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Will there be a Starmergeddon for gambling?

In this unnecessarily lengthy article, in preparation for a future publication, I am doing some thinking about the new political landscape for the British gambling industry after the July 2024 general Election (GE24). TLDR: I think there will be an on-going ratcheting up of further restrictions and a consequential explosion in the black market as I see no evidence of industry push-back.

 

The usual caveats apply, i.e. nothing is predictable and most political forecasts go woefully wrong, so take all of this with handfuls of salt. And as a trigger warning, I have used satirical commentary about people and groups of people. If it offends you, it is probably because the satire is quite close to the truth, get over it and grow up.

 

I’m going to walk through the main political players and discuss how the new landscape has changed.

 

First up is our new Prime Minister who in his Labour Party General Election manifesto stated:

 

Labour is committed to reducing gambling-related harm. Recognising the evolution of the gambling landscape since 2005, Labour will reform gambling regulation, strengthening protections. We will continue to work with the industry on how to ensure responsible gambling.[i]

 

The fact that there is no acknowledgement of the work done in the gambling White Paper is interesting but can be purely administrative. Gambling never gets more than a few sentences in any manifesto and this could have been from any Labour one since the 2010 election. The use of the term responsible gambling is re-assuring as it could signify that they have not drunk from the Kool-Aid of Public Health (of which more later) who dislike the term for ideological reasons. A counter argument is that they just have not updated their gambling section from previous versions.

 

But to see the only optics about gambling to be about harm is always a worry as it inserts in-built bias into the gambling debate. Again, gambling Minister (2010-2012) John Penrose MP, who predicted that this would be how all future debates about gambling would go in the future has been proved correct again and this is something the industry needs to confront or it will be regulated out of existence.

 

To be clear, Public Health zealots want gambling banned. The industry needs to shout from the rooftops that normal gamblers suffer zero harm and that problem gamblers, a tiny percentage of those who indulge are suffering complex mental health issues, none of which will be solved by banning gambling. Banning gambling just fuels the black market, where potential addicts will just get exploited.

 

[i] https://labour.org.uk/wp-content/uploads/2024/06/Labour-Party-manifesto-2024.pdf p.103

Number 10: Prime Minister Keir Starmer

 

The UK’s 58th Prime Minister, now resident in No.10 Downing Street, the Right Honourable Sir Keir Rodney Starmer KCB KC MP has only been an MP since 2015. He has never spoken in Parliament about racing, betting or gambling in all that time. His background as a lefty human rights lawyer and then Director of Public Prosecutions and head of the Crown Prosecution Service gives the implication that there is no reason why he should have, being  legally focussed and willing to support Jeremy Corbyn in two elections even though he despised him.

 

Two factors that may be in our favour are his love of football, playing for an amateur team and being a big Arsenal fan and his idolisation of his father’s job as a toolmaker, suggesting a support for working class culture. Unfortunately, a love of football does not always mean a support for the gambling firms that spend hundreds of millions sponsoring the teams and through various charities, funding the grass roots of football. Just look at the most gambling hating Minister ever, Dame Tracey Crouch MP, who thankfully resigned at the last election and whose Football regulator campaign looks like being scuppered for being too Nanny State. She was admonished for playing football in the (empty) chamber with three other female MPs (one being our new gambling Minister Stephanie Peacock MP ) as a stunt for the Parliamentary women’s football team.[i] Tracey Crouch ensured that FOBTs were effectively abolished although no evidence could be found to support such a move apart from opinion polls. As for being the son of a toolmaker, his father actually ran a factory making tools and it would appear it was an achingly middle class upbringing thus little evidence of a cultural affiliation with gambling.

 

A slight glimmer of hope is his wife, Lady Victoria, a solicitor turned occupational health worker for the NHS. She has been seen on numerous times attending corporate hospitality at racecourses. The rumours are that she is a big fan of a day at the races and has even bonded with our current Queen over this. She even took him to the St. Leger, which considering he had just returned from the White House was rather a coup for the Doncaster course even though he received some boos from pensioners so hard up they were at a racecourse trying to keep warm.[ii]

 

The fly in the ointment is that both are vegetarians and therefore mentally weak and impressionable to woke influences. Anyone eating tofu out of choice cannot be trusted. I provide Keir’s changing views on various policies as evidence of this.

 

On a serious note though, there have been some conflicting reports about what Starmer-ism is all about. On the plus side, it is reported that he is about all delivery rather than ideology, an entirely technocratic approach.[iii] Hopefully, this means he will not be convinced by the ideological nutters of the anti-gambling lobby. Starmer is supposedly about re-connecting Labour with its working class roots, which hopefully means that he’s also supporter of working class recreation, but as stated, there is no evidence of this.

 

In 2016, Starmer wrote an essay for the Fabian collection Future Left, where he advocated a new approach to public service reform, based around long-term, horizontal, and decentralised structures.[iv] While this article, like the rest in the collection was focussing on Labour’s defeat under anti-gambling Ed Miliband MP, it understandably doesn’t mention racing or gambling but does make some worrying statements:

 

our public services will have increasingly become crisis services – dealing only with expensive end results, not preventing them occurring in the first place.[v]

 

This is obviously heartening to hear when you think about the current state of Britain’s public services but is troublesome when you relate this to the Public Health approach to gambling (PHAG). This puritanical ideology, like many of the extremist strategies found in Public Health, uses the claim that prevention is better than cure as leverage for all matter of overly authoritarian policy proposals.

 

Obviously the NHS is over stretched, on its knees and if we can get people to live healthier lives then this will reduce the pressure on it. No one really has an issue with educating the masses on the benefits of not smoking, reducing alcohol intake, and eating healthier. The issue is that all evidence shows that to make your population significantly healthier you either have to make them richer or have a war so you can ration things. There are also serious questions about Public Health prevention strategies, if they actually work, even saving money, as a population that lives longer costs the economy more in pensions and elderly care but also in healthcare as the most expensive form of healthcare is at the end of life and a healthier population drags this out excessively.[vi] Oddly enough for a fanatical ideology, it begins to fall apart when you look at the details.

 

PHAG academics obviously favour such an approach as it provides them with a never ending supply of research grants and salves their anti-gambling activism based on their Post-Modernist/Marxist views which got them into the Sociology department in the first place.

 

To enhance the chance of their Puritan ideals being implemented, the PHAG academics have moved the goal posts, switching the focus from the number of problem gamblers, which has been consistently falling, to a focus on the nebulous concept of gambling harms. This is a highly flawed methodology that considers feelings of regret as a harm and that low risk problem gamblers suffer similar harm to those who have had an arm amputated without amputation.[vii] By having ridiculously low thresholds for what is considered harm, which most normal folk would call irritations or consequences or even just choices, they can falsely claim that practically everyone is harmed by gambling.[viii] The way they see to preventing harm is to have a significant reduction in the amount of gambling which takes place and by significant, they basically want prohibition or gambling to be nationalised as has proven such a failure in the Scandics.

 

These fanatics dressed up as academics want behavioural change and an end to gambling. Some want this because they hold religious beliefs, some hold radical Marxist beliefs, all do it because they know it will be, and already is, a gravy train for the anti-gambling lobby where anyone who says gambling should be banned gets funded by the Gambling Commission (e.g. Gambling With Lies, The Association of Directors of Public Health).

 

The number one fear for the almost half of the British population that gamble is that the prevention is better than cure argument will be accepted by No.10 as the main optic for dealing with gambling. The recent announcement that they will be banning smoking in outside places, regardless of the devastation it could cause to the hospitality industry and the rather spurious numbers about how many lives it will actually save suggests that a preventative approach is well received in No.10. More proof of Starmer’s willingness to embrace a Nanny State, is the recent announcement that junk food advertising on TV will get a watershed and will be banned completely from social media next year. Such a move will do absolutely nothing to reduce the amount of obese children there are. But banning things is cheaper than providing low cost healthy food, teaching parents how to cook and providing sufficient well paid work and/or benefits so they don’t have to work three jobs just to pay the bills but can have some time to feed/teach/look after their children.

 

We can only hope that the Prime Minister has the common sense to understand that smoking does harm every person who inhales but that is because poisons are being ingested and that high levels of fat, sugar and salt mostly cause obesity. But, gambling plainly does not harm everyone as can be seen by the fact that less than 10,000 people are seeking some sort of treatment for a gambling problem and problem gambling rates are the lowest they have ever been and are some of the very lowest in the world. The myth of endemic gambling harm is spread by those who seek personal gain from the illusion, whether that be ideological or financial and usually both.

 

The challenge for the British gambling industry is to have a coherent message heard in No.10 that shows up the lies of PHAG and the regulator and promotes gambling for what it is, fun for the masses. To consistently agree with every new restriction and regulation in the name of ‘sustainability’ is to accept the ideological approach and give it credence.

 

[i] https://www.euronews.com/2018/11/21/house-of-commons-mps-told-off-after-playing-football-in-uk-parliament

[ii] https://x.com/marcuspolo1981/status/1835035049504194675?t=5c-NM4C3OnPhn1oz-IPv6g&s=08

[iii] https://www.newstatesman.com/cover-story/2024/05/what-is-starmerism?utm_source=substack&utm_medium=email

[iv] https://fabians.org.uk/wp-content/uploads/2024/06/Starmer-future-public-services-trimmed.pdf

[v] Ibid p.84

[vi] Letter from Dr Ron Zimmern to the Times, 16th September 2024

[vii] Browne, M., Goodwin, B.C., Rockloff, M.J. (2018). Validation of the Short Gambling Harm Screen (SGHS): A Tool for Assessment of Harms from Gambling. Journal of Gambling Studies 34(2), 13. Browne, M., Langham, E., Rawat, V., Greer, N., Li, E., Rose, J., Rockloff, M., Donaldson, P., Thorne, H., Goodwin, B., Bryden, G., Best, T. (2016). Assessing gambling-related harm in Victoria: a public health perspective. Melbourne, Australia: Victorian Responsible Gambling Foundation, Retrieved from https://responsiblegambling.vic.gov.au/resources/publications/assessing-gambling-related-harm-in-victoria-a-public-health-perspective-69/

[viii] https://x.com/GambleWithLives/status/1835577067553058981

Number 11 – Chancellor of the Exchequer Rachel Reeves MP

 

The Right Honourable Rachel Jane Reeves MP has been an MP since 2010 and has only once mentioned gambling in Parliament once and that was when using it as part of a phrase from George Orwell’s book 1984 to symbolise the Tory budget of that year.[i] What we know about our first female chancellor is that she is a big ‘girly swot’. From a comprehensive school in Lewisham where she got  4 A's (when this was difficult), she then studied at Oxford New College to get a 2:1 (which every Oxbridge alumni will tell you puts you on a similar intelligence level with Einstein) in PPE and then got a MSc in Economics from the LSE. From there to the Bank of England, then to HBOS and then into Parliament as MP for Leeds West.

 

While still at school she enhanced her nerd credentials by becoming a U14 British Chess Champion, joined the Labour Party and famously had a poster on her wall of Gordon Brown (surely reason for a Social Service intervention). As shadow and now proper Chancellor of the Exchequer it does appear she is trying to emulate the Labour Party’s longest serving Chancellor and famed ‘son of a manse’, the MP for Kirkcaldy and Cowdenbeath who scuttled Tony Blair’s plans for a resort casino.

