-gambling views and one has an academic career based purely on gambling and homelessness and this may be the reason for the methodological leap that supposedly proves their stated hypothesis.

  • The PHE extrapolates the results of this 72 person survey up to the homeless population for the UK (estimated by Shelter to be 249,850 in 2021) and estimates the cost of excess statutory homeless applications associated with problem gamblers. It estimates that there are 21,438 excess statutory homeless applications associated with at-risk and problem gambling in England equating to a cost of £62.8 million (£2,929 per application).

  • The PHE estimates are based on all at-risk and problem gamblers – this includes low-risk and medium risk gamblers – i.e. not problem gamblers

  • The PHE estimate is based on the concept that problem gambling is the cause of homelessness, while we are certain it is a factor, the research used to argue its case doesn’t prove it

  • The PHE estimate does not incorporate that other factors (co-morbidity) such as alcohol and drugs and unemployment may be contributing factors as well but makes no attempt at allocating a financial amount for this

  • The PHE report admits its limitations in that it doesn’t include rough sleepers, that its London based sampling does not make it nationally representative and that it is based purely on a male sample.

  • The PHE’s statement that ‘Nevertheless, this remains the best evidence available’ seems to be their justification for what is potentially methodologically flawed and/or ideologically driven research.[xvii]


Health Harms – Suicide


  • This has been considered above – the number of suicides the PHE report uses is based on Swedish estimates and Sweden has double the suicide rate of the UK. Cultural attitudes to both gambling and suicide are very different in Sweden compared to the UK.

  • The PHE report cites the Gambling With Lives figures which are dismissed above and is indicative of the PHE report’s ideological bias

  • The PHE report cites the Wardle 2019 report.[xviii] This states that problem gamblers are more likely to think about suicide and attempt it then non-problem gamblers. This seems highly logical as these are people suffering a mental illness. The report also mentions that these people had higher rates of impairment, poor mental health and substance dependence, and exposure to a range of stressful experiences, including debt and homelessness and that the problem gamblers’ odds of having suicidal thoughts/attempts in the past year were halved once these other factors were taken into account.

  • The Wardle report gives its own limitations as ‘The survey was conducted over a decade ago and the sample was relatively small, with just 172 people identified as at risk of problem gambling and 41 identified as problem gamblers. Both problem gambling and past-year suicide attempts/thoughts are relatively rare, and the analyses were underpowered. The survey is cross-sectional in design and the data cannot be used to establish temporal sequencing in problem gambling and suicidality, nor causality’ and concludes: While it is not possible to conclude from these analyses that problem gambling causes suicidality and self-harm, the results do show that problem gamblers are a vulnerable group warranting targeted support who are more likely than others to have suicidal thoughts and to harm themselves.[xix]

  • The Swedish study used to provide the figure of 409 suicides is based on a study of 2,099 Swedish problem gamblers that were receiving medical treatment.[xx] While problem gamblers had 1.8 times increase in committing suicide (based on 21 suicides) compared to the population, the report’s conclusion was ‘Although common mental health comorbidities did not predict overall mortality, depression predicted suicide death.’

  • It is very clear that there is no evidence of problem gambling being a direct cause of suicide. It is more likely that depression is the main cause and that problem gambling may be a symptom of that.

  • The PHE report stretches the boundaries of reality when trying to calculate a cost for problem gambling related suicide. It comes to the cost of £619.2 million based firstly on the number of suicides it attributes to problem gambling, which, as said before, is a) of unproven causality and b) based on Swedish numbers that are mostly to do with depression. Then secondly, it uses a methodology used by the Department of Transport for the bizarrely named concept ‘willingness-to-pay to avoid fatality’.[xxi] This is a methodology for Cost Benefit Analysis in transport infrastructure schemes that estimates the costs of traffic accidents so that the costs of road safety measures can be put against them.  In the version the PHE uses, the number of healthy years these suicides would have lived if they had not committed suicide is estimated and then allocated a cost - £60,000 for each year, making each suicide worth £1.51 million and the total cost for suicide as £619.2 million

  • The report acknowledges that Swedish numbers may be problematic but doesn’t consider the differing suicide rates or cultural differences

  • Rather obvious in terms of critiquing this approach is that there is no direct evidence of problem gambling causing suicide, yet there is of depression. As stated numerous times, problem gambling can be a severe mental illness and severe mental illnesses can lead to suicide, so there is of course some linkage, but not what we would consider worthy of allocating the full value of a fatality as per the Department of Transport methodology. Those killed in road traffic accidents suffer the misfortune of an accident. A suicide is a fatality caused by a person, the reasons for which are multiple and incredibly complex.

  • This is a prime example of scant evidence being shoe-horned into a methodology to come up with a big number


Health harms – depression


  • Yet again the report uses scant research, a paper about depression in young adults in Canada.[xxii] It argues that ‘health care professionals should know that at-risk or PG [problem gambling] can lead to incident mental disorders and illegal drug use, as well as illegal drug use can lead to new onset at-risk or PG’.[xxiii] The research involved young adults (aged 18 to 20 years) who were surveyed at 4 time points across a 5-year span from 2007 to 2011. As stated before there is well established research that shows that problem gambling is linked to mental illness, in some cases it is the actual mental illness (psychopathic gambling), in the majority of cases it is a symptom of a mental illness (usually depression).

