GambleAware works with The Jockey Club’s advertising agency

  1. On 22 June 2018, GambleAware (GA), the UK’s leading problem-gambling charity, announced that it had appointed M&C Saatchi to develop a new “safer gambling” advertising campaign. There’s only one problem – and it’s a big one. The Jockey Club, the largest commercial group in British horseracing, is also a client of M&C Saatchi (screen shot in Figure 1). GA’s choice of an advertising agency with this glaring conflict of interest only undermines the charity’s independence and credibility.

    Figure 1. The Jockey Club is a client of M&C Saatchi: M&C Saatchi London website at 17 July 2018

  2. That GA press release was notable for another reason: there the charity finally publicly acknowledged on its website that it had been working with the Incorporated Society of British Advertisers (ISBA), the trade body for UK advertisers (for the importance of this point, see 17 June 2018 post, para 10).
  3. The Jockey Club is headquartered in central London, in the same offices as the British horseracing authorities,” says its website. Equally cosy is The Jockey Club’s relationship with the gambling industry. On 12 July 2018, for example, the largest commercial group in British horseracing proclaimed on its website that gambling company William Hill would operate retail betting shops for the next five years at all 15 of its racecourses nationwide, succeeding Betfred as “exclusive betting shop provider”.
  4. Betfred hasn’t disappeared, though: it’s one of the “four betting partners” that work with Rewards4Racing, The Jockey Club’s customer loyalty programme. (The other three bookmakers involved are: Coral, bet365 and Betfair.) Members of Rewards4Racing – membership is free – collect points on every bet they place online with the four gambling firms. The scheme has “more than 1m” members, according to The Jockey Club website. Members then spend their points at the racecourses.
  5. The Jockey Club says on its website: “Its [Rewards4Racing] aim is to incentivise racegoers to attend more frequently, while rewarding those who already do.” Well, yes, but by working with bookmakers in this way, The Jockey Club is also using its racecourses to encourage people to gamble online – that is, when punters are nowhere near a racecourse or high-street betting shop.
  6. Online gambling is rightly under particular scrutiny because of ease of access – and ease of addiction. The Financial Times newspaper, for example, examined some of the problems in a long article last month entitled “Online gambling: the hidden epidemic”.
  7. Yet another way The Jockey Club depends on the gambling industry is its (The Jockey Club) revenue streams from high-street bookies. The shops pay for media rights, permitting them to show racing on in-store TVs. Also, all gambling firms that take bets on horseracing in the UK cough up 10 per cent of their gross profits from racing, above the first £0.5m they make, to racecourse operators including The Jockey Club. This profits levy is known as the Horserace Betting Levy.
  8. Clearly, The Jockey Club and the gambling industry are inextricably intertwined. Therefore, advertising agency M&C Saatchi has a fatal conflict of interest working for both The Jockey Club and GA. In GA’s press release, Giles Hedger, chief executive of M&C Saatchi, burbled: “We are delighted to be playing our part in the creation of a more mindful gambling culture in the UK. This is a new and important chapter in the ongoing balancing of market freedoms and public health.” The advertising agency wins both ways on gambling. It promotes The Jockey Club, an organisation both closely linked to and dependent on betting firms. Thus M&C Saatchi helps to increase gambling-related harm. The overall aim of GA, meanwhile, is to reduce gambling-related harm, taking a public health approach. Therefore, the agency’s “safer gambling” campaign for GA is intended to tackle some of the problems partly arising from its work with The Jockey Club! On gambling, M&C Saatchi’s business model stinks. What’s worse, GA is legitimising that business model.
  9. The recently finished World Cup was only the latest reminder of the many controversies around gambling advertising (see 11 March 2018 post). Viewers and listeners, including children, were bombarded with betting ads. As I showed on 11 March 2018, the annual advertising budgets of the big gambling firms dwarf the £7m GA says it will spend each year on its new two-year campaign. So will GA’s “safer gambling” campaign even be noticed, let alone effective, in the blizzard of excessive gambling ads?
  10. ADDENDUM 1: A GA ad was certainly noticed last year – for the wrong reasons. Advertising regulator the Advertising Standards Authority (ASA) ruled against the charity for its “offensive” cinema ad (see 7 June 2017 post).
  11. ADDENDUM 2: Communications agency Atlas Partners acts as both PR agency and political lobbyist for GA (see 27 February 2017 post). Previously, both roles were carried out by the now defunct Bell Pottinger. Like M&C Saatchi, Bell Pottinger was conflicted when working for GA: Bell Pottinger acted for the British Horseracing Authority (BHA) at the same time. As its name suggests, BHA “is responsible for the governance, administration and regulation of horseracing and the wider horseracing industry in Britain”.
  12. ADDENDUM 3: A final point about openness, transparency and accountability – or lack of them. Scott Bowers is group director of communications and corporate affairs at The Jockey Club. He’s “one of the most influential PR professionals in the UK”, according to its website. I asked Mr Bowers in an email when his employer started working with M&C Saatchi. He replied: “I’m sorry but it’s our policy not to comment on third-party organisations. We have thousands of supplier relationships so it’s just not feasible.” A laughable response, as I told him. M&C Saatchi, meanwhile, was non-responsive: I‘d simply requested in an email confirmation of what’s on its website – that The Jockey Club is a client.
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Addendum: Fifth reason for astonishment at Tom Watson MP over Sky Bet