 

From her dour demeanour, certainty that major economic structural changes are needed to reverse nearly two decades of incompetent Tory financial management, with less said about the impact of Covid-19 and the Ukraine War, she makes for a convincing  cos-play of the Iron Chancellor. I say cos-play because there are no signs so far with Reeves of Brown’s anger management issues and fear of rivals to his leadership that arguably led the Labour Party down the black hole of Miliband and Corbyn as leaders. Reeves is allegedly very amenable when not dealing with the enormous omnishambles that British economy has got itself into after a number of years of highly ineffective government.

 

To look at her views on politics we can look at the Mais Lecture she gave in March of this year (2024).[ii] She believes that government should be driven by three imperatives, which are a bit amorphous, as were Starmer’s Election campaign based on 5 mission statements. She proclaims that she will be driven by:

 

First, guaranteeing stability.

Second, stimulating investment through partnership with business;

And third, reform to unlock the contribution of working people and the untapped potential throughout our economy.[iii]

 

She sees the fundamental underlying problem with the British economy as being low productivity leading to wage stagnation which leads to low growth. She sees the answer in ‘Secureconomics’ where the state actively intervenes in markets to promote stability which will in turn spur innovation that will drive growth. This doesn’t mean a top-down centralist state but one which in partnership with business seeks to find solutions to the obstacles to growth. Reeves also believes in comparative advantage, so government will back winners rather than propping up losers.

 

This is potentially where both the online and the offline businesses show up their weaknesses in the eyes of His Majesty’s Treasury (HMT).  As the majority of the online industry is offshore, with the admirable exception of Bet 365 (see Let there be Stoke below), very few jobs or taxes can be credited to it. Many MPs still consider offshore to mean unregulated and un-taxed and therefore, indefensible  against regulatory and revenue raising attacks. The land-based industry obviously has far better credentials when it comes to jobs and taxes but again the taxes are not that much and the jobs are mostly low paid.

 

To give some insight on gambling taxes, for the financial year until end of March 2024, gambling taxes for all forms of gambling raised £2,766 Million.[iv] In comparison, Air Passenger Duty raised £3,884 Million for the same period. So, gambling taxes are not huge in the big scheme of things but still not to be sniffed at, especially in these times of a £22 Billion black hole and government finances far worse, according to Reeves, than was expected when she entered No.11.

 

If we remember back to 2018, when Tracey Crouch MP effectively abolished FOBT’s based on nothing more than opinion polls, HM Treasury demanded a year’s grace to maximise revenue, causing chief-Puritan Crouch to publicly resign. The Treasury decided to make up the shortfall by putting up Remote Gaming Duty (RGD) to 21%, in an unprecedented move to penalise members of a completely different sector.

 

We know that in November 2023, HMT stated they would consult on simplifying online gambling duty by combining the three different duties; remote gaming duty, general betting duty (GBD) and pool betting duty (PBD).[v] So far no consultation has happened, it may appear in October’s budget. The concept makes sense as it simplifies the tax system, but it also leaves open the space for a tax rise. With RGD at 21% and GBD and PBD at 15% it seems logical that a new online tax rate could be set at 21%. But equally, it could be higher. HMT stated many years ago that they thought gambling tax rates of 29% or higher would cause a black market. This implies that it could be 21% but equally could be 28%. Rachel Reeves needs money from wherever she can find it and if that means tapping an industry who has little political support, so be it.

 

My prediction is the consultation on the new tax will rear its head in the Budget and a new tax system in place for the new financial year in April 2025. Apart from that I cannot see Rachel Reeves going anywhere near gambling. It would take a concerted effort to show her how Bet365 saved Stoke and her to have a Damascene conversion to seeing how gambling can be used for economic regeneration and equally, it would need miraculous creativity from the industry to show her how it can happen.

 

While the new casino slots promised in the White Paper would undoubtedly generate more tax revenue, as I explain below cannot see there being a rush to change to law to allow it. This is because I don’t see it being a priority for DCMS although this may not be completely the case.

 

[i] https://publications.parliament.uk/pa/cm201314/cmhansrd/cm140325/debtext/140325-0002.htm#140325-0002.htm_spnew1

[ii] https://labour.org.uk/updates/press-releases/rachel-reeves-mais-lecture/

[iii] Ibid. Starmer’s 5 missions were 1) Kickstart economic growth 2) Make Britain a clean energy superpower

3) Take back our streets 4) Break down barriers to opportunity 5) Build an NHS fit for the future

https://labour.org.uk/change/mission-driven-government/

[iv] Office for National Statistics. (2024). Public sector current receipts: Appendix D. Office for National Statistics,. https://www.ons.gov.uk/economy/governmentpublicsectorandtaxes/publicsectorfinance/datasets/appendixdpublicsectorcurrentreceipts/current

[v] https://igamingbusiness.com/legal-compliance/legal/autumn-statement-unified-tax/

100 Parliament Street - Department for Culture, Media and Sport

 

Without any insider knowledge to back this up, my guess is that DCMS is rather fed up with gambling, the Gambling White Paper taking 871 days from launch to publication. While the majority of its recommendations were able to be implemented by new Licence Conditions and Codes of Practice from the Gambling Commission, a number need legislative change (primary and secondary legislation) to happen and this means Departmental involvement. By my maths, the following need changes to law:

 

  • the ability for the Commission to set fees without resorting to the Secretary of State to set them via a Statutory Instrument

  • legal powers for the Commission to ask for a court order to get ISP and financial blocking of black market sites

  • All lotteries and football pools to be 18 over and Category D machines that involve cash out to be over 18.

  • 1968 Act casinos to be allowed up to 80 slots if space available and pro rata if not

  • The machine to table ratio equalised at 5:1 for both Large and Small 2005 Act and larger 1968 Act casinos

  • Casinos to offer sports betting alongside other activities

  • The government will take steps to free up unused 2005 Act casino licences where there is no prospect of development for reallocation to other local authorities.

  • Casinos will be allowed to offer credit to non-UK punters

  • Exploration of the potential for regulating the largest competitions, such as those advertised on TV as they are currently unregulated

  • Trials of linked gaming machines in venues other than casinos, where prizes could accrue from machines linked in a community to be allowed with legislation forthcoming

  • Consideration to be given to licensed bingo premises being permitted to offer side-bets

  • Local authorities to be given the power to introduce a formal system of cumulative impact assessments (CIAs) for gambling, as there is for alcohol, which will inevitably reduce the number of new gambling venues

  • Increase in fees for local authority licensing of gambling venue[i]

 

This is taken directly from the White Paper and what is striking is both the language and the diversity of topics. Language as in there are definitive measures, such machine numbers for casinos and increased age limits for lotteries and Category D cash prize slots, and then the more opaque taking steps to free up unused 2005 Act casino licenses, exploring how to regulate large competitions and giving consideration to bingo halls offering side-bets. This suggests that some recommendations have conceptually been formed while some need further consultation. The broad range of changes proposed, to casinos, more powers to the Gambling Commission and Local Authorities, changes to bingo and slot arcades, suggest that one Gambling Act 2005 (Amendment) Bill could be possible but would be all over the place. Equally, small Bills focussing on different sectors would be more easy to politically swallow but takes far more time and effort.

 

And this is my big issue with DCMS, although the last gambling Minister stated that they planned to start the legislative process by the Summer just gone, where is the motivation to start the process? Firstly, no new government is beholden to the work of the previous government. Even though there is no reason to believe that Labour’s DCMS would want to do anything dramatically different to what is in the White Paper, there is equally no burning reason for them to plough on with the proposed changes at speed. DCMS has spent nearly 3 years dealing with gambling and so has the scars and may not want to rush into re-opening debates where they increase gambling (as many of the land-based proposals do) and so could receive anti-gambling opposition. Equally, the relatively simple statutory instrument  needed to impose a mandatory research, education and treatment levy could be delayed as the cottage industry of grifters squabble over which organisation doles out the money and who receives it. Surveillance should then be put on university sociology department and gambling harm charity car parks to see who are upgrading their Nissan Leaf’s to Mercedes EQC’s.

 

I also think one of the main factors for there being no rush for any new legislative change is down to DCMS personnel.

 

[i] Department for Culture Media & Sport. (2023a). High Stakes: Gambling Reform for the Digital Age. HMSO.

Secretary of State – Lisa Nandy MP

 

Rt. Hon. Lisa Eva Nandy was elected MP for Wigan in 2010 and has held that seat with a substantial majority ever since. She has been a rising star in the party and a question about her appointment as Secretary of State for DCMS is whether this is in fact a demotion. While in Opposition, Nandy had been Shadow Foreign Secretary, Shadow Levelling Up Secretary, Shadow Energy Secretary and Shadow International Development Minister and even stood for Party leadership in 2020, coming in third place with 16.3% of the vote, behind Keir Starmer and Rebecca Long-Bailey. Taking the helm of the government’s smallest and most inconsequential department cannot have been part of her career dreams unless she has a particular DCMS-related bugbear, which isn’t apparent as her focus has been on setting up the Centre for Towns, or she has been given the ‘Ministry of Fun’ as a fop for her soft-left leanings not mixing with the Starmer creed.

 

She is aware of racing and gambling as the Tote has its headquarters in her constituency, employing c.600 people. Her only statements in Parliament on betting/racing/gambling have all been Tote related. She appears to be a fan of sport, to what degree is unknown, based on her obvious interest when watching the Olympics (perk of being SoS at DCMS) and when I would see her watching football in one of the bars in Parliament. Without knowledge to the contrary, I would suggest that gambling and racing are of interest to her only as far as the Tote being an employer in her constituency. I am certain she would appreciate a day at the races but I suspect she would manage if she didn’t.

 

The issue is whether she wants to enter the gambling milieu. As stated above, it would be highly understandable if DCMS had had enough, or at least deserved a break. As the Labour Party’s manifesto has nothing discernible within it to keep DCMS busy and with no Bills currently tabled to bother them, the only thing that looks like eating up their time will be any reforms to the Online Safety Act voted through last year, which may need tweaking after social media was used to inspire rioting this summer. There is also the Football Governance Bill mentioned in the King’s Speech.[i] This is the only proposed piece of legislation out of forty Bills that DCMS has been chosen to lead on. Like the Tobacco and Vapes Bill, this is a hangover from the Sunak government and while both Bills have cross-party support, they feel like being not of the highest priority.

 

The real issue for Nandy, should she feel the need to grab the nettle and try and get some gambling legislation passed, will be finding time in the Parliamentary diary. She will be up against the 40 Bills in the King’s Speech. History shows us that new government’s don’t focus on gambling for at least a few years as they have other priorities with the more important parts of politics, like housing, health and defence. The Blair government came in in 1997, knowing that changes were needed to update the gambling laws. There would have to be a wait until 2001 before the Budd report became the effective White Paper and then the Draft Gambling Bill wasn’t until 2004 with the legislation passing in 2005. My prediction is that we won’t see any gambling related legislation seeing the light of day before 2026 at the earliest.

 

However, what may question this prediction is the fact, or at least the very appearance, that we have two new Ministers with responsibility for gambling.