  • The next study, also of young people (17-24) is at least based in Britain.[xxiv]It states that ‘In conclusion, although many young people gamble without any harm, a significant minority (mainly males) show problem gambling behaviours which are associated with poor mental health, involvement in crime, and potentially harmful use of drugs and alcohol’.[xxv]

  • Both pieces of research acknowledge that young men, who are by far the majority, who are PG are likely to be of low IQ, financially disadvantaged, have parents who gamble, use alcohol and/or drugs and have a mental illness of some sort. To the lay person and not the activist academic this research does seem to reflect risk-taking problematic lifestyles of problematic young men and is not evidence of gambling causing depression. Although there is no doubt that for many with depression they gamble problematically and for a small number, their mental illness focussed on gambling obsessively.

  • The PHE report takes the methodological leap of referencing two research papers specifically about young people and then applying their results to people of all ages with no mention that research into young people gambling is undertaken as this is the time most people are considered at risk of harm.

  • The PHE report estimates that the number of people with depression associated with at-risk and problem gambling  is 212,511. This is a large number which is not surprising considering that at-risk gamblers includes 1.2 million people who are low risk (which is arguably no risk!) and the survey the numbers come from was done in 2018 when problem gambling rates were twice as high. But the advantage of such a large number, when multiplied with the average cost of everything to do with treating someone for depression, regardless of the fact that depression by its very nature is an illness caused by multiple factors, causing less or more harm to some and less and more cost to the NHS, is that you get a large amount supposedly attributable to gambling harms - £335.5 million.

  • Even the PHE report admits the limitation that ‘the analysis does not differentiate the level of harm between at-risk and problem gamblers. We would expect to see varying levels of risk between types of gambler, given that low-risk gamblers, for example, are likely to experience fewer or no negative consequences from their gambling activity’.[xxvi]

  • The PHE report again ignores the counterfactual, would all these people not have had depression if they didn’t gamble? We know that those that suffer from a mental illness that in part focusses on gambling are very unhappy people and would logically have some depression because of it, but this report is obviously not looking for nuance, but to make the statement, gambling must lead to problem gambling and this costs the country millions. Just the facts don’t stack up


Health harms – alcohol dependence


  • It’s almost as if by this point in the report they just gave up any pretence of methodological integrity. They used the study of young Canadians used in the depression section above to calculate the association between gambling and alcohol dependence which it did consider.[xxvii] They even acknowledge that ‘Given the lack of available data, we assumed that the alcohol dependent prevalence rate is constant across all age groups’ which it obviously isn’t![xxviii] They then calculate the number of people with alcohol dependence associated with at-risk and problem gambling to be 28,312. They then estimate the number that receive alcohol treatment in England to be and multiply that by the cost of that treatment, £4.7 million.

  • This would be logical if there was hard evidence that problem gambling caused alcoholism. What we do know is its linked, so yet again to allocate 100% of the cost is being unfair and just more evidence of big numbers being added to a total to make an ideological point. Again there is no counterfactual, would these problematic young men leading problematic lifestyles not have an alcohol problem if they didn’t have a gambling problem?

  • Yet again the PHE report acknowledges this section has serious limitations. But rather than stating that there wasn’t enough research to make the assertions it does, they just go with the extremely low bar in order to come up with a number. They admit the Canadian research is looking at people from a) another country, and b) who are young and more prone to the issues being measured, and c) at-risk and problem gamblers who therefore run the whole range of PG severity, from practically nothing to pathological but with the majority at the practically nothing end. They also assume ‘that a gambler who is alcohol-dependent has the same behavioural characteristics as other alcohol-dependent individuals’.[xxix] Another case of comparing apples and pears and excusing it because there is no other research.


Health harms – illicit drug use


  • As with all the work on health harms, the foundational research is scarce and when considering illicit drug use they use the research used in the depression section.[xxx] They take this research into young people who are at risk (e.g. a lot of people basically at no risk) or PG and make their assumptions, this time, purely based on 17-24 year olds. Obviously the extrapolating young people to the whole population had become too uncomfortable. They then forget that the Foundation research asked the young people about whether they took illicit drugs and only separated these from Cannabis. This meant that ecstasy, a low harm lifestyle drug with mass use amongst young people was put in with crack cocaine, heroin and crystal meth. In trying to look for a cost of illicit drug use they use the costs and the numbers for opiate and cocaine users only. This means smaller numbers, compensated by the larger numbers of the foundation research but higher costs as hard drugs cost more to treat. They estimate 712 young people receive community treatment for drug use associated with at-risk or PG at the cost of £2m.

  • The issue with this is the same with all, scarce research, apples with pairs, no basis for allocating all the costs and the counterfactual, would these drug users have taken drugs if they didn’t have  a problem with gambling?


Health harms – quality of life


  • There is not enough research to consider Quality of Life costs


Health harms – gambling treatment


  • Unsurprisingly for an ideological document, when it comes to gambling treatment there is practically no mention of the millions spent by the gambling industry. All the report states is that the main treatment providers are ‘funded by GambleAware, a large charity provider where fundraising activities include requesting the gambling industry to donate 0.1% of their annual gross’.[xxxi] There is no comment that GambleAware was set up by the gambling industry for the very purpose of funding these treatment providers amongst other things.

