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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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.

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.)

ASA censures “offensive” GambleAware ad

  1. Following the cover-up at GambleAware, the leading gambling charity (see last post): the Advertising Standards Authority (ASA) today (7 June 2017) ruled against the charity for its “offensive” cinema ad.
  2. The ad must not appear again in its current form,” said the advertising regulator. GambleAware must, the ASA added, “avoid using similarly offensive and distressing material in their future advertising.”
  3. The ASA ruling: https://www.asa.org.uk/rulings/responsible-gambling-trust-a17-381656.html.

Cover-up undermines credibility of GambleAware

  1. Here I describe a cover-up by GambleAware, the leading gambling charity, that undermines its credibility.
  2. GambleAware, formerly called the Responsible Gambling Trust (registered charity number: 1093910), is a national charity “committed to minimising gambling-related harm.” It does this by funding research, education and treatment services. Funded itself by donations from the gambling industry, the self-styled independent charity works closely with the industry – too closely for critics. I first wrote about GambleAware on 27 February 2017, identifying four main problems with the charity. Here’s another: it recently instituted a cover-up.
  3. On 28 March 2017, GambleAware published a news item on its website, entitled “Evaluation of MOSES” (screen shot in Figure 1). MOSES is the Multi Operator Self Exclusion Scheme for betting shops, a national scheme run by Multi Operator Self Exclusion Scheme Ltd (registered company number: 10269436). The company in turn is a wholly-owned but self-styled stand-alone subsidiary of the Senet Group (registered company number: 09310491).

    Figure 1. GambleAware news page at 30 March 2017

  4. Anyone wanting to control his or her high-street gambling can, with a single phone call to MOSES, register an initial wish to self-exclude from a self-selected group of betting shops, regardless of operator (self-exclusion.co.uk). A photo is required, which is shared with the relevant operators “to help staff recognise someone who has self-excluded and intervene if he or she breaches that undertaking.”
  5. The Senet Group is “an independent body set up to promote responsible gambling standards and ensure that the marketing of gambling is socially responsible,” says its website. Membership is open to “any gambling operator, and any associated organisation.” On 28 March 2017, the Senet Group, too, announced the MOSES evaluation on its website (screen shot in Figure 2). Its news item linked to the press release on the GambleAware website.

    Figure 2. Senet Group news page at 30 March 2017

  6. The GambleAware press release states that the charity had commissioned the evaluation of MOSES. The evaluation was carried out by company Chrysalis Research UK Limited (registered company number: 07375791). I didn’t understand why the original version of the Chrysalis Research report the charity published didn’t refer to GambleAware at all, astonishingly.
  7. On 29 March 2017, I therefore emailed the report’s author, Louise Duffy, seeking an explanation for the omission of GambleAware in her report. She’s a director of the research company. Having heard nothing, I sent a reminder a week later. This time Ms Duffy replied, on 6 April 2017, saying only: “Apologies for the delay. The published report does now have the acknowledgement in it and is attached here for your information.”
  8. The next day I pointed out in an email that she hadn’t explained, though, why the original version of the report didn’t refer to GambleAware at all. On 10 April 2017, Ms Duffy wrote: “It was an oversight on our part and we should have included that it was commissioned by GambleAware, hence the amendment made.”
  9. I wanted to be clear: did GambleAware really commission the evaluation, as stated in the accompanying press release? A related question is: what exactly is the relationship between the charity and the Senet Group anyway? I shall explain why the relationship is so important in a later post.
  10. The original version of the report was dated 23 March 2017 on the front cover. The file creation date in the file metadata as well is 23 March 2017 (screen shot in Figure 3). Here’s the original version, downloaded from the GambleAware website on 29 March 2017: jn175-moses-evaluation-final-report-230317.

    Figure 3. Original version of report: PDF document properties

  11. The revised version, though, remains dated 23 March 2017 on the front cover, which is misleading and dishonest, or could be perceived as such. The file creation date in the file metadata, meanwhile, is now later – 30 March 2017 (screen shot in Figure 4). Here’s the revised version, downloaded from the GambleAware website on 7 April 2017: jn175-moses-evaluation-report-final-report-230317.

