Regulus Partners, the strategic consultancy focused on international gambling and related industries, takes a look at UK stakeholder dynamics on collaborations for tackling problem gambling and addiction.
Collaboration is a rather subjective word; used variously to describe the very best and the very worst of human endeavour. In business, being collaborative is generally held to be a positive attribute; but in 1940s France, being branded as a ‘collaborator’ was a term of shame and derision.
Where one stands on collaboration tends to be dictated by who is collaborating with whom and to what end. This week, there were further signals in the UK that while collaboration to address gambling-related harm is a ‘good thing’, there may be boundaries to this; and that the gambling industry is in danger of falling (or being pushed) outside of those boundaries
On Tuesday in the House of Commons, GambleAware hosted an “informal policy fair to discuss opportunities to reduce gambling-related harm, with leading treatment providers, charities, churches and other interested groups”. Curiously it seems that no-one (so far as we can tell) from Britain’s licensed gambling industry was invited. By any sane definition of “other interested groups”, licensed gambling operators ought to have been invited. They are the ones providing the products and services that excite concerns; and they also (by choice) bankroll GambleAware – an organisation that they founded.
A number of other organisations engaged in harm prevention work were apparently not invited; their collaboration with licensed operators suggested as a possible reason for exclusion. Whether or not gambling operators were welcome at the event is relatively unimportant by itself (and the charity will have entirely valid reasons for selectivity); but the episode may also be symptomatic of a growing – and perhaps unhelpful – a process of segregation.
For instance, some commentators have observed that the proposed Gambling Commission national strategy to reduce gambling harms appears to silo industry initiatives away from efforts by treatment providers and public health organisations (in stark contrast to the current strategy which explicitly aspired to collaboration between the Commission, GambleAware and the industry). Similarly, the involvement or not of gambling operators has been a controversial aspect of the forthcoming GambleAware/Public Health England harm awareness advertising campaign (which the industry is expected to fund).
There is a sense that the gambling industry is starting to be shut out of discussions in the UK in which it ought to be a key participant: and elsewhere globally, where the industry is shut out knee-jerk and swingeing negative regulation tends to follow. So, where has all this come from and how wide (in terms of the global market) might it extend?
In 2017, what seemed like a rather abstruse spat kicked off in the world of gambling studies when Linda Hancock (Deakin University, Australia) and Garry Smith (Alberta University, Canada) published a paper in the International Journal on Mental Health and Addiction. The paper attacked the Reno Model, which is the theoretical construct that has influenced gambling policy in many western markets since its formulation in 2004.
One of Hancock and Smith’s criticisms was the Reno Model’s conception of a harm prevention programme based upon a collaborative and coordinated effort between the state, the industry and treatment or health services. They effectively argued that the commercial interests of industry were incompatible with the aims of harm reduction; and that therefore operators should be excluded from structures and processes intended to guide policy.
In Great Britain, highly respected researchers like Rebecca Cassidy and Jim Orford have made similar arguments. It is all symptomatic of a loss of trust in the industry allied perhaps with a broader tide of opinion in the field of public health (as last year’s DrinkAware controversy indicated); perhaps considered more stark in the UK than elsewhere given the strong levels of government collaboration enjoyed by elements of the industry prior to c. 2006 (or by adopting a very Anglo-centric offshore stance in Gibraltar prior to 2014: feeling part of the party without actually having an invitation).
As we have written before, the gambling industry needs to reflect on what it has done (or not done) to create this trust deficit and to take steps to address it. However, it is also important to remember that ‘the industry’ is an artificial collective; and thus while some market participants may have behaved ‘badly’, this is certainly not true of all. The absence of discrimination in such matters is not simply unfair; it also denies us the opportunity to show what responsible operation looks like and incentivise others to follow suit (thus using incentivisation and compulsion rather than solely the latter).
Those who take a dogmatic stance on this issue are unlikely to be swayed by these considerations; but they may wish to reflect on the fact that the more operators are excluded from discussions, the more they are likely to coalesce around an ‘anti-gambling’ framework which lacks necessary and valid balance. Given how industry disunity has played into the hands of the public health and anti-gambling lobbies in the past, segregation may not actually be in their interests either.
These are difficult times to be dealing with gambling policy – whether at DCMS or the Gambling Commission. However, the interests of the vulnerable (and consumers at large) will be best served by true collaboration between the key participants, based upon a spirit of tolerance, intellectual enquiry and respect for others. Now more than ever, we require the courage of governments and regulators to insist on an inclusive and coordinated approach to harm prevention – the alternative is stymied sectors of grudgingly compliant operators and a burgeoning black market with no social responsibility considerations at all: a position that the UK at least has hitherto avoided.
Winning Post – Regulus Partners