  • The PHE also states that based on problem gambling prevalence numbers and the number seeking treatment, ‘this implies that just 0.5% of individuals meeting these definitions accessed treatment in 2019 to 2020. This potentially reflects the lack of access to, and provision of, gambling treatment services in England’.[xxxii] It doesn’t dare consider that a) their numbers don’t incorporate the largest treatment provider Gamblers Anonymous which doesn’t provide statistics on its membership, or the large proportion of PG’s who self-treat or, b) the methodology for prevalence numbers are faulty and over inflate the number of PGs and at-risk



Employment and Education Harms


  • There is just not enough research (if any) to calculate any costs to Education

  • This section of the PHE report starts by accepting there is very little research to attempt a costing. It will rely mostly on a 2016 Institute for Public Policy Research (IPPR) report that attempted to estimate the cost of problem gambling.[xxxiii] The PHE report comments on the IPPR report that ‘Despite its limitations, this is the only estimate made to date in the English context and no better data has been identified to test a different method’.[xxxiv]

  • It is of interest that the PHE report doesn’t comment on the fact that a report, which precedes it and attempts to achieve the same goal, estimates the cost of problem gambling in the UK in 2016 to be ‘between £260 million and £1.16 billion’ while the PHE report, just a few years later, estimates it as (no range) £1.266 Billion.

  • One of the reasons for the discrepancy of £583.4 Million (from the mid-range of the IPPR) could be that the IPPR focuses on the numbers of actual problem gamblers and doesn’t add in the at-risk gamblers (PGSI Score >0) which includes millions of people who are not problematic with their gambling.

  • Maybe the other reason that the IPPR report, which would seem like an obvious touch stone for this report is almost ignored,  is that they state:

First, it is not possible from the literature to establish the extent to which problem gambling has caused problem gamblers to access services at a rate above that of non-problem gamblers. In the absence of existing studies, and in order to help us understand the extent of causal relationships between problem gambling and the presence of supposed ‘impacts’, we devised a short survey that was completed by five UK-based academics with expertise on problem gambling. Respondents were asked to provide their own judgement on the extent to which problem gambling is a causal factor determining increased demand for some of the services we have explored above. They were able to rank the extent of causality according to a score of 0 to 5. The responses support the conclusion that it is not possible to establish causality. For each of the areas of interaction that were tested, there was no consensus on the extent of any causality derived from the presence of problem gambling….


Taking into account the lack of existing studies proving causality, and related absence of academic consensus, this study makes no attempt to claim that excess fiscal costs incurred by problem gamblers are directly caused by problem gambling. Instead, we can say only that they occur alongside, and are associated with, one another.[xxxv]


Employment and Education Harms – Unemployment


  • Copying the approach of the IPPR, the PHE manages to come out with a cost of excess cost of unemployment benefits associated with problem gambling as £79.5 million for England. This compares to the IPPR’s estimate of £40 - £160 million for the UK but £30 - £80 million for England.

  • Of interest is that in the IPPR report which the PHE uses as its foundation, the IPPR state: – an average of 0.05 JSA claims per working-age adult in the UK. – while in the PHE calculations they state: The number of claims made per working-age individual is 0.09.[xxxvi] This is an almost doubling of the amount in 3 years which seems problematic. The PHE report states that the difference in the IPPR and PHE estimates for unemployment costs can be explained partly by the uprating in unemployment costs and ‘During this period, we saw 40% more claims for the general adult population (in our baseline calculations)’, yet provides no explanation as to why.[xxxvii]


Criminal Activity


  • The PHE estimate that the excess cost of imprisonment associated with problem gambling is £162.4 million based on there being 3,799 additional prisoners incarcerated due to problem gambling.

  • The PHE report is based on one piece of research that we have been unable to access but from its abstract looks to identify the prevalence rate of problem gamblers in prison based on surveys in one male and one female prison.[xxxviii]

  • The main issue with this research is that as part of it they asked prisoners to self-report on whether they thought their gambling was the cause of their crime and these numbers are a critical part of the calculations. In explaining the limitations of the research, the PHE accepts that there is a potential problem in prisoners self-reporting but only mentions it in the context of the prisoners not being honest about which crimes they were prosecuted for, it doesn’t even consider that a prisoner may want to suggest to a researcher on problem gambling being a cause of crime that their crime was caused by gambling in an attempt to in some way mitigate their sentence. The PHE also mentions that drug related crimes are over representative in the sample – but doesn’t make the suggestion that maybe this is the reason for incarceration rather than gambling?

  • So yet again the glaring issues of no proven causality or the counterfactual – would these people be in prison if they didn’t gamble?

  • A layperson would surely ask to examining court records and see if gambling was in anyway involved in the crime may be a better research strategy


The PHE report would be innocuous if it were just some academic paper in a Journal focussed on how impossible it was to make any viable assertions on the cost of gambling harms because of a lack of research, no proof of causality (but definite associativeness) and the difficulties of co-morbidity when it comes to allocating costs and the counter factual. Before it was disbanded for incompetence, Public Health England was an anti-gambling advocate and its ex-employees and associated researchers remain so. The PHE report is a political document and is being used politically as can be seen from it being referenced in our Lords debate of the 1st March 2022.


If we look at its costs estimate:


Type of Harm                                                          Cost

Statutory homelessness                                      £62.8M

Deaths from suicide                                             £619.2M

Depression                                                             £335.5M

Alcohol dependence                                            £4.7M

Illicit drug use                                                         £2M

Unemployment benefits                                       £79.5M

Imprisonment                                                         £162.5M

Total Estimated Excess Cost                                 £1,266.1M

Taken from Gambling-related harms evidence review: the economic and social cost of harms, p.6


As can be seen, the biggest cost, 48.9% of the total, is the supposed costs of suicide. This massive cost estimate completely ignores that there is no evidence of causality, that the professional advice is to never attribute suicide to just one cause due to the complexity of the issue and even ignoring this and attributing the suicide to gambling, the issue of co-morbidity and the counterfactual is still ignored. Then we have to consider that the number of suicides is purely based on Swedish estimates where the cultural attitude is different and the suicide rate is twice as high as in the UK. Then we need to consider the way the costs have been worked out. They have used a formula use for the Department of Transport to do a cost benefit analysis when building transport infrastructure. By estimating the cost of an accidental  road death they can estimate the benefits of road traffic safety features built in to traffic infrastructure which helps in deciding budgets. This is a million miles from the tragic self-caused death of someone with severe mental health issues. It is shocking that almost half the supposed cost of gambling harms is based on the most tenuous of assumptions that don’t stand up to even the most basic levels of scrutiny.