    Figure 4. Revised version of report: PDF document properties

  12. At date of publication the report linked to on the charity website is the revised version I downloaded on 7 April 2017.
  13. There’s no record in the revised version that it’s actually been revised, which again is misleading and dishonest, or could be perceived as such. Similarly, it’s misleading and dishonest, or could be perceived as such, that the revised version fails to explain the reason for the changes.
  14. What’s worse, GambleAware simply swapped the files in the news item dated 28 March 2017 – again misleading and dishonest, or could be perceived as such. Thus the charity hid the change of files (screen shot in Figure 5).

    Figure 5. GambleAware news page at 7 April 2017

  15. I asked Iain Corby at GambleAware in an email why the charity had failed to document on its website the fact that it’d swapped the files – and when. Also, the reason for doing so. Accuracy and transparency, I added, are essential for public trust and confidence in GambleAware and its work. Mr Corby, now deputy chief exec, simply said in his response: the “researcher corrected a minor error.” He said nothing about the charity hiding the change of files. Mr Corby also told me he wasn’t prepared to answer any further queries from me. (I’d explicitly acknowledged him in my 27 February 2017 post for being responsive and willing to engage in discussion. I also phoned then to thank him verbally.)
  16. ADDENDUM: On the subject of self-exclusion, a GambleAware trustee has seemingly failed to declare a relevant interest on the online trustee register of interests. I refer to Clive Hawkswood (screen shot in Figure 6), who is sole director of company The National Online Self Exclusion Scheme Limited (NOSES; registered company number: 10504973), too, according to Companies House records. The company is creating and will operate NOSES, an equivalent self-exclusion scheme for online gambling.

    Figure 6. Trustee Clive Hawkswood’s declared interests at 30 March 2017

  17. On this point Mr Corby said in his email: “Clive Hawkswood’s interest with the RGA [Remote Gambling Association], which is developing NOSES, is already registered.” True, but Mr Hawkswood is sole director of The National Online Self Exclusion Scheme Limited: his role at the company should surely be declared for full disclosure.

GambleAware: The problems with the charity for problem gambling that undermine its independence and credibility