  1. Here’s a fifth reason why I’m astonished Tom Watson MP accepted the gift of four tickets for a football match from Sky Bet (see previous post). On 28 March 2018, gambling regulator the Gambling Commission fined Sky Bet £1m for “failing to protect vulnerable consumers” (http://www.gamblingcommission.gov.uk/news-action-and-statistics/news/2018/SkyBet-to-pay-1m-penalty.aspx).
  2. As I say, Mr Watson didn’t respond to requests for comment. I emailed him twice at parliament: 23 June 2018 and 27 June 2018. On both occasions, I immediately received an automated acknowledgement.

Tom Watson MP accepts gift of four tickets for football match from Sky Bet

  1. The latest (at 18 June 2018) register of MPs’ financial interests shows that Tom Watson MP accepted a gift of four tickets for the Sky Bet Championship play-off final, a football match that took place on 26 May 2018. The total value was £392. Sky Betting and Gaming (Sky Bet), the gambling company, was the donor. As well as being deputy leader of Labour, Mr Watson is shadow culture secretary.
  2. I‘m astonished at his decision for at least four reasons.
  3. First, as shadow culture secretary, Mr Watson surely shouldn’t be compromised or appear to be compromised by accepting gifts from the gambling industry. Gambling is within his remit – and, as everyone knows, there are many controversies around the industry and its regulation.
  4. Second, the shadow culture secretary regularly lambasts the gambling industry. On 15 June 2018, for example, The Times newspaper revealed that the government wouldn’t be introducing its £2 maximum stake on fixed odds betting terminals (FOBTs) until April 2020 after the Treasury struck a backroom deal with bookmakers. The Guardian newspaper followed up the story the next day, where Mr Watson blasted the government for its two-year delay: “Capitulating to a two-year delay is a pathetic move from a fundamentally weak government. Those who praised the government when the announcement was made will feel badly let down. They are already rolling back on their promises and allowing these machines to ruin more lives.” Last weekend, meanwhile, Mr Watson turned his fire on online gambling, telling the Financial Times newspaper: “Britain is in the throes of a hidden epidemic of gambling addiction, with the rise in online and smartphone gambling a central part of the problem. There has been an explosion of new digital products since the last law was passed to regulate gambling. The current laws aren’t fit for the purpose of regulating these new products. If we are to get a grip on the rise of problem gambling we need a new Gambling Act fit for the digital age.”
  5. Third, Sky Betting and Gaming is a leading online gambling firm – and so one of the companies fuelling Mr Watson’s “hidden epidemic of gambling addiction”. (Sky Bet is its sports betting brand.)
  6. Fourth, Sky Betting and Gaming, as its name suggests, has a longstanding association with satellite broadcaster Sky PLC. Indeed, Sky held a controlling stake until 2015, when it sold an 80 percent stake to private equity firm CVC Capital Partners. Sky continued as partner, retaining a 20% stake and consenting to a long-term licence of the Sky brand. In April 2018, CVC and Sky in turn sold the firm to Canadian betting behemoth The Stars Group for £3.4 billion. Nevertheless Sky retains an interest with a small stake in Stars, and the Sky trademarks are still used under licence. Sky, of course, was founded by media mogul Rupert Murdoch, who owns 39.14% of the firm. Mr Murdoch’s company News International was seriously damaged by the 2011 phone-hacking scandal at the now-closed News of the World newspaper. And Mr Watson was one of the leading campaigners who helped expose wrongdoing at the infamous tabloid. In 2012, he published a well-known book with journalist Martin Hickman on the alleged abuses of power by Mr Murdoch’s UK newspapers not only the News of the World, “Dial M for Murdoch: News Corporation and The Corruption of Britain”. Mr Watson remains a vocal critic of Mr Murdoch as the mogul continues his protracted stop-start battle for full control of Sky.
  7. Four reasons, then, why I’m astonished Mr Watson accepted the gift of four tickets for a football match from Sky Bet.
  8. Mr Watson didn’t respond to requests for comment.