The second biggest cost, 26.49% of the total, is the supposed cost of depression. This cost is based on taking the cost of treatment for depression which implies severe depression and applying it to a large number calculated from scant Canadian research into young people extrapolated up to a UK population and taking all those with a PGSI score >0, which includes hundreds of thousands with only minor negative consequences from their gambling and then estimating that an enormous 212,511 people were in need of treatment for serious mental illness. In 2020/21 a record 634,649 people completed the NHS Talking Therapy programme in the UK.[xxxix] The PHE therefore estimates that an equivalent of a third of the people that received therapy for mental illness in the UK would be those receiving treatment due to gambling. This is obviously a preposterously large figure due to a methodologically flawed approach unworthy of publication and that’s before there is any discussion of the lack of evidence of causality or the counterfactual.


Probably the only conclusion that can be drawn from this report is that if its authors: Annalisa Belloni, Shaun Donaghy, Brian Ferguson, Jonathan Knight, Alexandra Melaugh, William Naughton and Ruth Puig-Peiro, turned their hand to painting and decorating they would probably provide you with an estimate of £27 million just to put a few coats of magnolia on the front hall.


The PHE report needs to be withdrawn and apologies made for its outlandish attempts at politicising gambling harms.


Another concerning conclusion, is there appears to be a small pool of academics researching problem gambling. Many of who are publicly anti-gambling activists. What we see is poor quality methodology or early stage research being dressed up as evidence fit for policy making. It would not be surprising if these academics peer reviewed each other and accepted low research standards in favour of ideological campaigning. This and the public health campaign against gambling will be the subject of another article.


[i] Public Health England:  Gambling-related harms evidence review: the economic and social cost of harms, 2021, p.5


[iii] See Grinols, E. L. (2004). Gambling in America: Costs and benefits. Cambridge University Press, Grinols, Earl Mustard, David, Measuring Industry Externalities: The Curious Case Of Casinos And Crime, March 2001, Thompson, William, Gazel, Ricardo, Rickman, Dan, Social and Legal Costs of Compulsive Gambling, Gaming Law Review, Volume 1, Number 1,1997

[iv] William R. Eadington, University of Nevada, Measuring Costs from Permitted Gaming: Concepts and Categories in Evaluating Gambling’s Consequences, Journal of Gambling Studies, Vol. 19 No. 2, Summer 2003, pp.193-94

[v] Walker, Douglas M., Challenges that confront researchers on estimating the social costs of gambling. Report American Gaming Association (2008).

[vi] Ibid p.2

[vii] Ibid p.4&5

[viii] Ibid p.6. See Reith, Gerda et al (2010). Situating Problem Gambling: The Social Context of 'Gambling Careers': Full Research Report ESRC End of Award Report, RES-164-25-0006. Swindon: ESRC

[ix] Walker, Douglas M., Challenges that confront researchers on estimating the social costs of gambling. Report American Gaming Association (2008).p.7&8

[x] Muggleton N, Parpart P, Newall P, Leake D, Gathergood J, Stewart N. The associationbetween gambling and financial, social and health outcomes in big financial data. Nat HumBehav. 2021.

[xi] Gambling-related harms evidence review: the economic and social cost of harms, p.23

[xii] Ibid p.23

[xiii] Ibid p.24

[xiv] Sharman S, Dreyer J, Clark L, Bowden-Jones H. Down and Out in London: Addictive Behaviors in Homelessness. J Behav Addict. 2016;5(2):318-24

[xv] Sharman S, Dreyer J, Aitken M, Clark L, Bowden-Jones H. Rates of problematic gambling in a British homeless sample: a preliminary study. J Gambl Stud. 2015;31(2):525-32.

[xvi] Down and Out in London: Addictive Behaviors in Homelessness in web form

[xvii] Gambling-related harms evidence review: the economic and social cost of harms, p.27

[xviii] Problem gambling and suicidal thoughts, suicide attempts and non-suicidal self-harm in England: evidence from the Adult Psychiatric Morbidity Survey 2007, Heather Wardle, Simon Dymond, Ann John, Sally McManus Prepared for GambleAware May 2019

[xix] Ibid p.6

[xx] Karlsson A, Håkansson A. Gambling disorder, increased mortality, suicidality, and associated comorbidity: A longitudinal nationwide register study. J Behav Addict. 2018 Dec 1;7(4):1091-1099.

[xxi] Gambling-related harms evidence review: the economic and social cost of harms, p.31

[xxii] Afifi TO, Nicholson R, Martins SS, Sareen J. A Longitudinal Study of the Temporal Relation Between Problem Gambling and Mental and Substance Use Disorders Among Young Adults. Can J Psychiatry. 2016;61(2):102-111.

[xxiii] Ibid p.109

[xxiv] A longitudinal study of gambling in late adolescence and early adulthood: Follow-up assessment at 24 years, Alan Emond, Mark D. Griffiths, Linda Hollén, Report for GambleAware, December 2019

[xxv] Ibid p.28

[xxvi] Gambling-related harms evidence review: the economic and social cost of harms, p.35

[xxvii] Afifi TO, Nicholson R, Martins SS, Sareen J. A Longitudinal Study of the Temporal Relation Between Problem Gambling and Mental and Substance Use Disorders Among Young Adults. Can J Psychiatry. 2016;61(2):102-111.

