The Campaign for Fairer Gambling (CFG) has submitted an 11-page complaint document with 44 sourced references to the Charity Commission following news that the Commission was investigating the Responsible Gambling Trust (RGT). CFG also advised that a further submission of evidence would be presented next month.
One of the key issues relates to the FOBT research which was set to answer two questions:
1. Can we distinguish between harmful and non-harmful gaming machine play?
2. If we can, what measures might limit harmful play without impacting on those who do not exhibit harmful behaviour?
When the research was made public in December 2014, it was clear that the second question had been virtually ignored. Whilst the first question is designed to tell us nothing about what is causing the harm, removing the word “machine” might still have provided worthwhile research.
If distinguishing harmful play was the objective, this could have been achieved far more easily on remote gambling than on machines. Remote sites have full data on all the records of all their gamblers, including the funds deposited, added to and withdrawn. They also have the record of players switching across sports, racing, bingo, table games and slots.
But nearly all the FOBT data is anonymous, so it had to focus on a sample of a few thousand loyalty card players. This meant that if any inconvenient truths were to be uncovered by the research, there would be inbuilt excuses to argue against the result such as: "gamblers may not have always used their loyalty card giving incomplete data", and "the loyalty group is not representative of all gamblers so giving biased data."
The reason that the distinguishing harmful play question was not asked of remote gambling, where it could best be answered, is that the FOBT research was designed to address a political situation.
The 2005 Gambling Act legitimised FOBTs as category B2 machines. It was recognised that these could be dangerous and counterproductive to the licensing objective of the prevention of harm to the young and vulnerable. As
Baroness (Tessa) Jowell explains, FOBTs were "on probation” and Labour got it wrong. The gift was granted to the DCMS minister to reduce the stakes on FOBTs without primary legislation. This could be done at any time under the basis of the precautionary principle.
Lord (Don) Foster, former Lib Dem MP and part of the last Coalition Government asked in 2012 for this stake reduction to be undertaken and reduced to £2 per spin. As this request was denied, the FOBT research questions should have been-
1. Do the features of FOBTs – such as stake size, speed of play and the roulette content – induce or exacerbate gambling related harm?
2. What harm reduction will be provided by a stake reduction from £100 to £2?
But the RGT was not willing to ask these research questions. It does not want to fund research that could suggest reducing gambling as a method of reducing harm. In order to steer the Government away from stake reduction, Neil Goulden, then RGT Chair and at the same time Chair of the Association of British Bookmakers, wrote to DCMS in both capacities requesting meetings. Mr. Goulden has since
resigned from both positions.
The research questions were then proposed by the Responsible Gambling Strategy Board (RGSB), which answers to the Gambling Commission. The RGT has always claimed that the RGSB set the research questions, but recently the Gambling Commission claimed that the RGT set the questions.
The RGT also claims that the RGT Research Committee includes observers from DCMS. What representations did the RGT make to DCMS at those meetings? Who set the questions? Who approved the questions? Why were the questions approved? Will the truth ever come out?
In a recent press release the RGT states, "campaigners are seeking to undermine RGT ... because the outcome of our ... research did not say what they wanted it to say". When Lord Bell of Bell Pottinger spoke at an ABB annual meeting he advised against them naming their opponents. Bell Pottinger is the PR firm for the RGT. The term "campaigners" enables anything said by anyone opposing FOBTs to be implicated in the STOP the FOBTs campaign by CFG, so is a useful means for the RGT to try and discredit CFG.
It is grossly misleading to state that the CFG is "unhappy with the outcome" as the outcome was totally predictable. CFG is unhappy with the way that due process has been abused and that the abuse has been covered up.
The RGT press release also makes the misleading statement that: "No-one has produced proof that the research is flawed and biased". CFG has published appropriate independent research which is very
critical of the RGT FOBT research, conducted by academics with impeccable credentials.
So even if there was no financial corruption and no organized conspiracy, the impact of the RGT research was to help to delay any political action against FOBTs, protect the bookies’ high street monopoly on FOBTs and increase their FOBT revenues, consequently resulting in a greater quantity of FOBT harm.