 

[i] https://assets.publishing.service.gov.uk/media/6697f5c10808eaf43b50d18e/The_King_s_Speech_2024_background_briefing_notes.pdf

Parliamentary Under-Secretary of State (Minister for Sport, Media, Civil Society and Youth) - Stephanie Peacock MP

 

When my news feed told me that Stephanie Peacock MP had been appointed a Minister for Sport in the new DCMS, I automatically assumed that she was our new Minister with responsibility for gambling. Member of Parliament for Barnsley East (Michael Dugher’s old seat) in 2017 and has represented Barnsley South since 2024. Stephanie was Shadow Minister for Digital, Culture, Media and Sport, with responsibility for gambling, from 22nd July 2022 – 30th May 2024 and has participated in a number of roundtables to learn about gambling issues, namely she attended a dinner set up by the BHA for Parliamentarians and she has held her own meetings with stakeholders.

 

What we know about her views on gambling we can only gauge from her comments in Parliament. As the new gambling Minister she has already had to respond to written questions and given an understandably political yet still questionable answer:

 

The Government will consider the best available evidence from a wide range of sources, including the Gambling Commission’s Gambling Survey for Great Britain (GSGB), to inform decisions on how best to fulfil its manifesto commitment to reducing gambling-related harm.[i]

 

As will be discussed below, this is questionable as it does appear that the Gambling Commission’s new survey is not fit for purpose and so shouldn’t be a part of the policy process until the glaring flaws in its methodology are addressed.

 

As Opposition spokesperson she asked questions about whether prisoners received support for problem gambling, whether there would be an assessment of the effectiveness of research, prevention and treatment commissioning when the statutory gambling levy is in place, what the framework developed by the National Centre for Social Research for process and impact evaluations of the review of the Gambling Act 2005 will include and what was the amount of money that was returned to victims of gambling-related crimes.[ii] She also asked whether the government has made an assessment on the impact of the White Paper on illegal gambling, whether the results of the 2012 Gambling Commission consultation into affordability would be published and about the draft guidance on GPs asking patients presenting with a mental health issue about their potential gambling habits.[iii]I could go on, but it is unnecessary, these questions don’t suggest a vehemently anti-gambling stance but a mixture of doing her job and holding the government to account and fact-finding, as you would expect from someone preparing for their role as Minister.

 

In the Westminster Hall debate on the collapse of Football Index held in April 2024, she criticised both BetIndex and the Gambling Commission.[iv] In another Westminster Hall debate called by rabid anti-gambler, Ronnie Cowan MP on the unevidenced perils of gambling advertising and sport, she promoted the White Paper recommendation for an advertising code set by sport’s governing bodies.[v] She also appreciated the value to sport of advertising and sponsorship from gambling companies. Speaking in the Westminster Hall debate forced due to the Jockey Club petition to get affordability checks banned, she makes the statement:

 

I remember my nan going to bingo every week when I was growing up, and I have always enjoyed going to the races—I was pleased to attend the St Leger last year.[vi]

 

However, she is very supportive of the checks as a way of preventing gambling harm and correctly points out that the missing link is what operators should do if someone fails an affordability check. She goes on to ask the government to ensure that the checks are ‘accurate, frictionless and non-intrusive for consumers, as they have promised’ due to the massive potential cost to racing. She had previously asked a written question on how the government were planning to make affordability checks friction free.[vii] This echoes the comments she made in an October 2023 Westminster Hall debate on the future of racing, where she supported affordability checks to prevent gambling harms but demanded that they had to be ‘proportionate’, she also supported the review of the Levy.[viii]

 

What it appears is that we have as our gambling Minister is someone who it appears so far, has not drunk the anti-gambling Kool-Aid, is measured and understands the gambling brief and maybe, just maybe, likes a bit of racing and an occasional flutter.

 

It remains to be seen how long this remains the case as she will undoubtedly be given an indoctrination session by the Richie’s and their pretend charity but actual activist group, Gambling With Lies, maybe supported by an apparently anti-gambling civil service. We can only hope that unlike the previous post-holders she doesn’t get consumed by the tsunami of misinformation that the Forces of Darkness (see below) will be shovelling her way.

 

There is, however, some confusion with what is going on with DCMS. For as long as I can remember and I caveat this with saying that I am at an age now that I walk into a room and can’t remember why I went there, so I may be wrong, but the role of gambling Minister has always been the lowest rung of the Ministerial ladder, Minister of State, and Stephanie Peacock MP is the next rung up, Parliamentary Under-Secretary of State. This may be just an administrative issue, but the confusion is exacerbated by the appointment of Baroness Twycross as Minister for Gambling as well as DCMS Lords Minister. The terminology is confusing. Peacock’s page on the government website showing DCMS Ministers has her down as Minister for Sport, Media, Civil Society and Youth and gives as  one of her responsibilities:

 

Gambling (in the House of Commons)[ix]

 

Whereas for Baroness Twycross, her job title is Parliamentary Under-Secretary of State (Minister for Gambling and Lords Minister) and her responsibilities are listed as:

 

  • Gambling

  • DCMS business in the House of Lords[x]

 

In 30 years I have never seen the job of gambling Minister split between the Lords and Commons. Traditionally, there would be a gambling Minister in the Commons and the DCMS spokesperson in the Lords would field any gambling related questions. We know that Peacock is answering Written Questions as gambling Minister and Baroness Twycross is attending an anti-gambling fringe event held by the Derek Webb funded, James Noyes’s Social Market Foundation at Labour Party Conference, of which more later.[xi] So they are both sharing the brief, the question is why?

 

It would be logical to deduce that DCMS is expecting gambling related legislation and thus to ensure efficient passage through the upper House, where there are many armchair generals in the gambling war, having a dedicated gambling Minister fully on their brief would be most beneficial. This rather goes against my previous predictions of their being little gambling action by DCMS due to the packed Parliamentary timetable of the King’s Speech, but who knows?

 

With all to do with British politics, one must always consider the cock-up option, as this may just be a simple job share with Peacock wanting to offload some of the more contentious parts of her brief, unfortunately only time will tell.

 

[i] https://questions-statements.parliament.uk/written-questions/detail/2024-08-30/2706

[ii] https://questions-statements.parliament.uk/written-questions/detail/2024-05-21/27552 https://questions-statements.parliament.uk/written-questions/detail/2024-05-21/27555 https://questions-statements.parliament.uk/written-questions/detail/2024-05-21/27556

https://questions-statements.parliament.uk/written-questions/detail/2024-05-21/27554

[iii] https://questions-statements.parliament.uk/written-questions/detail/2023-12-12/6579

https://questions-statements.parliament.uk/written-questions/detail/2023-10-17/203093

https://questions-statements.parliament.uk/written-questions/detail/2023-10-17/203092

[iv] HC Deb, 24 April 2024, c319WH

[v] HC Deb, 13 March 2024, c136WH

[vi] HC Deb, 26 February 2024, c41WH

[vii] https://questions-statements.parliament.uk/written-questions/detail/2023-12-13/6868

[viii] HC Deb, 25 October 2023, c332WH

[ix] https://www.gov.uk/government/people/stephanie-peacock

[x] https://www.gov.uk/government/people/baroness-twycross

[xi] https://x.com/SMFthinktank/status/1833784278498382037

Parliamentary Under-Secretary of State (Minister for Gambling and Lords Minister) - Baroness Twycross

 

Fiona Ruth Twycross, Baroness Twycross was elevated to the peerage on the 7th November 2022. Her career prior to this is that of a Labour politician. She worked for the Labour Party as Regional Director in Yorkshire and the Humber and the North East, and was Agent for the Sedgefield by-election, in which Phil Wilson succeeded Tony Blair after Blair's resignation from parliament. She was elected as a Londonwide Assembly Member of the London Assembly in May 2012. Twycross became a member of the London Fire and Emergency Planning Authority (LFEPA) from 2012 until its abolition in 2018. She served as Labour Group Leader on the Authority from July 2013, and as Chair from 2016 until LFEPA's 2018 abolition and was then appointed as Sadiq Khan's Deputy Mayor for Fire and Resilience until joining the government in July 2024 as Baroness in Waiting (a junior government whip) and a week later as gambling Minister in the Lords.

 

Like Peacock she has already been answering written questions on gambling from the nutters. The Bishop of St Albans has asked if the government received any of the fine money so liberally imposed by the Gambling Commission, Twycross answered in the negative.[i] The Bishop also asked if Twycross would comment on the heavily flawed survey published by the Commission which suggested problem gambling numbers were 8x higher than previously thought, Twycross rightly responded:

 

The Gambling Commission’s formal guidance is clear about the inaccuracies of comparing the findings of the recent statistics released in the Gambling Survey for Great Britain with previous surveys.[ii]

 

The only other legislative chamber with religious appointees there by right of their religious rank is found in Iran. I sometimes question if the Bishop of St. Albans may be doing the work of their morality police as part of an international exchange programme?

 

Long term anti-gambler and most in need of a razor, Lord Foster of Bath, asked if the government had plans to reduce the amount of gambling related advertising and sponsorship of sport – a current leitmotif of the anti-gambling lobby. Twycross gives an informative non-answer:

 

We are in the early stages of the new Government and are still considering the full range of gambling policy. However, the Government recognises the impact harmful gambling can have on individuals and their families and, as stated in its manifesto, the Government is committed to strengthening the protections for those at risk. We will consider the best available evidence from a wide range of sources to inform decisions on how best to fulfil its manifesto commitment to reducing gambling-related harm.[iii]

 

This I think sums up the DCMS position. They are considering gambling policy in the round and, hopefully, listening to all sides of the debate. There is nothing about Baroness Twycross, an uber apparatchik, to suggest she has is a fan of gambling or has ever even gambled. But as such an apparatchik she will be certain to not go off-piste from government policy. The question is who is deciding it and how heavily influenced will it be by the Forces of Darkness (see below).

 

[i] https://questions-statements.parliament.uk/written-questions/detail/2024-07-25/HL359

[ii] https://questions-statements.parliament.uk/written-questions/detail/2024-07-30/HL532

[iii]https://questions-statements.parliament.uk/written-questions/detail/2024-07-30/HL500

Houses of Parliament

 

The new Parliament after the General Election saw a record 335 new MPs take their seats, the largest number in modern history.[i] Such was the political ‘sea change’ that the House of Commons is now obviously far more Labour and Lib Dem than it has been for over a generation. It is also a bit younger, with the average of MPs elected in 2024 being 48 compared to 50 for the period 1979-2019 and a lot more female, 263 female MPs elected compared to 220 in 2019.[ii]

 

What do these demographic changes mean? Apart from making some very broadbrush generalisations it is difficult to say. As a very unsophisticated rule of thumb; younger, more female and more on the Left does not usually mean supporting gambling, why is discussed below, but at a very ‘helicopter’ level of analysis, these MPs are probably more likely to consider racing from an animal welfare perspective and gambling from an addiction one than being fans of the Sport of Kings and the lovers of risk.

 

Even though the 2024 intake shows the biggest increase in the proportion of MPs who went to a comprehensive, with the lowest number of MPs being privately educated in over 50 years, the number with a university degree is over 4x the national average at 90%.[iii] Supporters of working class culture they are probably not. But equally, they are fresh-faced and impressionable, the opportunity is there for new MPs, especially in racecourse constituencies (see below) to be educated in how much racing and gambling benefits the nation both culturally and economically. Again the issue is whether the Forces of Darkness, which seem far more keen to do actual political lobbying, get to them first.