[xxviii] Gambling-related harms evidence review: the economic and social cost of harms, p.36

[xxix] Ibid p.38

[xxx] A longitudinal study of gambling in late adolescence and early adulthood: Follow-up assessment at 24 years, Alan Emond, Mark D. Griffiths, Linda Hollén, Report for GambleAware, December 2019

[xxxi]Gambling-related harms evidence review: the economic and social cost of harms, p.42

[xxxii] Ibid p.43

[xxxiii] Thorley C, Stirling, A., Huynh, E. Cards on the Table: Cost to the government associated with people who are problem gamblers in Britain. Institute for Public Policy Research; 2016.

[xxxiv] Gambling-related harms evidence review: the economic and social cost of harms, p.45

[xxxv] Thorley C, Stirling, A., Huynh, E. Cards on the Table: Cost to the government associated with people who are problem gamblers in Britain. Institute for Public Policy Research; 2016. pp.37-38

[xxxvi] Thorley C, Stirling, A., Huynh, E. Cards on the Table: Cost to the government associated with people who are problem gamblers in Britain. Institute for Public Policy Research; 2016. p.49. Gambling-related harms evidence review: the economic and social cost of harms, p.47.

[xxxvii] Gambling-related harms evidence review: the economic and social cost of harms, p.48

[xxxviii] May-Chahal, C, Wilson, A, Humphreys, L & Anderson, J 2012, 'Promoting an Evidence-Informed Approach to Addressing Problem Gambling in UK Prison Populations', The Howard Journal of Criminal Justice, vol. 51, no. 4, pp. 372–386


The Cost of Gambling Harms

To finish this article, I will now consider two bits of so-called research that are part of the anti-gambling messaging tool box. Although they were not mentioned in the Lords debate, they are part of the very fabric of the All Party Group for Gambling Harms and the Peers for Gambling Reform so called evidence.  As with all the zombie memes cited above, they too remain un-challenged by the gambling industry and as such are allowed to roam about the political sphere infecting the uninformed in Westminster.


The first is the assertion that for the online gambling industry, “60% of its profits come from the 5% who are already problem gamblers, or are at risk of becoming so”.[i] This is one of the headline comments found in the July 2020, House of Lord’s Select Committee on the Social and Economic Impact of the Gambling Industry report entitled, Gambling Harm— Time for Action. Considering that the Select Committee was formed on the request of the virulently anti-gambling Bishop of St. Albans and had a number of the foreign-based multi-millionaire funded Peers for Gambling Reform as members, this is un-surprising, also un-surprising is the supposed evidence behind the statement. An example of how these Zombie memes find a life of their own when they are unchallenged, is that in a recent Commons debate, Paul Blomfield MP, Labour (Sheffield Central) stated that ‘Eighty-six per cent. of its profits come from just 5% of its customers—those who are addicted or at risk of harm.’[ii]


Below is a replica of the chart provided on p.74 of the House of Lords report:


As the report mentions, this research estimates that problem gamblers account for almost 25% of online gambling profits and when you add together all the supposed profits from all the gamblers supposedly at risk of problem gambling (Low risk 17.04%, Moderate risk 17.10% and Problem gambler 24.49%) you get to 58.63%, so rounded up it’s a massive 60%.


Before we even consider how these numbers were concocted we need to state, yet again, that the categories of low-risk and moderate-risk are highly problematic. They imply that there is linear progression in problem gambling and that those who are low risk, become moderate risk and those who are moderate risk become problem gamblers. This is not always the case in a significant proportion of examples, as even one of the more prominent activist anti-gambling academics, Gerda Reith, has found, behaviour changes or stays the same.[i]


These categories only have validity when considered as thresholds of the PGSI problem gambling screen. A similar screen (although DSM IV variant) is shown above when discussing children’s gambling. In the PGSI the following questions are asked:


Over the last 12 months have you:


  1. Have you bet more than you could really afford to lose?

  2. Have you needed to gamble with larger amounts of money to get the same feeling of excitement?

  3. When you gambled, did you go back another day to try to win back the money you lost?

  4. Have you borrowed money or sold anything to get money to gamble?

  5. Have you felt that you might have a problem with gambling?

  6. Has gambling caused you any health problems, including stress or anxiety?

  7. Have people criticized your betting or told you that you had a gambling problem, regardless of whether or not you thought it was true?

  8. Has your gambling caused any financial problems for you or your household?

  9. Have you felt guilty about the way you gamble or what happens when you gamble?


The possible answers and scores allotted are:


  • never = score zero

  • sometimes = score one

  • most of the time = score two

  • almost always = score three


The official, as in used in the Health Survey for England, Scottish Health Survey and the Welsh Problem gambling Survey, scoring thresholds are:



0                 Gamblers who gamble with no negative consequences

1-2             Gamblers who experience a low level of problems with few or no identified negative                              consequences

3-7             Gamblers who experience a moderate level of problems leading to some negative                                  consequences

8 or more        Gambling with negative consequences and a possible loss of control[ii]


This supposed research, along with much of the research mentioned in this paper prefers to use terms that include the word ‘risk’- obviously for its emotive impact – and fail to comment that low risk actually means ‘low level of problems with few or no identified negative consequences’ and moderate risk actually means ‘moderate level of problems leading to some negative consequences’. This is far less ‘scary’ and points out that there are some negative consequences but not imminent mental and family breakdown and thoughts of suicide, negative consequences can just mean financial loss.