GambleAware trustee works for secretive political lobbyist – and fails to disclose role on trustee register of interests

  1. A trustee of key charity GambleAware (GA; registered charity number: 1093910) is working for a secretive political lobbyist – and has failed to disclose the role on the trustee register of interests.
  2. Former MP and government minister Chris Pond was appointed as a trustee of GA, the UK’s leading problem-gambling charity, on 9 March 2017, Companies House filings show. Mr Pond “was until recently head of UK public affairs with Kreab Gavin Anderson”, says his biography on the charity website (screen shot in Figure 1). As you can see, no dates are given. His Who’s Who 2018 entry, however, states Mr Pond worked for the political lobbyist 2013-2016. Before becoming a GA trustee, then.

    Figure 1. Trustee Chris Pond biography on GambleAware website at 26 May 2018

  3. In 2017, though, Mr Pond became an “adviser” to another political lobbyist, Centaurus Communications Ltd (registered company number: 08335964), according to its recently re-designed website (screen shot in Figure 2). Nevertheless Mr Pond hasn’t disclosed the role on the GA trustee register of interests (screen shot in Figure 3).

    Figure 2. “Chris Pond joined Centaurus as an adviser in 2017” – Centaurus Communications Ltd website at 30 May 2018

    Figure 3. Chris Pond’s entry on GambleAware trustee register of interests at 26 May 2018

  4. At 17 February 2017 Mr Pond was on the Centaurus website as an “adviser” – that is, prior to joining the charity as a trustee (https://web.archive.org/web/20170217211513/http://centauruscommunications.com/#team). There’s nothing special about 17 February 2017: it happens to be the earliest date last year when the Centaurus website was captured on online archive the Wayback Machine.
  5. It’s bad enough a GA trustee is working for a political lobbyist. What’s more, Centaurus is a secretive company: it doesn’t routinely disclose the clients for whom it provides political lobbying services. Thus there’s no client list on its website.
  6. Further, Centaurus Communications isn’t a member of the Association of Professional Political Consultants (APPC), where members report their political lobbying clients on a public register. The firm isn’t a member of the Public Relations Consultants Association (PRCA) either, where again members disclose their political lobbying clients on a public register.
  7. As I say, Centaurus keeps its clients secret. In addition, Jonathan Horsman, the company’s owner and sole director, didn’t respond to emailed requests for comment about the lack of transparency on clients.
  8. Incidentally, the hidden clients – and non-responsiveness – surely call into question Centaurus’ involvement with the alternative lending all-party parliamentary group (APPG). Mr Horsman at the firm is listed as “public enquiry point” (!) for the APPG on parliament’s latest (at 6 June 2018) register of APPGs. For the avoidance of doubt, I only became aware of Centaurus’ role there because of the information on the register of APPGs.
  9. I first wrote about GA on 27 February 2017, revealing several problems with the charity that undermined its independence and credibility. One of these was that the then new independent chair, Kate Lampard, was – and is – paid proportionately more than the prime minister (almost all charity trustees are unpaid, remember). Another was that half of the then trustees, five of the ten, held senior positions in the UK gambling industry! So it’s important to acknowledge the improvements Ms Lampard has instigated at GA. The most significant is the shake-up in the board of trustees: of the now eleven trustees, only one works for a gambling company (Henry Birch, who is chief executive of The Rank Group PLC).
  10. Astonishingly, though, there’s still nothing on the GA website about working with the Incorporated Society of British Advertisers (ISBA), the trade body for UK advertisers. At date of publication searching the charity website for “Incorporated Society of British Advertisers” or “ISBA” produces no results. On 11 March 2018, I exclusively described four problems with the tie-up. Given the many controversies around gambling advertising (see 11 March 2018 post), the continuing opacity and unaccountability at the charity on its relationship with ISBA only damage public trust and confidence in GA.
  11. Back to Mr Pond and his role at Centaurus Communications. That he was already an “adviser” to the political lobbyist when appointed as a GA trustee is surely unacceptable. No trustee of the UK’s leading charity for problem gambling should be working for a political lobbyist – even if it routinely lists its clients, which Centaurus doesn’t. Equally as serious is Mr Pond’s failure to disclose the role on the trustee register of interests.
  12. I put my findings to GA in an email. In its response, a spokesperson, who withheld his/her name, wrote: “He [Mr Pond] has confirmed that Centaurus Communications Ltd recently asked him to do some paid advisory work on financial service issues going forward, which he appreciates he would need to declare, but he has not begun this work, nor has he received any payment in the past from this company.”
  13. The anonymous spokesperson continued: “May I reassure you that the register of interests is updated at least annually, and when any material changes occur – new paid employment does constitute a material change so we have now added reference to this connection in the published register of interests in advance of the work beginning. While not required to do so unless a specific conflict has arisen, Chris also brought this interest to the attention of other trustees verbally at the start of our most recent board meeting.”
  14. He/she finished: “Finally, given your concerns about the non-disclosure of the company’s client list, Chris has checked and been assured that Centaurus has never undertaken any work related to gambling. His own work with them is in financial services.”
  15. As you can see, GA didn’t explain why “adviser” Mr Pond has been on the Centaurus website from before the date of his appointment as a trustee of the charity (9 March 2017). Oh, and withholding the name of its spokesperson only undermines GA’s credibility. So much for transparency and accountability.