 

[i] https://www.theguardian.com/politics/article/2024/jul/09/record-335-new-mps-to-be-inducted-into-house-of-commons-this-week

[ii] https://commonslibrary.parliament.uk/2024-general-election-how-many-women-were-elected/

[iii] https://www.suttontrust.com/our-research/parliamentary-privilege-2024/

Culture, Media & Sport Select Committee

 

Where backbench MPs get a chance of doing something useful, rather than just being ‘lobby fodder’ is by getting themselves elected on to a Select Committee. Select Committees are Committees of the House of Commons, whose job is to shadow the work of government and hold it accountable. Each government department has its own Select Committee, whose membership, in terms of Chair and numbers of members, reflect the make-up of the House (so more Labour MPs) and membership is elected by MPs of each of the main parties to fill these posts.

 

Of interest to us is the Culture, Media & Sport Committee as this is the one that covers DCMS and therefore gambling. MPs recently re-elected, unopposed as its Chair, the Tory, Dame Caroline Dinenage MP. Its membership is still to be elected. Under the recent Conservative government, its membership was 5 Tory MPs, 4 Labour and one SNP, this may end up in this new Parliament as 5 Labour, 3 Tories and 2 Lib Dems but equally it could be 5 Labour, 4 Tories and 1 Lib Dem, it just depends on the success of Lib Dem lobbying.

 

In December 2023, the Culture, Media & Sport Committee published its report on Gambling regulation.[i] This had the following recommendations to which I have added the response of the government in their April 2024 report, Gambling regulation: Government Response to the Committee’s Second Report.[ii]:

 

  • The government must set out a detailed timetable for the legislation due to the White Paper – it will do!

  • Consultation on changes made in the White Paper must have wide ranging consultation – it is in the process of doing so

  • Gambling Commission (GCUK) to address growth in black market and set out how it plans to monitor this – The Criminal Justice Bill includes giving UKGC more powers to disrupt block illegal sites

  • With affordability, GCUK must determine customers’ willingness to be subject to the checks, and whether they apply at suitable thresholds – this is why the UKGC is currently undertaking a pilot study

  • DCMS and UKGC must set out progress of single customer view – GamProtect (now launched) has been trialled since 2023

  • DCMS to consider having POS information about gambling risks – gambling harm is too complex to provide a robust model for measuring gambling harms comparatively

  • Stake limits on online slots to be no more than £5 – limit has been set at £5 for over 24 and £2 for 18-24 year olds

  • Operators should convince players to use player management tools and impose them if evidence of harm – consultation taken by UKGC and at time of the government response had not published results

  • DCMS to review banning U18 access to social casinos – DCMS has previously published on Loot Boxes where the video gaming industry has agreed to strengthen age rules, but if it doesn’t pay out its not gambling

  • DCMS to commission independent longitudinal research on the link between gambling advertising and the risk of gambling harm, including specifically for women and children – this will happen when the mandatory levy comes in

  • DCMS, UKGC and sports’ governing bodies to work on reducing the amount of gambling advertising and sponsorship in stadia and increase the amount of in-stadia safer gambling messaging - the cross-sport gambling sponsorship Code of Conduct was agreed in March 2024

  • With the proposed introduction of cashless payments in land-based gaming, customers must be allowed a cash only option – consultation response to be published shortly (it was on 16/05/2024).[iii]

  • With the proposed additional casino slots, DCMS and UKGC must consider with the increased availability of Category B gaming machines in high street venues, the risk of gambling harm – UKGC will monitor

  • DCMS must ensure councils are given guidance on how Cumulative Impact Assessments can be applied to gambling premises – UKGC will so in guidance note to local authorities

  • Supports a mandatory Levy for research, prevention and treatment, but the new system must minimize disruption for existing providers, impose a new national strategy for minimising gambling harm and have measurable targets. – In August 2023, the Gambling Commission approved the transfer of around £32 million in regulatory settlement funds to GambleAware for the creation of a system stabilisation fund.

  • When it comes to UKGC research:

    • It is vital that any such research is accurate, representative, and understood – agreed!

    • Studies similar to the Patterns of Play research could be conducted on a regular basis – UKGC will take an incremental approach as Patterns of Play was a one off

    • UKGC should publish clear guidance about the interpretation of official gambling statistics – UKGC doing this with Gambling Survey for Great Britain (more on this later)

  • DCMS and UKGC to continue to develop understanding of the relationship between gambling and suicide – UKGC working with the Department for Health and Social Care and has commissioned research

  • There should be a gambling ombudsman who would adjudicate on all disputes between gambling operators and their customers, replacing the existing gambling ADR providers – needs the industry to deliver a credible scheme

 

While on first glance it does seem that the CMS Select Committee had swallowed rather a lot of the anti-gambling Kool-Aid, there were a few glimmers of light and comments worthy of note

 

  • Tim Miller, Director, UKGC: The quarterly telephone survey that had produced the world beating low problem gambling numbers was only used for tracking purposes and suffered from a small (1,000) sample size. What had been considered the ‘gold standard’ were the NHS health surveys which suffered from taking years for the data to get through, being run by the NHS and having different methodologies in England, Scotland and Wales. This was the reasoning behind the Great British Gambling Survey (GBGS) being commissioned. – or the UKGC wanting its primary data to show what it wants (see below)?

  • Andrew Rhodes, CEO, UKGC: “Nine out of 10 of the largest penalties and 85% of all the activity in the world in gambling regulation comes from UKGC…. The other thing that the industry says itself—and this is from many of the people I talk to, as well as I think the trade body—is that the industry has not done itself any favours in recent years with some of the cases that we have seen. In all of the examples—I am talking about the penalties—the operators have accepted that there were breaches and there were failings and have agreed that they needed to be put right…People will argue about why was it not right in the first place, and that is a very justifiable question. But we are seeing success in this area undoubtedly. I think that is what we need to continue to press on” – if a class at school persistently fails its exams then at some point they look at the teacher?

  • Andrew Rhodes, Director, UKGC: “I have said in public a number of times that I think the risk [of people moving to the black market] is over-stated, but I do not think there is no risk… However, every time I have heard someone say to me, “Based on what is happening here, people are going to the black market”, I have asked them same question, “Tell me where”. I have not once had an answer. I have not once been given the name of an operator or a person or a location or anything I can act upon, and I have consistently asked that question every time.” – equally, just because you can’t see gravity, it probably doesn’t exist?

  • Andrew Rhodes, CEO, UKGC: “there are a number of operators who already have checks in place on basic financial risk who turn away customers because of their level of financial risk, and this already happens and is a commercial decision that they have made” – or possibly the result of an regulatory agreement enforced by the UKGC?

  • Tim Miller, Director, UKGC: “[regarding Affordability checks] that is no different to what we have expected them to do for a very long period of time. The difference is that the industry themselves were saying to us, “We want to ensure that we are all acting with consistency. We want you to give us a clearer steer as to at what level should some of these checks kick in”, and that is exactly what this work is doing. The White Paper set out a very clear policy around bringing in these checks, and what we are consulting on is how you bring those into practice.” – this rather ignores the fact that Affordability was imposed by the UKGC in 2019 and the variety of ways it was done so by the industry was that was how the UKGC wrote the regulations.

  • Andrew Rhodes, CEO, UKGC: “What we are talking about with the horse racing industry is the same as we are talking about with anything else, but the horse racing industry does have some different factors around it. We are talking about 3% of accounts requiring an enhanced check. That is very similar to the level of gambling risk that we are concerned about. Horse racing gets 70% of its income from 1% of accounts, which is why it will have a natural concern about this. In terms of an assessment of the overall impacts of the White Paper, that would be for the Department because it is the Department’s White Paper, not the Gambling Commission’s, and that was published. I don’t know if you have any further information on that – bizarre considering all the recommendations of the UKGC were adopted in the White Paper and it would be UKGC providing DCMS with all the data for any impact assessments, so to not know anything sounds disingenuous

  • Andrew Rhodes, CEO, UKGC: [responding to the statement that there is no evidence of causality between advertising and problem gambling] “One is public acceptability and whether people like it or not. When I meet people, people I haven’t seen for a while and we talk about where I work, they will inevitably want to complain to me about the level of gambling advertising, although that is not actually in our remit. It is something that is not particularly popular in society. I think that is different to, as you make out, that causal link. Our advice was based on the available evidence. The White Paper is a rare opportunity to explore this issue and we were clear. We felt there should be some reductions in this space. Is it held to a different standard to other things? I think that in the end is a political decision as to what people want to do with it. You will sometimes struggle to have a truly definitive evidence base because these are complicated things.  – this highlights the use of public opinion as an excuse for gambling restriction. Public Opinion is very often biased due to the way questions are asked and the lack of knowledge on the topic of respondents.

  • Andrew Rhodes, CEO, UKGC: [on the accusation that industry won’t give access to their data for research] “There will always be an argument about the data and access to it. I think some in the industry fear the data will be used by people who have made their minds up, so they are very cautious about the use of data. Others feel they cannot get access to the data so the industry must be hiding something. That is where I think having an independent research council and the right standards around it will help encourage more research, truly independent research, as you say, into the area of gambling. I think that can only be a good thing, and at worst it will tell us that some questions are difficult to answer or cannot be answered. That would be a step forward in itself.” – the bias of research is clear for all to see, the industry needs to be commissioning its own using methods of funding that preclude influence.

  • Stuart Andrew MP, gambling Minister, DCMS: [asked whether gambling was more alcohol than tobacco] Yes, I think so, but I would also say that this needs a bespoke approach because there is a tremendous amount of research into the effects of alcohol and of tobacco. There is probably less research in gambling so it does need a slightly different approach. In itself, alcohol is not something that can be instantly harmful, it is over a period of time, so, on that level, perhaps yes, but the potential to enter gambling harm could happen a lot quicker than with alcohol. Do you see what I mean? There are some distinctions and that is why I would say that it needs a slightly different approach than just thinking about an alcohol approach.- this does suggest that it’s more like tobacco?

  • Stuart Andrew MP, gambling Minister, DCMS: [when questioned about the number of gambling related suicides] “I do not think that we as a Government have actual, definitive information that would say that X number of suicides are a result of gambling harm. In some cases that will have been a cause but there will be potentially other reasons as well.” – good to see that the government isn’t swallowing the laughably piss-poor research by the OHID on this topic.