When trying to work out where these numbers come from, we see from the references from the Lord’s Select Committee that they got their numbers from the August 2018 report from the centre-right think tank, ResPublica, entitled Online Gambling: Addicted to Addiction by Tim Cowen (a competition lawyer) and Phillip Blond (head of ResPublica) and funded by the Campaign for Fairer Gambling which is funded by the foreign-based multi-millionaire.[iii] In the previous year, ResPublica published ‘Wheel of Misfortune: The case for lowering the stakes on Fixed Odds Betting Terminals’ which was also funded by the Campaign for Fairer Gambling.[iv] Of interest is that the co-author is James Noyes, who goes on to work for the Social Market Foundation, who bring out their own anti-gambling reports also funded by the foreign multi-millionaire. The foreword of the anti-FOBT report is written by Chris Philp MP, our current gambling Minister.


The ResPublica report cites the following:


Howard Reed of Landman Economics calculated this data using the number of days and the amount of money spent on online gambling, using Table 13 on Page 43 in the PWC report for GambleAware (2017), Remote Gambling Research (online) - available at - and combining this with Tables 3.3 and 4.5 in NatCen (2017), Gambling behaviour in Great Britain in 2015 (online), which is available at[v]


Howard Reed of Landman Economics also has form, having written in 2013 the report, The Economic Impact of Fixed Odds Betting Terminals, also funded by the Campaign for Fairer Gambling also funded by the foreign based multi-millionaire.[vi] This, like the NERA report mentioned above used the argument: ‘For every additional £1 billion spent on FOBTs, an estimated 7,000 jobs are created in the betting sector. However, at the same time consumer spending on other goods and services falls by £1 billion, which reduces employment in other industries by around 20,000’.[vii] Like with the NERA report, this approach was widely ridiculed.


To try and understand how the 60% of profits from problem gamblers was derived at, let us look at the three tables mentioned:


PWC/GambleAware, Remote Gambling Research Interim report on Phase II, August 2017

p.43 Table 13. Transactional and account behaviours by PGSI band: median (inter-quartile range)


2017, NatCen Social Research, Gambling behaviour in Great Britain in 2015

Non-economists may find it a bit difficult to calculate how a percentage of profits of the online gambling industry was calculated using the data in these three tables as cited. We also think that most economists will have problems too, especially as this data doesn’t consider winnings anywhere which are surely a critical factor in estimating profits. Such is the confusion about how the 60% figure was reached, an email was sent to Howard Reed of Landman Economics asking for an explanation and he responded with:


  1. From the PWC report (p.43, Table 13), you take the number of betting days per year for each category of gambler (non-problem, low-risk, moderate risk and problem gambler) and multiply by the daily amount staked to give you an annual amount staked by each category of gambler: Non-problem =£1,092, low-risk=£2,024, moderate-risk=£4,644, problem gambler=£9,310).


  1. From the Nat Cen report (Table 3.3) you get the percentage of low-risk (16%) and moderate-risk (7%) gamblers who gamble online. From the Nat Cen report (Table 4.5) you get the percentage of problem gamblers who have gambled online 5.1%. It can then be deduced that the number of non-problem gamblers is 72% as 100%-16%-7%-5%=72%.


  1. Mr Reed then multiplies these two columns together:

            Non-problem£1,092 x 72% = £786

            Low-risk£2,024 x 16%= £324

            Moderate-risk£4,644 x 7% = £325

            Problem gambler £9,310 x 5% = £466




  1. Mr Reed then breaks down the categories as a percentage of this total number




           Problem gambler £466÷£1,901=0.24=24%


  1. Mr Reed then adds all the percentages of the at-risk and problem gamblers and you get 17%+17%+24%=58% or 60% rounded up[viii]


What is not so clear is how this equates to the gambling industry profits?


Ignoring the fact that these are two very different reports that do things very differently, it does seem impossible to make an estimate on company profits when there is no knowledge of winnings and even then you would only get to Gross Gaming Revenue – there is no understanding of costs, which seems bizarre considering how the anti-gambling groups like to hector about the amount the industry spends on marketing


As this author is basically number illiterate, Dan Waugh of Regulus Partners was asked to comment on Mr Reed’s calculations:


This assertion [60% of online gambling profits come from the 5% of gamblers that a PG or at risk of it] is demonstrably false – based on a corruption of findings from the PWC ‘Remote Gambling Phase II’ report from 2017. The PWC study does suggest that a large proportion of stakes (which is neither revenue or profit, nor a particularly good proxy for either) derived from PGSI ‘problem’ and ‘at risk’ gamblers’ – but the study itself was deliberately skewed to include a much higher proportion of ‘problem’ and ‘at risk’ gamblers (63% in the PWC sample) than is found in the population (3.9% of adults or around 8% of gamblers in the Health Survey 2018) and was based exclusively on remote gambling expenditure. The House of Lords report thus took a finding from one skewed study of online gamblers and applied it to the entire population, including non-gamblers – something that is clearly nonsensical. Attempts to replicate the calculation, using the correct PGSI prevalence figures for online gambling (and notwithstanding the methodological issues of extrapolation between two very different studies) present a rather different picture. Using results from the 2015 Health Surveys suggests that 58.9% of stakes might be attributed to the 28.1% of online gamblers classified as ‘at risk’ or ‘problem’ gamblers; and this falls to 53.5% of stakes from 26.4%, when using 2018 results."