  1. Here I show that GambleAware, the leading gambling charity, isn’t nearly transparent enough – despite being one of the most transparent charities. The fat-cat pay of the new chair – her salary is nearly 70 per cent higher than the figure in last year’s job ad – and her failure to disclose in full personal interests, too, risk damaging the charity’s reputation. The role of Atlas Communications Partners Ltd (trading name: Atlas Partners) is a serious concern. The firm handles media enquiries for GambleAware. Yet the charity also uses Atlas Partners as a political lobbyist, the latest statutory Register of Consultant Lobbyists reveals. The charity website fails to disclose the firm’s function as political lobbyist. Given how close GambleAware is to the gambling industry, there’s an urgent need for the charity to prove that it isn’t actually lobbying for the industry. Finally, the composition of the board contravenes GambleAware’s stated policy on the proportion of trustees from the gambling industry.
  2. GambleAware, formerly called the Responsible Gambling Trust (registered charity number: 1093910), is a national charity “committed to minimising gambling-related harm.” It does this by funding research, education and treatment services. Funded itself by donations from the gambling industry, the self-styled independent charity works closely with the industry – too closely for critics. In a move to bolster independence and credibility, GambleAware appointed an independent chair, Kate Lampard, in June 2016. Unlike predecessor Neil Goulden, Ms Lampard has no known links with the gambling industry. Last November the charity published its new five-year strategy, which aims, among other things, to treble the number of people treated each year who suffer from gambling-related harm.
  3. There’s a glaring omission in the new strategy: the fundraising chapter, 6, fails to mention donation of services. It covers donation of money only. We know, though, that GambleAware receives donated services, according to the latest accounts, for financial year ending 31 March 2016 (and in previous years). More about the inadequate financial reporting of the donated services in a moment. But first I must explain why the omission in the new strategy is such a concern.
  4. Donation of services is fundamentally different from donation of money, conceptually and operationally. For any charity, both have their own advantages and disadvantages. GambleAware openly and readily acknowledges that it needs to counter the perception that it’s too close to the gambling industry. But a company donating services is necessarily nearer to the charity than a simple money donor, which is more removed. Clearly, GambleAware needs to be particularly careful about what companies it accepts donated services from and how, if it’s to uphold its independence and credibility.
  5. So what companies did the charity receive donated services from, according to the latest accounts? Unfortunately, the reader isn’t told; but there’s an itemised breakdown of the three gifts in kind: boardroom hire £11 000; exhibition space £5 000; and software £558. To its credit, GambleAware promptly identifed the three companies on request. Law firm Gordon Dadds LLP made its boardroom available for the regular meetings of the board of trustees, while events company Clarion Events Ltd gave the charity a free stand at the ICE exhibition, an event for the gambling industry. But working with both organisations in this way raises serious questions about the charity’s independence and credibility.
  6. Betting and gaming is a speciality of Gordon Dadds, as its website makes clear. There it trumpets its “involvement in the ongoing modernisation of the UK’s gambling laws,” which “means we have unrivalled knowledge of the latest developments…” (http://www.gordondadds.com/service/gaming-betting/) By accepting the gift in kind from lawyers for the gambling industry, GambleAware risks undermining its independence and credibility.
  7. It’s a shame, too, that the latest accounts don’t disclose Gordon Dadds as source. The lack of transparency invites suspicion: is the charity trying to hide the role of the law firm?
  8. On gaming, Clarion Events isn’t only responsible for the ICE Totally Gaming event, as its website makes clear. There it proclaims: “Clarion Events occupies a unique position in the [gaming] sector, providing the full range of services to the entire spectrum of the global industry including exhibitions, conferences, technical training, research and digital information.” (http://clarionevents.com/sectors/gaming/) So again, by accepting the gift in kind from an events company so involved with the gaming industry, GambleAware risks undermining its independence and credibility.
  9. And again, the failure in the latest accounts to disclose Clarion Events as source is disappointing.
  10. In another revealing omission, the list of supporters on the charity website shows donors of money only: neither Gordon Dadds nor Clarion Events appear in the 2015-16 list (Figures 1-2). Iain Corby, Director of Operations and Development at GambleAware, agreed in an email that donors of services, too, should appear in the list. He added: “I will raise this with our fundraising director as a suggestion.”
    Figure 1. GambleAware 2015-16 supporters: no Gordon Dadds LLP at 27 January 2017

    Figure 1. GambleAware 2015-16 supporters: no Gordon Dadds LLP at 27 January 2017

    Figure 2. GambleAware 2015-16 supporters: no Clarion Events Ltd at 27 January 2017

    Figure 2. GambleAware 2015-16 supporters: no Clarion Events Ltd at 27 January 2017