  • Ben Dean, Director, Sport and Gambling, DCMS: [when asked about what the government’s strategy was regarding gambling harm] “With gambling it is about that balance that the Minister talked about. Forty per cent of the population gamble every month and the vast majority of them do so safely and happily and we have to recognise that it is their money to spend how they see fit. However, what we want to focus in on is that 1%, roughly, of the population who are problem gamblers and those who are at risk of harm. That roughly 1% has been pretty stable over 20 years and this White Paper is about trying to do all we can to reduce the impact on those at risk and those suffering gambling harms.” – this goes further to suggest that DCMS doesn’t believe the PHAG mantra that gambling harms everyone

  • Ben Dean, Director, Sport and Gambling, DCMS: [when asked if the UKGC’s lived experience panel should include normal gamblers] “I do not want to speak on their behalf, but I know that one of the things that it has heard and that it is considering is that it has seen the value of having that lived-experiences group but it also recognises that there is a body of people who, as you say, are normal gamblers, normal people who have been engaged in the industry. They may not be industry representatives but they come from that side of the debate as well. It is something that it is looking at about how it engages that side and whether there is more that it should be doing to make sure that it is hearing a balanced view from both sides of the argument. – this is positive as so far the debate is heavily biased towards the tiny proportion who suffer harm

  • Ben Dean, Director, Sport and Gambling, DCMS: [when asked by Kevin Brennan MP why no impact assessment had been undertaken for the White Paper] “Hold on. One of the main criticisms that we have had is being able to move on to make actual impact on the ground. We did not want to hold up further the White Paper by having a detailed impact assessment when what people want is us taking the White Paper out and having an impact on the ground, which is the main criticism that—” – only a cynic would suggest that the reason no impact assessment was published was that it would show that affordability would lead to a massive growth in the black market (BTW I am a massive cynic)

  • Stuart Andrew MP, gambling Minister, DCMS: [when asked about racing’s concerns about Affordability] “that is why, yes, we are bringing in these checks but we want them to be frictionless and that standard approach throughout. At the same time we have launched the review into the horserace betting levy. We have had representations from both the British Horseracing Association and from the Betting & Gaming Council. We have encouraged them to come together. There have been some recommendations made by BHA that we are currently considering but we have also said to the two to get together and come up with some proposals. We even extended the deadline to allow that to happen because I am keen that we take this opportunity to try to plug the gaps where we can and ensure that we secure a good future for horseracing in this country. There is a lot that we can be very proud of with the horseracing industry in terms of its reputation around the world and we are keen for that to happen. However, we are using this as an opportunity to do the two hand in glove as it were.”

 

This does suggest that DCMS was rather lumbered with the recommendations made by UKGC for the White Paper. They obviously couldn’t reject wholesale the recommendations and could see the easy win in limits for online slots, there being no particular pushback from the industry as by far the majority play at under the £5 stake limit. It does appear that racing’s lobby had done its best and may well have been the reason for the alleged delay in publishing the White Paper, according to Kevin Brennan MP (retired at GE2024). This left them with the hot potato that is Affordability and the disastrous impact will have on racing. DCMS’s cop out is to argue for an increase in Levy to fill the predicted massive hole in racing’s finances. Where this fails as a solution is that if you force the big punters in racing to the black market, you lose the liquidity from the betting markets, reduce the Levy and so reduce prize money and for those not wishing to go illegal, force many owners out of racing and thus diminish the supply chain further.

 

Unfortunately, the pilot study on Affordability that is going on now is not about enhanced financial checks that will kill the horseracing market, it’s about seeing if data can be used and shared legally. Tying robust punters up in knots over declaring their wealth is still months off. That is why political pressure has to be kept up and the opportunity of a new government considering its approach with gambling needs to be exploited so that disaster can be avoided. The best place to do this, to my mind, would include at least, the informal racing lobby in Parliament.

 

[i] https://committees.parliament.uk/publications/42630/documents/211944/default/

[ii] https://committees.parliament.uk/publications/44296/documents/220160/default/

[iii] https://www.gov.uk/government/consultations/measures-relating-to-the-land-based-gambling-sector/outcome/government-response-to-measures-relating-to-the-land-based-gambling-sector

House of Commons Racing Lobby

 

Probably the most influential within Parliament is the unofficial lobby of MPs representing the constituencies of Britain’s 59 racecourses. History has shown that if racing can be bothered to lobby them and highlight that a government policy will impact on the Horserace Betting Levy (which funds prize money) then political pressure would be exerted. For the last 14 years this has meant mostly Tory backbenchers, and some notable front benchers, having conversations with Ministers which usually meant policies were delayed (e.g. FOBTs) and possibly shelved (but we have no evidence of that).

 

The big change the General Election made is the understandable change in the make-up of racecourse MPs. Using research undertaken in March 2023 and comparing it to September 2024, the most obvious change is the Party allegiance of the racecourse MPs. Prior to the election, 69.5% of racecourse MPs were Tory, 16.9% Labour, SNP 5.1% and the Lib Dems, Alba and an independent each had one MP or 1.7%. Such was the annihilation of the Conservative Party that mix is now: 37.3% Labour, 35.6% Tory, 22% Lib Dem and one MP each for Reform, SNP and Green or 1.7% each.

 

Considering at the General Election the number of Conservative seats dropped from 344 to 121 (-65.8%), the number of Labour seats rose from 205 to 411 (+100.4%)  and the number of Lib Dem seats rose from 15 to 72 (+380%) such a realignment in racecourse MPs is very logical.

 

What is of concern is that the number of ‘progressive alliance’ seats in racing constituencies, the combination of Labour, Lib Dems, Greens, SNP and Alba has increased from 15 to 36 (+140%) or 61% of racecourse MPs. My definition of the ‘progressive alliance’ is political parties to the left of centre who indulge supporters who are against horseracing and gambling for welfare purposes, their ideology outstripping the evidential need for the restriction/prohibitions they campaign for. If I were the Daily Express I may go so far as to call them the ‘woke brigade’. This is not to say that a MP being a member of the progressive alliance automatically means they are against racing and gambling, but, I would suggest, it increases their chances significantly.

 

A similar fear is that of the gender breakdown, whereas prior to the election 71.2% of racecourse MPs were male versus 28.8% female, after the election this has changed to 64.4% versus 35.6% reflecting an increase in the number of female racecourse MPs from 17 to 21 (23.5%). This reflects the overall increase in the number of female MPs from 220 in 2019 to 263 (+19.5%).[i]

 

Normally, we should celebrate any increase in the number of female MPs in the hope of having a Parliamentary chamber that more reflects the population at large. But I would go so far as to say that when it comes to racing and gambling this is not the case. Let me explain:

 

When considering their motivations for becoming an MP, a rough guide is to consider a spider graph that has three axes: public service, personal gain and political activism. Obviously, no MP is going to be self-aware or politically inept enough to complete such a task honestly so we are just left to my anecdotal experience of working with a variety of MPs for over 30 years, so highly unscientific and incredibly generalising, but in my experience, female MPs are far more motivated by activism than male MPs.

 

I should state that in my personal life which involves horseracing and incompetently betting thereon, the majority of my racing buddies are female. Throughout my career in the gambling industry, I have come across numerous women involved in horseracing and betting/gambling who have unparalled passion and knowledge of the sport/industry. I would never suggest that being female automatically means that you are against racing and/or betting/gambling.

 

If only the same were true for when it came to female MPs. As a general rule, they are definitely against gambling, don’t like betting and many hate horseracing – again for misplaced ideas about welfare, both human and animal. There are notable exceptions such as Helen Grant MP, the only non-gambling hating female DCMS Minister during my career and hopefully the current incumbent, but as a rule, if we look at Parliamentary debates and speeches made by DCMS Ministers, for these women, the only optics they have about horseracing and gambling is a misplaced belief in welfare.

 

A look at the speeches of DCMS Secretaries of State; Maria Miller MP, Karen Bradley MP, Nicky Morgan MP, Nadine Dorries MP, Michelle Donelan MP and Lucy Frazer MP and Ministers with responsibility for gambling Tracey Crouch MP and Mims Davies MP will show not a single word of positivity for racing and gambling except for the usual platitudes when attending a conference hosted by them.  The scary bit is that these are all Conservatives, who traditionally (admittedly there hasn’t been a traditional Tory government since definitely 2016) have been supporters of racing and betting. There is an argument that Fixed Odds Betting Terminals radicalised them.

 

If there are any female supporters, going by the debate in Westminster Hall on Affordability that the Jockey Club’s online petition forced, what they support is corporate hospitality at racecourses, not the muckiness of betting/gambling that funds the sport and definitely not the concept that working class people may actually get a lot of enjoyment from the activity. Not fans of a betting shop, but take them to bingo and they love the sisterhood. Gambling politics is gendered I’m afraid.

 

Then we add progressive politics into the mix and it gets more worrying. Progressive alliance female MPs (Labour, Lib Dem and Green) number 18 seats or 85% of all female racecourse MPs and 30.5% of all racecourse MPs. We can’t be certain of how much the fact they have a racecourse in their constituency providing jobs and generating income from its spectators will be a priority over their personal beliefs about welfare.

 

As a caveat, I should reiterate that I’m not suggesting that every MP of the progressive alliance or every female MP or every female MP of a progressive alliance party is against horseracing and gambling in general, I’m just suggesting that they probably are more likely to than not. Just remember that Ian Duncan Smith MP and Chris Philp MP, both male Conservative MPs are rabid anti-gamblers. The mood music against gambling is playing throughout Parliament and has been for a few years (just read my articles passim) so those Parliamentarians who are most impressionable will likely find us (racing/betting/gambling) a cause to campaign against.

 

This is also another danger as probably the biggest change in the make-up of the racecourse MPs is the number who were only elected in 2024 which includes two retread MPs:  Anna Turley MP for Redcar and The Rt Hon Mr Douglas Alexander MP for Musselburgh. 31 of the 59 racecourse MPs (52.5%) were newly elected in 2024, 29 for the first time (49%). This means that a significant proportion have no knowledge of the political issues regarding racing and gambling and probably little understanding of the symbiosis between the two industries or the supply chains involved.

 

Who will educate them? Who will show them the way when, as discussed below, we have groups active in and out of Parliament actively spreading misinformation about our industries. This needs racing and gambling to get on the front foot. Whether this will happen is a question considered in the conclusion.

 

A possible opportunity is to focus on the Right Honourables, these are MPs who have been admitted to the elevated ranks of the Privy Council due to their appointment to Cabinet. There are 9 such Tory racecourse MPs, including one current leader (Rishi Sunak MP) and two, at the time of writing, leadership contenders, Kemi Badenoch MP and Robert Jenrick MP. Why these previous Ministers may be useful is because now they are in opposition, to be frank, they have far less to do and can take up a cause like racing and betting and put their remaining political clout (people have at least heard of them!) behind it. As stated elsewhere, gambling isn’t on the government’s agenda for the next few years so to some political heavyweights campaigning for us may prove useful to at least try to change the narrative.

 

[i] https://commonslibrary.parliament.uk/research-briefings/sn06652/

Let there be Stoke

 

Unknown to many, is the mini-gambling lobby of the three Stoke-on-Trent MPs (Central, North and South). When these seats were Tory they were very vocal in their support for the gambling industry. Undoubtedly due to the munificence of Coates family, whose stellar success with Bet365 has allowed them to plough their millions into Stoke-on-Trent. It’s very possible that without the Coates’s good works that this city would be a post-industrial wasteland as its traditional industry of ceramics have dwindled to almost just a pottery show on Channel 4. Having the world’s biggest online sportsbook located there has meant thousands of well-paid IT jobs. The question is will the three newly elected Labour MPs be prepared to campaign on behalf of one of their constituencies’ biggest employers?

 

Another pertinent question is whether the Betting & Gaming Council will be bothered to support them? One infamous debate in the House saw Stoke MPs supporting the gambling industry and doing so from Bet365 briefing notes – not from the more obvious BGC? Why was so, has never been revealed. One industry wag suggested it was because Dugher was still at lunch!

Is there support in the Lords?