RGSB now publishes the minutes for its meetings – at last

  1. On 14 May 2018, I received an email from Sarah Webster of the Responsible Gambling Strategy Board (RGSB) secretariat informing me that RGSB had finally resumed publication on its website of the minutes for its meetings. (For the background on RGSB, see 20 March 2018 post.)
  2. This was after I revealed on 20 March this year RGSB‘s failure to publish the minutes for its meetings in a timely fashion. Then the latest minutes on the website were for the meeting on 18 July 2016!

Why is RGSB failing to publish the minutes for its meetings?

  1. The Responsible Gambling Strategy Board (RGSB) is an “independent expert body” whose “aim is to minimise gambling-related harm”. Funded by regulator the Gambling Commission, RGSB meets “regularly”, and publishes the minutes for its meetings on its website – or at least says it does. In fact, there at date of publication the latest minutes are for the meeting on 18 July 2016! (screen shot in Figure 1).

    Figure 1. RGSB board meetings and minutes: website at 9 March 2018

  2. RGSB has two main functions. First, it sets the national responsible gambling strategy for the Gambling Commission. The expert advisers define the “research, education and treatment” required to deliver the strategy. Second, RGSB also “works closely” with GambleAware, the leading gambling charity (see previous post), thus ensuring implementation of the national responsible gambling strategy.
  3. In response to my query why RGSB has failed to publish minutes for meetings after 18 July 2016, Sarah Webster of the RGSB secretariat said in an email last week: “The glitch was highlighted in the summer after website (sic) was updated by our IT manager, it was brought to our attention in January that there was still a problem with the website and we are working on a solution.”
  4. The Gambling Commission yesterday (19 March 2018) published its eagerly awaited advice to support the government with its review of gaming machines and social responsibility measures. In its linked letter to the Secretary of State (for Digital, Culture, Media and Sport), the regulator rightly berates the gambling industry for making “insufficient progress” in relation to the objectives of the national responsible gambling strategy.
  5. Yet it’s not just the gambling industry failing to make sufficient progress: the body that sets the national responsible gambling strategy is, too – at least in publishing the minutes for its meetings. This failure undermines public trust and confidence in both RGSB and the national responsible gambling strategy. Further, RGSB‘s response is hardly reassuring: it’s vague and lacks a sense of urgency.