On page 17 of the PwC report you will find this comment: "The sample was explicitly skewed to avoid very infrequent bettors and increase the proportion of problem gamblers. This was important for the present study to strengthen the signal from markers of remote problem gambling. However, the findings on problem gambling prevalence are not generalisable to the larger population of online gamblers."


What Landsman/Respublica does is not only generalise the findings for all online gamblers (in contravention of the report's warning) but generalise the findings for all adults in Britain - regardless of whether they gamble or not.[ix]


Yet again one of the key issues is the term at-risk gamblers. This is people who score >0 on the PGSI screen. As a reminder the biggest proportion of these ‘at risk’ gamblers have ‘few or no identified negative consequences’. Before the Public Health lobby started their anti-gambling campaign, research just looked at problem gamblers, those with actual problems with their gambling. Then the activists realised that if they included categories of ‘at risk’ implying an imminent descent into problem gambling, which is unevidenced, they would massively increase the number of people supposedly being affected by gambling and so increase the numbers in every piece of research.


Add to that the common ignorance of winnings, the main motivation of all gamblers and you begin to see what is an orchestrated moralistic middle class campaign against gamblers as has occurred episodically throughout the last three centuries.

[i] House of Lords, Select Committee on the Social and Economic Impact of the Gambling Industry, Report of Session 2019–21, HL Paper 79, Gambling Harm— Time for Action, p.6




i] Reith, Gerda et al (2010). Situating Problem Gambling: The Social Context of 'Gambling Careers': Full Research Report ESRC End of Award Report, RES-164-25-0006. Swindon: ESRC








[v] ResPublica, Online Gambling: Addicted to Addiction, Tim Cowen and Phillip Blond, p.12


[vi] Landman Economics, The Economic Impact of Fixed Odds Betting Terminals, A report by Howard Reed (Director, Landman Economics), April 2013


[vii] Ibid p.18

[viii] email from Howard Reed to the author 23/04/22

[ix] email from Dan Waugh to the author 23/04/22

"60% of online gambling profits"

This rather nicely segues into my final Zombie meme, as the research I shall critique also doesn’t consider winnings as part of its calculations and is also being used politically, this time by our gambling Minister, Chris Philip, he of the anti-FOBT foreword mentioned above.


Oxford University’s Naomi Muggleton et al’s The association between gambling and financial, social and health outcomes in big financial data is another example of research looking for a causality of harms due to gambling while ignoring the fact that the majority of problem gamblers are from the lower socio-economic groups who have traditionally suffered social harms due to their lower economic status rather than gambling.[i] Yet again, it is activist academics failing to ask the counterfactual. It should be noted that one of the co-authors of this research, Dr Philip Newall was also a specialist advisor to the less than neutral, House of Lord’s Select Committee on the Social and Economic Impact of the Gambling Industry report along with the overtly anti-gambling Prof. Rebecca Cassidy of Goldsmiths.


The Muggleton report is clearly negative in tone, you can almost feel the middle class hand wringing that went on when they found that ‘the top 10% of gamblers spending >£1,800 on gambling in the calendar year, close to 8% of their total spending’.[ii] That’s £34.61 per week on gambling and their total spending is unknown to Ms Muggleton, as this report only covers transactions from one bank to gambling companies that have been coded that way on banking transactions (miscoding of transactions is very common). It completely ignores all cash transactions, the fact that people may have more than one bank account and there is no mention of winnings which some would say it critical to any financial analysis. Although annual income is a variable that is used throughout the research it does not say how this data is known, because for some people their income or part of their income (if more than one job) may be in cash so not counted or may not be transferred into their Lloyds bank account.


The report makes bold statements:


Gambling and financial stress


  • Higher gambling is associated with a higher rate of using an unplanned bank overdraft, missing a credit card, loan or mortgage payment, and taking a payday loan

  • Gambling is associated with lower rates of holding a credit card, loan or mortgage, higher use of credit card balances and a higher likelihood of the individual being subject to debt collection by bailiffs.

  • Higher gambling is associated with smaller spends on insurance and mortgage repayments, smaller total savings and smaller pension contributions


None of which we would have an issue with if we are considering people for who gambling is a problem due to a mental health issues. The data  does not include any PGSI/DSM-IV screening so we can’t easily say that those with problematic gambling are the ones showing the most financial stress. But as Muggleton points out:


the association with gambling is notably stronger at high percentile ranks approximately above the 75th percentile (which equates to ~3.6% of total monthly expenditure). This suggests that the relationship between gambling and many of the harmful outcomes is stronger when the individual is devoting a relatively large share of total monthly spending to gambling.[iii]


This at least acknowledges that there are a relatively small proportion who gamble larger amounts and also suffer financial issues. We would think it logical that those who have the mental issues focussed on gambling are the most likely to be suffering financial issues. But, as said before, there is a correlation between gambling and socio-economic status and there is a correlation between socio-economic status and negative financial outcomes, the two do not mean causality.


Gambling, lifestyle and well being


This section could not epitomise more the middle class sneering at gamblers by academic activists, which I think can be argued is a proxy, for working class lifestyles. Negative activities are considered by spend on fast food, gaming, bars, tobacco and off licences. Positive activities are considered by spend on hobbies, social activities, education and travel. The paper is peppered with value-laden assumptions. Muggleton states:


Results show a negative association between gambling and self-care, fitness activities (for example, gym membership), social activities, and spending on education and hobbies. There is also an association between gambling, social isolation and night-time wakefulness—individuals spending more on gambling travel less and are more likely to spend at night.[iv]


One wonders if Muggleton et al, have ever met the predominantly young male, working class men who gamble and enjoy their nights out rather than a soya latte followed by yoga and mindfulness workshop before a weekend break somewhere exotic these researchers seem to think epitomises a wholesome lifestyle. This has overtones of the interwar and post war activists who campaigned to bring opera and art to the working classes so that, if only by access, they would end their decadent ways and get cultured. There is also no acceptance that gambling itself is often a social activity for many gamblers or that those gambling on their phone at 4am in the morning may be passing the time while bored working a night shift. 