 

It used to be the case that racing and betting had strong support in the House of Lords and to some extent so did casinos. For racing, this was due, in part, to the history of the landed aristocracy owning racehorses and racecourses and also because many in the upper House are high net worth individuals and horseracing is a sport that attracts the wealthy. Equally, many in the Lords, have kept in touch with their working class roots and like to bet on horses, dogs and even politics. Support for casinos was due mainly from the sterling work of the no more Ritz Casino, who would wine and dine many a Peer and MP.

 

Unfortunately time has taken its inevitable toll in the Lords. If we take some of the most vocal supporters of racing and gambling in the  upper chamber, the peers who were part of the Joint Committee of the Houses of Lords and Commons that was brought together in 2003/04 to consider the draft Gambling Bill, we see that with Starmer’s plans to bring in mandatory retirement at 80, many will have soon vacated the red benches, if not earlier. Going through them: Lord Brooke of Sutton Mandeville unfortunately died last year (2023), Lord Donoughue has just turned 90, Viscount Falkland retired last year, Lord Faulkner of Worcester is a spritely 78, Baroness Golding is 91, Lord Mancroft is the relative baby of the group at 67, Lord Wade of Chorlton passed away in 2016 and Lord Walpole also passed in 2021. Other racing and gambling supporting peers are Lord Lipsey who is 76, Viscount Astor is 72 and Lord Grantchester is 73. This gives our gambling supporting peers, those who remain alive and active an average age of 78.1 years.

 

If we compare these ages to the members of Peers for Gambling Reform; Lord Foster of Bath is 77, Lord Filkin is 80, Baroness Armstrong of Hill Top is 78, Lord Butler of Brockwell is 86, Baroness Bakewell of Hardington Mandeville is 75, Lord Trevethin and Oaksey is just 64, Lord Watts is 73, Lord Layard is 90 and Lord Bishop of St Albans is 67. This gives our gambling hating peers an average age of 76.6 years. Gambling haters are just a tad younger and if Starmer does instruct an age limit of 80, they still have more numbers. The only thing we can look forward to is the retirement of the Lord Bishop of St Albans, the peerage is fixed to the job, so he will be no longer one of the biggest puritans in Westminster.

 

The legislation to remove the remaining hereditary peers got its first reading at the time of writing and is expected to sail through the Commons, what happens in the Lords is still unclear. It’s a manifesto commitment so the Lords cannot block just delay but one Lord spoken to thinks it will all be over by next summer. The removal of heredity peers will see Lord Mancroft, Lord Grantchester, Viscount Astor and Lord Trevethin and Oaksey removed. Which unfortunately again favours the anti-gamblers.

 

What will be of interest politically is the interplay between the Brownite (supporters of Gordon Brown) gang of three. Michael Dugher, Chair of the BGC, and shadow secretary of state for DCMS for 3 months in 2015/16 is rumoured to be waiting on a peerage. Considering that his pal Lord Tom Watson got one eventually even after taking donations from Derek Webb/ruining the lives of a number of politicians for supporting the ravings of a lunatic falsely claiming there was a paedophile ring in Parliament, the fact that he hasn’t been elevated after leaving Parliament in 2017 leads one to conclude it may never happen. If it did then he could meet with his pal John Spellar, who has just been ennobled and while the now Baron Spellar served as a vice-chair on the now defunct Parliamentary All Party Betting  & Gaming Group, the suspicion was that he was there as a spy for his mate Dugher rather than a strong supporter of racing and betting. We can only hope that Dugher’ s parliamentary pass will allow him to keep Spellar on side at least to counter the influence of Watson.

All Party Groups

 

Another form of Parliamentary policy actor are the Parliamentary All Party Groups (APGs) which are informal groups of MPs and Peers from all parties who are interested in a  particular country or topic. They have no formal powers but have varying levels of influence due to the size of their membership and their ability to act, should they so wish, as a concerted lobby. They are also a point of contention due to the possibility of outside influence.

 

I will be the first to say that the only pro-gambling APG, the All Party Betting & Gaming Group, of which I was unpaid Secretariat from 2007-2023, was brought down due to the folly of its Chairman, Scott Benton MP. He made the mistake of  offering undercover reporters pretending to be gambling operators access to the un-published White Paper and all sort of political access, which upon investigation was found that Scott could not actually provide. This was not a debacle due to outside access though, it was a symptom of Benton’s inexperience, fear of being unemployed after the election and so need in remuneration and possibly some self-importance thrown in as well. It was a case of individual foolishness for which he was rightly punished. Now defunct, the All Party Betting & Gaming Group was robust in ensuring it independence, not taking funding from anyone – it did take money to pay for events, but there was never any willingness to accept money for influence and I have to say, none (to my knowledge) was ever offered.

 

Whether the same can be said of the anti-gambling lobby is another question. The All Party Group on FOBTs which later became the All Party Group on Gambling Harms, has had as its Secretariat, a lobbying firm, Interel, which states that it was funded by the Campaign for Fairer Gambling, which in turn is funded by Derek Webb. This in itself is not against the rules, however, there is also a completely unsubstantiated rumour that the Labour Party’s own Mrs Brown’s Boys look-a-alike, Carolyn Harris MP, Co-Chair of the APG, received a paid member of staff from a similar source which has never been declared, which would be completely against the rules. But I stress, there is no evidence of this and it is simply a rumour.

 

While the All Party Group on Betting and Gaming had a battle on with the Betting and Gaming Council, as they couldn’t understand the need for independence and wanted their own play thing, the anti-gambling lobby got exactly what they wanted in the All Party Group on Gambling Harms, a group of MPs willing to drink the anti-gambling Kool-Aid and parrot their demands and spread their misinformation throughout Parliament. They held a number of faux select-committee hearing where they invited various stakeholders to give evidence. In analysis I did for my PhD, I found that these witnesses were mostly vehemently anti-gambling, never had their assertions however extreme challenged and when someone did make statements based on evidence, it was ignored.

 

The proof that All Party Groups can have influence is in a comparison between the demands of the APG on Gambling Harms for the White Paper, the subsequent submission by the Gambling Commission for the White Paper and what was in the White Paper – almost identical.

 

So what does this mean for the future? Currently, at the time of writing, no gambling related APGs have been formed yet. After a General Election, all Groups have to be formed from new and have their Officers elected. There has been very little actual Parliamentary time since GE2024 so this not having happened is par for the course. Over the next few weeks, after party conference season we will see new groups being formed.

 

First out of the stalls is the All Party Group for Racing and Bloodstock, which is supposedly being set up under the Chair of Dan Carden MP. Whether a new version of the Betting and Gaming Group happens waits to be seen. The BGC have an opportunity to set up their own plaything, the question is whether they can find 20 Parliamentarians willing to sign up to what is still, after FOBTs, considered a toxic topic by many.

 

Considering its funding and the fanaticism of its officers, we can be certain that the APG on Gambling Harms will return. The question is whether it will come back as an APG given that its sister group, Peers for Gambling Reform (both funded by Direct Webb) is a ‘an informal group of Peers with a common interest in particular issues’ and thus not subject to same rules and financial transparency that an APG is.[i] It also means that the unelected nutters can start off the new Parliament with a loon-fest (or the usual suspects) who think that even though there is no evidence to back up their argument, that gambling advertising and especially sponsorship and advertising at football stadia should be banned.[ii]

 

Their logic remains the farcical argument used by the House of Lords Select Committee on the Social and Economic Impact of the Gambling Industry (the majority of whose members are in the Peers for Gambling Reform) that advertising causes increased purchasing or why would companies do it and therefore increased purchasing of gambling must mean an increased number of problem gamblers.[iii] They also press the hot button of children, arguing that exposure to gambling sponsorship/adverts will turn them into problem gamblers instantaneously.

 

What is most worrying is that people with an input on this country’s legislative process can obviously be so divorced from the scientific process, again it has to be stated that there is no evidence that exposure to adverting/sponsorship of gambling brands causes problem gambling. What is even more worrying is that they cannot even see the error of their own thought process in that if advertising/sponsorship did cause harm, then since we have had advertising/sponsorship for almost 20 years – why have problem gambling rates fallen to such a low extent? Why are only a tiny amount of children actually gambling and only doing so because their parents let them have access to their accounts? Why is it fine to expose children to adult behaviours (drinking, smoking, swearing, fighting) in football stadia and pubs but if they see a gambling brand name they will immediately suffer harm? It is so obviously an ideological concoction that questions like how did fascism rise in advanced countries becomes understandable – supposedly educated and civilised people who have their hands on the levers of power, lose all sense when lost in the midst of ideological dogma. The best Starmer can do is abolish the House of Lords.

 

Non-sensical arguments seem to be the theme of the re-awakened Webb funded lobby as can be seen in their lobbying at Party Conference

 

[i] https://peers-for-gambling-reform.yolasite.com/

[ii] https://www.theguardian.com/society/article/2024/sep/11/labour-urged-to-impose-stricter-controls-on-gambling-ads

[iii] 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, July 2020, p.124

Party Conference Season

 

At the time of writing the Lib Dem Party Conference is just finishing and the Labour Party one is due to start shortly. At this, the Social Market Foundation, under Derek Webb protégé, James Noyes will be discussing ‘Bad money: the economics of gambling harm’.[i] This is based on a recent farcical report by Webb-funded Nera Economics, that argues that money spent on gambling is bad for the economy due to the shortness of its supply chain. They argue that if people spent their money on other things this would have a greater economic impact and this is a good reason to prohibit gambling. The SMF came up with a similar pile of manure a few years back. While literally true, it is completely economically illiterate. Most service industries have very short supply chains, think the stock market or insurance. Many industries have long supply chains which don’t provide major benefits to the British economy, think most luxury goods where the supply chain exists in another country. It also ignores the idea of consumer choice – people want to spend their money on gambling as is evidential. Christopher Snowdon of the IEA, has a good critique of this ideological claptrap here https://thecritic.co.uk/online-gambling-isnt-bad-for-the-economy/

 

What is slightly concerning is the appearance on the panel of Baroness Twycross, our gambling Minister and the renowned left-wing commentator/economist/Guardianista Will Hutton giving it some credence. In reality, it’s on at 10am in the morning, most speakers will have agreed just to justify the expense of attending Party Conference for which the evening’s activities are what are really of interest and I suspect there will be not enough people in the audience to justify the amount of crack cocaine which they must have smoked to have come up with such a tenuous and utterly bullshit argument.

 

In the same theme is the session hosted by the anti-gambling campaign group who needs reporting to the Charities Commission for fraud (it not being a charity), Gambling With Lies. This Gambling Commission funded group holds my award for the anti-gambling group that has spread the most disinformation about gambling, ignoring requests from the Office for Statistics Regulation and the Gambling Commission to stop blatantly lying about gambling related suicide statistics.[ii] Considering the early work of the Campaign for Fairer Gambling, this is quite an achievement. Their fringe is entitled ‘Stopping Gambling Suicides’ which translated from the language of zealots, means banning all gambling.[iii] What is surreal is that anyone with any ounce of knowledge of psychology knows that suicide is a multi-variable complex condition of which no specific cause can be attributed to a suicide. This was the line the Samaritans have stuck with for decades, until their relatively new CEO, Julie Bentley, a panellist for this loon-fest, decided that gambling was an exception. There is no evidence that other activities are seen as equally exceptional, it just seems that Bentley has taken up the anti-gambling cause. It may be that she has research that is yet unpublished, or is a great friend of the Ritchies or she has realised that gambling-related suicide is a ‘hot topic’ and will be the recipient of thousands in research funding and she wants her snout in the trough as well, Gambling With Lies appearing to have the ear of many in DCMS regardless of their distance from the truth.

