I recently wrote an article for Eventus International on the importance of annual audits for operators (https://www.eventus-international.com/post/the-importance-of-an-annual-audit), and I was pleased to see a number of these themes echoed by those speaking at the Ethical Gaming Forum this year. Compliance as a central part of gambling is only increasing in importance, and the EGF provided an opportunity for various stakeholders in the gaming ecosystem to come together and discuss how to reassess and reposition compliance, with a particular focus on responsible gambling and player protection.
The first of these proposals comes from the top; ethical corporate governance. This boils down to one simple mantra; do what is right by the customer. An operator with a healthy relationship with its players is one which has proactive responsible gambling policies, balances policies with execution, and acknowledges the power and influence of certain individuals within the organisation. Audits, staff training and staff mentoring are all helpful ways of achieving ethical corporate governance. Audits can also help to flush out where problems lie; an organisation which is always fighting fires does not have chance to look and figure out where those fires are actually starting. The biggest disasters hit companies which did not see it coming.
The second method mooted for championing compliance was to rethink who players really are – and who safer gambling tools should be aimed at.
The recognition and acknowledgment that there is a sliding scale of customers should be the starting point. Customers do not fit neatly into two boxes of ‘problem gambler’ and ‘responsible gambler’. This simple recognition has helped a number of operators to reframe their player protection measures and reposition them earlier in the customer journey to assist with harm minimisation by placing friction in the right places. For example some are now implementing an ‘opt out’ process; the guard rails are automatically in place on an account and a customer must actively remove them. Safer gambling tools should be aimed at all customers. In fact – some go as far as to say that safer gambling tools should NOT be aimed at problem gamblers at all – self-exclusion is there for problem gamblers.
A big objective for most operators present was to have every single customer on their platform utilising player protection measures or safer gambling tools, not just those potentially on the riskier end of the scale. A comment I found particularly interesting was a dislike of the phrase ‘ responsible gambling’, because it implies the existence of irresponsible gaming… And whilst that may exist, this leads to stigmatisation of gaming not considered responsible, and can result in a failure to seek assistance in the form of safer gambling tools.
Here is where the ski helmet (or seatbelt) analogy comes into play. Wearing a helmet for winter sports is now considered the norm. It is now strange and somewhat uncomfortable to see someone without a helmet. And yet not too long ago that was the reverse; but most would agree they would rather have it and not need it than need it and not have it!
These changes in the industry do not need to come from the regulator or the legislation, and it is encouraging to see such positive changes coming from the industry itself.
And finally, a reframing of compliance as a commercially beneficial aspect of operations. Compliance as a commercial element may seem either counter intuitive, or even potentially dangerous, to many operators, however it undoubtedly creates opportunity to leverage commercial advantages when utilised correctly. Better customer trust and loyalty, a reason not to stray into the black market, employee retention, brand image and awareness, and – of course- avoiding regulator intervention to name just a few. As a regulatory lawyer, my focus will always be on the latter, but it is important to mention the other benefits too, particularly with a view to ensuring compliance is always considered a cornerstone of the industry.
These benefits also lead me nicely into another theme (and therefore another article!) from the conference; the public perception of gambling.
Amanda Usher