Why GambleAware working with ISBA is problematic

  1. On 20 February 2018, Campaign reported on its website that GambleAware, the leading gambling charity, has engaged the Incorporated Society of British Advertisers (ISBA), the trade body for UK advertisers, to help it select an advertising agency for a new £7m public awareness campaign about low-level gambling-related harm. This tie-up hasn’t received the attention it deserves – perhaps because the charity failed to publish on its website a press release(s) about it. Further, at date of publication searching the GambleAware website for “Incorporated Society of British Advertisers” or “ISBA” produces no hits. Here are four problems with GambleAware working with the self-styled “voice” of UK advertisers.
  2. First, big gambling firms are members of ISBA, the list on its website shows. Thus ISBA isn’t independent from the gambling industry.
  3. Second, the big gambling firms splash a lot on advertising. Several are in the top 100 advertisers by spend in UK national newspapers, for example (list on Newsworks website, for the year to September 2017). Then there’s the sector’s alarming arms race in advertising: marketing spend in the UK sports betting market has increased by a staggering “estimated 19% per annum in the last few years”, according to Paddy Power Betfair, the FTSE 100 firm, when announcing its 2017 preliminary results on 7 March 2018. Clearly, the battle for market share is fierce. Meanwhile, organisations that spend more on advertising also pay more for ISBA membership, the trade body told me in an email. (At date of publication its website doesn’t even reveal this.) So the big gambling firms must have significant influence over ISBA.
  4. Third, ISBA is opaque, as its failure to disclose membership rates on its website indicates. When I queried this, Claudia King, “the powerhouse of the membership team”, said in an email: “Members who spend more on advertising will pay a higher fee as it’s based on their media spend. I’m afraid I can’t share any more information than that.” Its non-transparency and unaccountability are ironic given ISBA is loudly demanding transparency and accountability from the tech giants – Google and Facebook, in particular – as well as advertising agencies. ISBA’s 2018 annual conference, which took place last week on 6 March, was entitled “The Age of Accountability”.
  5. Fourth, membership “supports your sectoral lobbying efforts” (screen shot in Figure 1). Thus the trade body explicitly identifies, and promotes, itself as a lobby group. Like any other sector, the gambling industry presumably uses ISBA for this purpose. Otherwise, why join? More accurately, why pay to join? GambleAware surely shouldn’t be involved with an organisation that lobbies for, and with, the gambling sector.

    Figure 1. ISBA website: membership “supports your sectoral lobbying efforts” at 7 March 2018

  6. Gambling advertising is everywhere – including football shirts, notoriously. And it continues to rocket, as Paddy Power Betfair’s latest results last week show. The bookmaker reported that in 2017 its Paddy Power brand lost share in marketing spend in the UK sports betting market (15% in 2014 v 12% in 2017). Cue another hike in advertising spend: the firm will this year add around £20m to its worldwide £300m annual advertising budget. (These figures put into context GambleAware’s £7m campaign – and Paddy Power Betfair is just one gambling firm operating here, of course.) Yet many believe there’s already too much gambling advertising, and not just in the UK.
  7. For many reasons, gambling advertising is a highly contentious issue. Nevertheless ISBA “champions advertising and promotes the freedom of commercial speech” (latest directors’ report, made up to 31 March 2017). Critically, it also supports “responsible” self-regulation by the advertising industry, and has a voice in that self-regulation. Thus ISBA influences the UK advertising codes, which are written by the Committee of Advertising Practice (CAP). The codes are in turn enforced by the advertising regulator, the Advertising Standards Authority (ASA).
  8. In short, gambling advertising raises many questions, and ISBA has conflicted roles in and around it. The organisation is therefore conflicted in the ongoing debates, too. ISBA can’t act for both GambleAware and the gambling sector, if the charity is to maintain its independence and credibility (see 27 February 2017 post). The arrangement represents a fatal conflict of interest for the trade body for UK advertisers. Further, the lack of transparency and accountability only further undermine public trust and confidence in both GambleAware and ISBA.
  9. What’s worse, it’s not even clear what ISBA is actually doing with, and for, GambleAware. A report on the Marketing Week website, a few days before the Campaign one, quotes Phil Smith, director general of ISBA, saying his organisation is working with the charity “to help plan and develop its new campaign” (screen shot in Figure 2). Rather more, then, than simply helping it select an advertising agency. Thus there’s an urgent need for clarity on ISBA’s activities with, and for, GambleAware.

    Figure 2. Marketing Week website: ISBA is working with GambleAware “to help plan and develop its new campaign” at 10 March 2018

  10. In a response to a request for comment, Abi Slater, director of communications, said in an email: “At ISBA we represent responsible advertisers. We believe our gambling members are absolutely right and proper to take responsibility for some of the issues around problem gambling. To be clear we and our members will have no influence on how this campaign is executed. ISBA’s only role is to ensure they have the best agency team to develop an effective campaign.” In her second message, Ms Slater decided to be more forthcoming about membership rates, after prompting: “I can confirm that fees start at around £5k and then are on a sliding scale based on Nielsen data. This is the information we give potential members when we discuss costs with them.” (Still not full disclosure, but an obvious improvement over what Ms King was prepared to divulge earlier.)