More Double Standards

## Double Standards – Lottery – iGB

One of the most prevalent criticisms of the gaming industry is that it focuses on low-income individuals. We are constantly reminded that the most egregious offenders are UK retail betting companies, writes Jon Bruford.

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More Double Standards

Every business will target its most numerous clientele. I’m not suggesting this is morally right or wrong, it’s simply a reality. In these areas, you’ll find a greater number of low-rent unlicensed establishments, more kebab shops and more charity stores, and fewer Waitrose stores. High-income areas have more Waitrose, fewer betting shops… that’s just how it is.

However, for some reason, the National Lottery has never been included in this discussion.

This is the epitome of gambling normalization. Its initial advertising campaigns were all about: “Transform your unfortunate life, win the lottery!” It’s still permitted to advertise in The Guardian, so you know it’s entirely accepted by the middle class and above.

Why am I singling out the lottery? Because the playing field is far from equitable, and recent news makes me believe it won’t be made fair anytime soon.

The National Lottery Exemption

The government recently announced a consultation on a new mandatory gaming tax levy, aimed at raising additional funds for gambling harm Research, Education and Treatment (RET).

The Arts Minister, Lucy Fraser, declared: “We’re taking a significant step to safeguard those most susceptible to gambling-related issues by implementing a new levy on gambling operators. The funds generated will be directed towards treatment and research.

“Every gambling enterprise will be obligated to contribute equitably. This period of gathering input offers a chance for the industry, medical professionals, individuals who have encountered gambling-related harm, and the broader public to express their views on the proposed method of taxing gambling companies.

“The introduction of this tax will bolster the safety net and aid in realizing our long-term objectives to foster stronger communities, while enabling millions to continue engaging in gambling responsibly.”

Naturally, what she stated and her true intentions are not identical. “Every gambling enterprise will be obligated to contribute equitably,” except for the National Lottery. For some unknown reason, it’s neither classified nor treated as a gambling enterprise, despite being the most substantial by a significant margin. Of course, directing funds to worthy causes is commendable – and it alleviates the government’s burden of finding ways to ease the strain on citizens. So everyone benefits, correct? Incorrect.

Because the lottery isn’t merely a lottery drawing. Retailers also sell scratch-off tickets, and that’s a completely different scenario.

The issue with this type of wagering is… where to even start? In the “Journal of Gambling Issues,” Dr. Mark Griffiths, Professor of Behavioral Addiction at Nottingham Trent University, states that scratch cards are a “tough” form of gambling.

This “tough” classification puts them on the same level as games like roulette and blackjack, not the casual, harmless games we might be led to believe.

The ease of access to scratch cards
Lotteries themselves, despite their numerous auxiliary games, are definitely gentle gambling – the low event frequency ensures this. Even the UK’s auxiliary games follow this pattern.

But scratch cards? They are frequently designed to imitate fruit machines or similar machines, which feature “the potential to trigger excessive gambling, regardless of the gambler’s personality, environment or genetic makeup. These features include the ability to produce a psychologically pleasurable experience in the face of economic loss – particularly the near-miss phenomenon,” says Professor Griffiths.

So, what’s the big deal? It’s the combination of normalization and the number of sales outlets. There are over 6,000 retail betting shops in the UK; that’s about one betting shop for every 10,000 people. Yes, I know, they aren’t evenly distributed/proportional. Just to illustrate the point.

The National Lottery has over 43,000 points of sale, all of which sell scratch cards.

Camelot, the operator, boasted that a vast majority of the UK population, a staggering 94%, resides or works within a short distance, a mere mile, of a National Lottery outlet.

I attempted to obtain more specific data, categorized by demographics and geographical location, but predictably, they declined to provide such information. They explained that releasing more detailed, commercially sensitive sales figures could empower competitors to target specific regions of the UK for promotional campaigns, which would negatively impact Camelot’s overarching objective of maximizing profits for charitable causes.

Or, as I prefer to put it, it would hinder Camelot’s ability to sell more lottery tickets.

The fundamental objective of any gambling operator is to generate profits, and anyone who claims otherwise is being dishonest. The charitable aspect is merely a tactic employed by lottery operators to circumvent the stringent regulations that the rest of us must adhere to.

Safeguarding those under the age of 18
Withholding this information also avoids scrutiny of the proliferation of sales points in various areas, because – and I’m taking a chance here – I’d wager it reflects the concentration of retail gambling outlets, and surpasses them proportionally.

Camelot did emphasize their efforts to ensure retailers comply with the law, refraining from selling to minors and requesting identification, which is quite commendable.

A representative communicated with me electronically: “Although National Lottery games are different from those offered by the broader gambling sector, we and our retail partners must keep working hard to stop underage and excessive participation.

“For instance, in 2022-23, we made over 11,600 visits to retailers as part of ‘Operation 18’ – which uses individuals over the age of 18 but who look younger – to prevent retailers from accidentally breaking the law during test visits. If retailers fail three secret shopper visits, their National Lottery terminal will be suspended and might be removed.

“I am happy to say that in the 2022-23 ‘Operation 18’ secret shopper program, a record 92% of National Lottery retailers correctly asked for identification on the first visit – showing their continued dedication to selling National Lottery games responsibly. This top performance is especially impressive considering that the National Lottery’s participation age only changed from 16 to 18 in 2021.”

Possible negative effects
The representative added: “As part of our commitment to healthy gaming, we have a variety of other training programs. For example, in 2022-23, our retail team made over 160,000 contacts with National Lottery retailers via phone, in-person visits and email – giving them advice on preventing underage play and how to best support healthy gaming in-store.

The “Healthy Gaming” secret shopper program has been implemented in various locations, involving over 4,000 store visits to educate retailers about recognizing signs of unhealthy gaming habits among their patrons.

This surpasses the efforts of most gambling companies, even when considering their retail team visits to promote responsible gaming. The company also pledged to train retailers to identify unhealthy behaviors.

However, as Professor Griffiths stated, “It’s easy to see how scratchcards could become an addictive habit, because they combine conditioned reflexes, frequent events, quick payouts, and psychological rewards. They also require no skill, are inexpensive, readily available, and sold in everyday stores.”

This makes the claim that “National Lottery games are distinct from other gambling games” appear more plausible. They are not that different.

A representative stated, “The risk of addiction from National Lottery games is extremely low due to our robust safeguards, and this is widely acknowledged.” I disagree. If you consider all forms of gambling together, I believe the addiction risk from the main games would lower the overall data.

Including the National Lottery in RET taxation…

Although this is the case, I don’t believe anyone specifically researches scratch cards, and considering the nature of retail and players, I don’t think it’s feasible to track risky behavior with this kind of game.

However, what truly surprised me was that I completely agreed with the Gambling Commission on this matter. Following the RET consultation announcement, they stated: “We believe [taxation] should apply to all operators, including national lotteries, without negatively impacting good causes, they are not immune from problem gamblers using their products (such as scratch cards and instant win games) to gamble.”

Imagine the positive impact that could be achieved if their extensive sales network was involved, and all game types were taxed, including the National Lottery.

As I always emphasize, if it’s an issue, treat it as an issue. Don’t be selective because you have a preference.

Jon Buford has been involved in the gambling industry for over 17 years, previously serving as Executive Editor of International Casino magazine and currently as Publishing Director of Gaming Board, collaborating with Kate Chambers and Greg Saint. He owns a very large canine with a delicate stomach, and dedicates his leisure time to learning how to remove stains.

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