 

Like with the SMF, this fringe is really quite fringe. Whilst these meetings provide the nutters with a chance to share their conspiracy theories with each other and dream of a world without fun and laughter and possibly undertake heinous sexual practices as these folk have a preponderance to do, the biggest Puritans usually being the biggest Perverts (see various MPs spouting family values), they have little if any political impact. The real political movers and shakers would not be found at such events, very few people attending Party conference give a hoot about gambling. But it is a funded jolly.

 

Where is the pro-gambling/racing opposition to all of this? Last year the Betting and Gaming Council spent thousands of pounds on sponsoring the biggest party at Labour Party conference, the Daily Mirror party which would have given the BGC access to the number one ticket of the week an supposedly all the party’s great and good. How useful was this in terms of lobbying? Having attended this party a number of times, it’s pointless trying to lobby as everyone is letting their hair down. This is the big question about the BGC, is how useful have they been considering practically everything that the anti-gambling groups have been adopted by DCMS and the only public evidence of their efforts have been press releases welcoming every new restriction on gambling. We will consider this after we look at one of the biggest elephant’s in the room.

 

[i] https://www.smf.co.uk/party_conferences/smf-at-2024-party-conferences/

[ii] Author’s own complaint and https://x.com/lynchjordan12/status/1826620439998972365

[iii] https://x.com/GambleWithLives/status/1834561348065268055

Political donations

 

While fringe meetings like these at Party Conference don’t have much political sway. Donations of cash to political parties do. It used to be said that £125,000 bought you a knighthood and double that a peerage. If this is fee structure, which I very much doubt, then Derek Webb is possibly after a Dukedom.

 

Since Derek Webb’s £71,000 donation to Tom Watson MP in 2018/19 (£36,000 on 01/12/2018 and £36,000 on 01/06/2019) which was at the time when his protégé Derek Noyes was writing an anti-gambling report for Watson, Webb had a political donation hiatus for a couple of years.[i] Then in 2021, he gave the Labour Party £10,000 and £40,000 in 2023, pocket change for the multi-millionaire ex-casino-games salesman.[ii]It should be clarified that Derek Webb has categorically stated that he has no more business dealings with the gambling industry. The fact that he funds anti-gambling groups and thinktanks who campaign against the online industry but not his friends in landbased, does leave some questions unanswered. As does why he has donated £1 million pounds to the Labour Party (4 x £250,000) in the build up to the General Election?[iii]

 

It may simply be that he is a passionate supporter of Keir Starmer and wanted to do everything to support his election. A laudable political aspiration, especially as he donated to the Lib Dems £332,000 back in 2014 just before they announced they were all for banning FOBTs which Webb set up the Campaign for Fairer Gambling to do.[iv] Even odder if a true Labour fan is the donation of £250,000 to the Lib Dems registered on the 221nd June 2024.[v]

 

Obviously, there is no suggestion of wrongdoing or political influence. In the same time period, the Labour Party received £23.5 million in political donations, so Webb’s million is a measly 4.2%, and of those donations, £10.7 million came from individuals, again Webb’s is a measly 9.3%. Webb’s donations are outshined by the likes of Lord David Sainsbury of Turville (greengrocer), Gary Lubner (windshield repairman), Martin Taylor (hedge fund guy), Stuart Roden (another hedge fund guy) and Fiona McTaggart (ex-Labour politician).[vi]

 

The size of the donation does rather outweigh the donations of very well-known Labour supporters who happen to also be in the gambling industry such as John Coates from Bet365, who stayed in Stoke because they wanted to pay their taxes, not because they wanted to influence government policy as alluded to by often-mistaken-for-a-serial-killer Rob ‘prohibitionist’ Davies of the consistently anti-gambling, Daily Mail of the Left and so bankrupt they have to sell the Observer, Guardian newspaper.[vii] Hope your job’s safe Rob, if not, maybe Noyes will let you join the paid protégé gang, you’ve been parroting their mantra for years pretending it was news anyway.

 

If anything, the gambling industry must question why a multi-millionaire ex-pat, resident in Las Vegas and one would suspect, paying tax there, is willing to keep spending money on British political parties?

 

You would have thought that the BGC would be very publicly question it at least?

 

[i] Electoral Commission Register donation references: C0400230 & NC0406063

[ii] Electoral Commission Register donation references: C0453531 & C0568566

[iii] Electoral Commission Register donation references: C0576215, C0587017, C0579513 & C0587016

[iv] Electoral Commission Register donation references: C0146149, C0146147, C0146148, C0146150, C0165387 &C0165399

[v] Electoral Commission Register donation references: C0579513

[vi] https://www.electoralcommission.org.uk/political-registration-and-regulation/financial-reporting/political-finance-online

[vii] https://www.theguardian.com/society/article/2024/jun/28/tory-betting-scandal-labour-gambling-industry-regulation

The Betting & Gaming Council (BGC)

 

They may have not noticed as the trade association representing the biggest players in the industry has very recently had a change in management. After their Chair, seasoned leisure industry trade association veteran Brigid Simmons had decided she’s had had enough, the CEO, Michael Dugher moved himself into her job and Grainne Hurst became CEO. The question is what will change?

 

There are quite a few unfounded allegations about Dugher’s effectiveness doing the rounds. The malicious gossip suggests that Dugher was more interested in corporate hospitality, expensed lunches and general political chit chat than the nitty gritty of gambling politics, which considering his rumoured salary of £300K+, suggests the industry has not been best served. But if we dig a little deeper, it might just be, that if these scandalous allegations were true it is because he had been given very little to do by his paymasters.

 

The clue to this is in the statement by Hurst on taking on the new role:

 

There is a huge amount of work ahead of us, not least delivering and implementing the outstanding proposals outlined in last year’s White Paper, many of which our members called for.[i]

 

This is a reminder that back in 2020, when giving evidence to the anti-gambling House of Lords Select Committee on the Social and Economic Impact of the Gambling Industry, the then CEO of GVC (now Entain) and the then COO of Skybet (now part of Flutter), both stated they wanted Affordability introduced.[ii] Hurst states they wanted other restrictive measures as well. This being the case, this may be way Dugher had so little to do. His paymasters were willing to accept all the forthcoming gambling restrictions proposed by the anti-gambling groups.

 

Was this a survival strategy, with gambling being told if it didn’t accept everything the anti-gambling lobby wanted, gambling would be prohibited? There is no evidence to suggest this ultimatum was ever given. Equally, there is no evidence that suggests the big boys of gambling a) know that the stricter the regulations, the higher the barriers of entry so they are less likely to compete against some market changing innovation from a newcomer, and b) restrictions like  Affordability mean they no longer have the shame of closing down people’s accounts for commercial reasons (like winning) as enhanced financial checks will push them all to the black market, causing the eventual demise of the expensive to produce product of racing and they can focus on the cheap and predictable profit margins of casino games played by recreational players thus transforming them from being gambling companies to just farmers, harvesting their profits but without the risk of weather or disease causing crop failure.

 

We may never know why, when writing the history of the BGC with Dugher as CEO, was it so supine and so unwilling to pushback against the Forces of Darkness. But will Grainne be any more effective in the traditional role of trade association pushing for the rights of the industry?

 

I have known Grainne from the time she was a researcher for the most effective pro-gambling politician in my career, Philip Davies MP. She has always struck me as highly effective, intelligent and a real fan of racing, having set up a syndicate in the past. I have to say that there have already been some examples of the BGC growing some, until now very absent, cojones. There was the letter from Grainne to the Times newspaper in response to an atypical anti-gambling article, where she reminded them of the facts and not to conflate problem gambling, a sub-clinical ailment, with addiction.[iii] The BGC also issued a press release about the Gambling Survey of Great Britain (GSGB), a ridiculously flawed piece of work of which more below, stating:

 

Our members are concerned these findings may be unreliable because there is a significant risk GSGB overstates gambling participation and gambling related harm[iv]

 

While this is encouraging, the BGC seems to be ignoring rebutting the more obvious sources of misinformation, like the report by NERA mentioned above or in fact anything issued by Gambling With Lies. This may be due to a lack of personnel, they are hiring Public Affairs staff, but after about 5 years in operation, it does seem like it’s by design.

 

They have also released a report, just in time for Labour Party Conference,  on the size of the black market, stating that 1.5m gamblers stake up to £4.3bn on illegal gambling black market each year. Grainne is quoted:

 

The Government and the regulator risk sleepwalking into this issue. Simply giving the GC more powers and more resources to tackle the black market won’t, in itself, work. Enforcement is only part of the solution. The fact is onerous and ill-judged regulations drive customers from the regulated sector to the unsafe, unregulated gambling black market. Proposals by anti-gambling prohibitionists like advertising bans or intrusive, blanket, low level affordability checks will not protect customers, in fact they will give another leg up to unscrupulous black market operators, the last thing anyone wants. Every comparable market in the world tells us the same thing. The best defence against this growing illegal, gambling black market is getting the balance of regulations right.[v]

 

This is all very laudable but surely too little too late. Where was the push back over the last few years. I don’t call a few strongly worded press releases warning about the black market, in between press releases welcoming all the new restrictions that will cause a black market as pushing back or even doing the job of a trade association. We have seen more pushback under Grainne’s few days in office than under years of Dugher, I just hope she is getting paid at least the same.

 

Using a historical analogy, the BGC are like the USA in the early years of the Second World War and do trust me, we are in the midst of a war with a very well-funded campaign to get gambling abolished, they have been uninterested in getting involved. When and what will be their Pearl Harbour?

 

[i] https://www.intergameonline.com/casino/news/bgc-welcomes-new-ceo

[ii] https://committees.parliament.uk/oralevidence/97/html/

[iii] https://x.com/BetGameCouncil/status/1828343389177233872

[iv] https://bettingandgamingcouncil.com/news/bgc-statement-on-gsgb-publication

[v] https://bettingandgamingcouncil.com/news/shock-new-study

Gambling Commission

 

The Gambling Commission maintain their strategy of mendaciousness and perfidy. They are arguably the most effective of all the anti-gambling groups and continue on the path of destroying our gambling industry.

 

We currently have the pilot of Affordability being undertaken by the big boys (who asked for it). With financial thresholds set at twice what they will be when the LCCP comes in proper, it was never an attempt to see if this ‘sledgehammer to crack a nut’ policy would destroy British racing. We will have to wait probably until the new year for that. This test is simply to see if the data sharing works and whether the checks will be as frictionless as Stuart Andrew MP repeatedly promised and our new gambling Minister accepted. Expect this to be a slow burn with wild fires starting when the LCCP comes in.