Gambling, unemployment, disability and mortality.


This section could not epitomise more the conceptual leaps that activist academics are prepared to make in trying to find negative outcomes from gambling. Muggleton suggests that there is an association with higher levels of gambling and ‘with a higher risk of future unemployment and future physical disability’.[v] What is important here is the use of the term association, to most laypeople and we include policymakers in this, it automatically implies that one factor determines another, otherwise know as correlation. The amount of US spending on science, space and technology has a 99.79% correlation with the number of suicides by hanging, strangulation and suffocation but no one is suggesting that one causes the other.[vi] Muggleton implies that increased levels of gambling in some way cause disability which is verging on the surreal. As for unemployment; ‘employed individuals in the highest percentiles of gambling having a 6% likelihood of experiencing future unemployment’[vii] looks equally a stretch. While we can consider, as stated above, that those at the highest levels of gambling spend are most likely those with the mental health issues who would find most difficult to keep a job, we must also consider the UK job market that for a large proportion of people is highly precarious and so to expect someone to maintain continuous employment for five years suggests someone of a purely public sector lifetime tenure worldview. The 6% figure should surely have been questioned as whether it was not it was significant or just noise.


The most preposterous methodological overreach is Muggleton’s claim that high levels of gambling is linked with premature death. She gives the example:


among 44-year-old women, gambling 30% of annual expenditure (relative to 0%) is associated with an increased chance of death from 50 in 10,000 (95% CIs [50, 51]) to 69 in 10,000 (95% CIs [66, 72]) or by a factor of 1.37 (Supplementary Table 11). High levels of gambling are associated with a likelihood of mortality that is about one-third higher, for both men and women, younger and older.[viii]


In other words, a very specific type of gambler (female, 44 year old) who spends an a enormous amount on gambling (30% of annual expenditure – the equivalent of rent/mortgage payments) has a chance of death of 0.69% compared to a non-gamblers’ 0.5%, Yes, that is a massive increase of x1.37 but in reality we are considering an outlier due to her level of gambling spend and still incredibly small chances of death with no explanation of how the correlation has occurred.


How much relevance is there in Muggleton’s statement that ‘High levels of gambling are associated with a likelihood of mortality that is about one-third higher, for both men and women, younger and older’ when there is no consideration of causality or other more relevant socio-economic factors.[ix] These statements are obviously there for emotive effect.


It should be stated that hidden away in the discussions section and not written in prominence as it should be is the statement:


we do not establish causality, which means that findings demonstrate associations that may reflect causality or comorbidity—both of which are of concern. Causality would indicate that higher levels of gambling increase one’s risk of negative outcomes like financial distress, social exclusion, disability and unemployment. Comorbidity, however, would indicate that individuals who are susceptible to these negative outcomes due to other factors are more likely to be drawn to gambling. In reality, the observed effects could result from a blend of causality and comorbidity, both of which have significant implications for policy-makers and public health experts.




our methodology does not rule out the possibility of reverse causation, such that an increase in harm precedes an increase in gambling. To partially overcome this, we use measures of gambling at t0 to predict outcomes at t1 to exclude scenarios where, say, missing a credit card payment leads to an individual gambling as a means to pay off debt.


and of most importance to anyone who has bothered to consider that gamblers exist in a complex world and are not just data points in statistical formulas to be massaged to make ideological campaign points


the breadth of our analyses means that we cannot control for all social, economic and political events that occurred in the 2012–2018 window of our study.[x]


What the Muggleton report is, as with much of the research considered in this paper is anti-gambling activist half truths that are being used as the evidence in evidence-based policy making. Nowhere are the scientists involved shouting from the rooftops that their research is based on incomplete data and comes up with very limited results and that they all scream out for more research to make up for the glaring holes in their own research. Nor are any of the scientists standing up and critiquing their fellow academics for publishing such methodologically flawed ideologically based insults to the scientific process.


[i] Muggleton, N., Parpart, P., Newall, P. et al. The association between gambling and financial, social and health outcomes in big financial data. Nat Hum Behav 5, 319–326 (2021). NatCen Social Research, Gambling behaviour in Great Britain in 2015, p.48

[ii] The association between gambling and financial, social and health outcomes in big financial data, p.320

[iii] Ibid p.320

[iv] Ibid p.321

[v] Ibid p.321

[vi]  accessed 24/03/22

[vii] The association between gambling and financial, social and health outcomes in big financial data, p.321

[viii] Ibid p.321

[ix] Ibid p.321

[x] Ibid p.323

Muggleton et al

Because the scientific community is so blatantly failing in its tradition of peer review and willingness to accept ideological dogma over the spirit of the enlightenment, it should be the eventual victims of this orchestrated campaign against it that should be fighting the hardest to counter this disinformation war, but where is the gambling industry?


In a final military analogy, currently in the information war over British gambling’s future, the gambling industry is fighting much like the Italians in the Second World War. While individually they were as brave as every other nation, their persistent defeats were due to poor leadership, confused objectives and poor allocation of resources. Unfortunately, unless things change very rapidly, with the most anti-gambling gambling Minister in living history and a white paper due in May, the future of the British gambling industry will seem like that of post-war Italy’s – utter chaos and devastation.

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