 

Also don’t expect the result of various Parliamentary Committees demanding the Commission do research into whether any of their anti-gambling policies actually make any difference to amount to anything. Yes, the Commission is finally on the case, but they are wheeling out the NatCen to do the evaluation.[i] If the BGC was worth its salt it would demand the Competition and Markets Authority look into the Commission’s tendering process as Nat Cen are so embedded within the Commission that I’m surprised they don’t call Tim Miller a person of significant control. I’m not suggesting that Nat Cen are rabidly anti-gambling on a corporate level, I’m just suggesting that they use anti-gambling researchers and their persistent commissioning suggests potential integrity issues if they are to be considered independent, especially their involvement in actual research that they are now supposedly evaluating. One of their previous employees/researchers I am calling out as anti-gambling and actively seeking to change the regulatory regime for one that is akin to prohibition and that is the apex predator of the anti-gambling pseudo-academia, Heather Wardle, who again is commissioned by UKGC to do the hideously flawed Gambling Survey of Great Britain. Wardle has been commissioned so many times by the UKGC that she is surely subject to IR35 tax rules. Again the BGC needs to ask questions on the transparency of the UKGC’s commissioning process as the public would expect independent researchers to be used, not ones so unconcerned about the flaws in the methodology.[ii]

 

The methodological issues with the GBSB are well known and were well known before its publication.[iii] Professor Sturgis, who was called in to look at the methodology, according to the Commission gave it a glowing bill of health, the Commission just forgot to publish the bit where he warned about the danger of problem gamblers being over represented due to the way the sample was collected. Very good articles by Chris Snowdon https://thecritic.co.uk/gambling-with-the-numbers/  and Andrew Tottenham  https://cdcgaming.com/commentary/publish-and-be-damned/ look at how seriously the research is flawed. I thoroughly recommend signing up to Dan Waugh or Regulus Partners’ Winning Post newsletter (https://www.reguluspartners.com/subscribe) which has done a forensic investigation into what can only be described as the egregious case of perfidy of the Commission so far.

 

A stern letter was written from the BGC pointing this flaw out and how over inflated numbers would feed into all sorts of research and policy, giving a false impression of the state of the gambling industry and increase demands for its restriction. This forced the UKGC to issue guidance on how to use the survey, which showed off just how little use it actually is.[iv]  The Commission warned people from abusing the statistics and said that they would punish those who did. Unsurprisingly, the usual anti-gambling brigade ignored this and deep-dived into the survey that multiplied the supposed number of problem gamblers by a factor of eight. This was picked up by the Guardian and some politicians, almost as if this was the plan of the Commission overall.[v] Why so cynical? Because there has been no public admonishment of those who have misused the statistics, or the very fact that the Commission published the survey in the first place – a neutral organisation would have sought to rectify the problems before publishing or maybe started again.

 

This is the way of the Commission. Evidence and facts are not their objective. It is an ideological strategy to restrict gambling. If one considers many of the statements of Andrew Rhodes, who has the appearance and C.V. of a mediocre public sector worker, with very few successes to his name, it does seem that he is trying to destroy the industry he regulates as this is what his mediocre public sector social circle expect of him and he is willing to ignore facts and evidence to do it. Hopefully, the Labour Party’s suggestion of an ombudsman for regulators will see the light of day and us normal folk can take him to task. The fact that the big gambling companies have not sought a judicial review of the Commission speaks volumes.

 

Unfortunately, with my prediction that there will be little Parliamentary scrutiny over the next few years due to the distraction of trying to turn this country around, the Commission has free rein to do what they want and a White Paper full of amorphous policy suggestions that give them pretty much carte blanche. My prediction is that bonuses/incentives will be next for the chop and that the government imposed voluntary agreement with sporting bodies on advertising/sponsorship will be attacked backed up by spurious research. Racing will wither on the vine as it is not, as the Commission have stated, part of their remit if their actions destroy Britain’s second most favourite sport, by viewer numbers.

 

[i] https://www.gamblingcommission.gov.uk/blog/post/evaluating-the-impact-of-the-gambling-act-review

[ii] https://x.com/chrisgambler247/status/1817150512204046737

[iii] https://x.com/chrisgambler247/status/1817494661851726187

[iv] https://www.gamblingcommission.gov.uk/about-us/page/guidance-on-using-statistics-from-the-gambling-survey-for-great-britain

[v] https://x.com/chrisgambler247/status/1816462611254256125/photo/1

The Forces of Darkness

 

Spurious research is the signature of those who I call the Forces of Darkness. These are the pseudo-academics and non-independent researchers who provide the biased research that unfortunately makes up the evidence in evidence policy making these days. I will hold with my accusation of them being pseudo-academics as the very foundations of academia is the scientific approach of neutrally gathering evidence and reaching a conclusion based on it, not what they do which is use methodologically flawed processes to reach their pre-decided conclusions based on ideology. These people are political activists not scientists.

 

How the Forces of Darkness will be operating is around the current research hot topics – the supposed harms of gambling and how they can show the majority of the population is harmed. I hear that Wardle presented to the UKGC Industry Forum on the harm to relationships that gambling can cause, based on the flawed GSGB. Without seeing the data I cannot say, but I would bet a large amount of money that her work both conflated problem gambling with normal gambling (she has form for this) and that gambling is seen as the only cause of relationship issues, ignoring co-morbidities as is commonplace amongst the zealots.

 

There is also research starting on gambling related suicide. A recent letter in the academic journal, Addiction, stated that researchers (some blatantly anti-gamblers) would start doing ‘psychological autopsies’ of suicides considered to be gambling-related.[i] This process involves interviewing people close to the suicide in order to ascertain what caused it. There is obviously a huge amount of scope here for bias. As we have already seen, prominent campaigners against gambling related suicide have tended to focus on the suicide’s gambling, rather than say their drug and/or alcohol addiction, long term mental health problems and relationship issues. Again, suicide is a multi-variable complex issue but this will undoubtedly be ignored. As will the common theme in suicides of ACE (adverse childhood experiences), because that would imply blame could, in part, lie with the bereaving and campaigning parents. We can be pretty sure this will lead to anti-gambling bias as the example they give of psychological autopsies is the research undertaken in Hong Kong in 2010, which Gambling With Lies have used to provide over inflated estimates of gambling related suicide number in the UK. This letter to Addiction, as with Gambling With Lies, fails to mention that the main cause of the heightened percentage of suicides in the research was due to the suicides having been threatened by triads and shamed by their families. No real academic would think this research was culturally extrapolative to the UK, but that is why they are pseudo-academics.

 

Apart from ideologues pretending to be academics and inserting bias into the evidence base, the other issue we have to deal with is how the Forces of Darkness work together and are embedded into the government and regulator. As mentioned above Wardle is the pet academic for the Commission, Gambling With Lies has met every Secretary of State and gambling Minister since they were formed and more importantly, done so in face to face meeting not part of roundtable discussions. The BGC cannot say the same. Then we have the SMF hosting roundtables for DCMS, clinicians, GambleAware but with no industry present.[ii] Do DCMS think of the SMF as a revered political thinktank or just the paid tool of Derek Webb?

 

We also have the issue of cross pollination, where anti-gamblers either have undeclared partners working in other organisations, causing a conflict of interest as happened with the rabidly anti-gambling Matt Gaskill, head of the NHS Northern Gambling Service and his wife working for Gambling With Lies. Or Gambling With Lies fanatic Will Prochaska[iii], going to be CEO of the Derek Webb funded Coalition to End Gambling Ads (CEGA), originally set up by the only person sacked by Corbyn for being incompetent, Matt Zorb-Cousins, also a Webb employee. This ‘People’s Front of Judea approach, increases the number of anti-gambling groups, even if they have the same paymasters and share the same staff. Gambling With Lies doesn’t show a CEO on its website, are they recruiting, or is Fanatic Prochaska doing both jobs?

 

On a similar theme of academic bias, a recent advert by University of Lincoln for a research assistant in gambling advertising, stated about their preferred candidate; 'Ideally, we are hoping to recruit somebody with lived experience of gambling harms.' As campaigner for common sense, Chris Fawcett highlighted and questioned ‘Why would this be relevant for an objective scientific research project?’.[iv] How can any academic research be taken as proper research when those who undertake it are blatantly anti-gambling. The irony is that the pseudo-academics have been campaigning successfully, for the mandatory Levy, as they say it stops the influence of the gambling industry – although never ever providing any examples of where research has been influenced. However, academic research provided by pseudo-academics who are overtly-antigambling and have received benefits from the anti-gambling lobby remain impervious to any allegation of bias.

 

We need the industry not only to call out biased research but also to invest in academic research inside and outside the mandatory Levy. Research that can show no influence from its paymasters is eminently possible and exists throughout academia. The industry needs to fight back in this space or it will always lose the evidence in evidence based gambling policy war.

 

[i] https://onlinelibrary.wiley.com/doi/10.1111/add.16668

[ii] https://x.com/chrisgambler247/status/1818757066707943827

[iii] https://x.com/cjsnowdon/status/1835306640049881555

[iv] https://x.com/chrisgambler247/status/1813651042287927792

We’re talking about money, money

 

And this is what it comes down to as always, money. The anti-gambling groups are motivated by it. In my typology of the Forces of Darkness there are the Derek Webb funded groups and research. They are motivated by campaigning against anything which competes with Derek’s mates in the land-based casino industry as evidenced by them never once mentioning that problem gamblers do use casinos. Then there are the pseudo-academics, they are motivated by the grant giving gravy train that already exists due to the Gambling Commission spaffing money on anyone with a bad word to say about gambling and the tsunami of industry cash that will arrive once the mandatory Levy happens and we will see research on every aspect they can think of to provide evidence for gambling’s demise. Gambling With Lies already has its money due to their regulatory settlement from Playtech that allows them to campaign against gambling while pretending to be a charity. By not doing charitable things they can pay themselves for years until their guilt hopefully subsides. For money isn’t the only motivator, many of the pseudo-academics and anti-gambling groups are full of anti-gambling zeal for reasons of religiosity and political ideology (Marxist). Many are ex-problem gamblers who find it easier to blame the industry than themselves and some blame the industry because they cant see that they were at least partially at fault for gambling related suicide

 

The ridiculous thing is that we are an industry that deals in billions of pounds and makes hundreds of millions of pounds in profit, yet it seems as if we are spending pennies against the Forces of Darkness that are trying to shut us down. In some ways the nutters are always expected in the gambling debate, the surprise over the last decade has been how well funded they are, but at every stage if more money and better personnel had been employed by forces of Light – the gambling industry - we would not be at the existential point we are now.

Conclusions

 

I feel I must apologise for this 17,500 word rant about what has been going on in British gambling since the General Election, but it has been good research for a future publication and cathartic for me, having seen how far the nutters have succeeded.

 

To conclude, I think gambling restrictions are going to get much worse. I think legislative change will take some time, but that’s not really the issue. The issue is how well the British gambling industry and horseracing makes their case for survival, as I can’t see that many policy actors willing to fight for it. What I do see is Derek Webb spending millions. I see a deeply flawed GBSB being accepted as science and then creating a new paradigm for viewing gambling – it just causing everyone harm. I see no investment in proper research and real academics willing to point out that the majority of the evidence base against gambling is deeply flawed and paid for and created by anti-gamblers.

 

As an industry we only have the BGC to depend on. Is that enough, their track history says no, but the new CEO looks like bucking that trend, but again, is it enough? Currently, I would suggest that you invest in black market licences and operators as that’s where the customers and businesses will be going.

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