  11. Though GambleAware defended its failure to consider donation of services in the new strategy: the “vast majority” of donations are of money, said Mr Corby, “donations in kind are not at all material at present so did not merit mention in our strategy.” Nevertheless covert, back-room arrangements don’t engender trust and confidence. The charity simply can’t afford to be perceived as being too close in any way to the gambling industry. GambleAware should therefore surely be open and transparent about BOTH fundraising routes.
  12. But it isn’t just the new strategy that’s deficient in this way. The donation form on the website is for donation of money only. And there isn’t a separate form for donation of services. Again, the charity’s reputation can only be enhanced by making the process to donate services clear and transparent. Hiding the process, whatever it actually is, only invites suspicion.
  13. The presentation of the donated money in the latest accounts, too, is inadequate. There isn’t an itemised breakdown this time: the reader is unable to see which company has given what. This inadequate disclosure is even worse in light of Ms Lampard’s recent interview in the FT newspaper, headline: Gambling companies ‘taking the mickey’, says charity chief”: https://www.ft.com/content/9f6440fe-9b93-11e6-8f9b-70e3cabccfae. (Published in the print edition: 29 October 2016.) There the new chair lambasted unidentified companies for failing to give as much as the charity believes they should. Well, we just have to take her word for it. Here the list of supporters on the website doesn’t help either, as donation size isn’t disclosed. I don’t understand why the donation form doesn’t ask for permission to publish donation size. The data should surely be public. Why is the charity acting against the public interest by failing to publish the donation sizes?
  14. In response, Mr Corby said in an email: “it would be exceptional for a charity to publish the amount of individual donations.” Yet GambleAware does already – for donated services, as money equivalents (see para 5). The charity’s case for more support from the gambling industry would be more convincing if the data were public: that way anyone could see the donation sizes for themselves. Also, this transparency would bolster the charity’s independence and credibility.
  15. Something else to notice in the FT report: there Jim Mullen, chief executive of bookmaker Ladbrokes, rejected claims that the fixed odds betting terminals in high street betting shops are dangerous or addictive. He was responding to concerns about the notorious machines raised in part by Ms Lampard in the interview. Since then Mr Mullen has become a trustee of GambleAware! His appointment to the board in January is only the latest manifestation of the close ties between the gambling industry and the charity.
  16. Then there’s the fact that Ms Lampard is paid in her role – a lot. Remember: most charity trustees are volunteers. She works six days a month as chair of trustees, Mr Corby told me in an email. In January 2016, the post was advertised in The Sunday Times newspaper with a salary of c. £30 000 pa for this number of days a month: http://appointments.thesundaytimes.co.uk/job/449842/chair/. Yet Ms Lampard receives nearly 70 per cent more – £50 000 pa. Her fat-cat salary is revealed in the minutes of the board of trustees’ meeting that took place on 5 May 2016. (GambleAware publishes board minutes on its website.) £50 000 pa for six days a month is equivalent to £183 333 pa full-time, if the average number of working days in a month is 22. The full-time figure is well above £150 000, then, the government threshold forhigh earners” in the public sector; the Cabinet Office names all such individuals.
  17. On Ms Lampard’s high pay, Mr Corby said in an email: “Trustees received advice that the likely market rate for the appropriate candidate would be in a range of £30 000 to £50 000 for up to six days a month. During the recruitment process, it became clear that it would be necessary to pay up to £50 000 to attract the skills, experience and public reputation required. The Charity Commission were asked for and gave its permission for the payment of a trustee to act as chair in full knowledge of the amount involved.” Still, Ms Lampard is paid proportionately more than the prime minister – and most charity trustees are unpaid.
  18. GambleAware commendably publishes a trustee register of interests on its website. In further good practice, the charity asks trustees to declare “their interests in general (not only those with a potential for a conflict of interest).” And each trustee must also declare the interests of “close relative/household members.” So it’s disappointing that Ms Lampard fails to disclose in full personal interests. She’s declared “none” for the interests of “close relative/household members” (Figure 3). According to Who’s Who 2017, the chair is married to Hon. John Leigh-Pemberton. He’s a vice president of national charity The Country Trust (registered charity number: 1122103) (Figure 4). His position there should surely be disclosed by Ms Lampard.
    Figure 3. Kate Lampard's declared interests at 31 January 2017

    Figure 3. Kate Lampard’s declared interests at 31 January 2017

    Figure 4. Hon. John Leigh-Pemberton: a vice president of national charity The Country Trust at 10 February 2017

    Figure 4. Hon. John Leigh-Pemberton: a vice president of national charity The Country Trust at 10 February 2017

  19. In response, Mr Corby said in an email: “Trustees are required to declare relevant potential conflicts of interests in line with Charity Commission guidance which is provided to them all upon appointment (https://www.gov.uk/government/publications/conflicts-of-interest-a-guide-for-charity-trustees-cc29/conflicts-of-interest-a-guide-for-charity-trustees). The Country Trust’s website states that The Country Trust help children to learn and experience food, farming and the countryside. I find it very hard to imagine a situation where GambleAware would in any way have dealing with this Trust.” Perhaps, but that’s not the point. GambleAware trustees should declare “their interests in general (not only those with a potential for a conflict of interest),” according to the online trustee register of interests.
  20. The role of Atlas Communications Partners Ltd (trading name: Atlas Partners) is a serious concern. The firm handles media enquiries for GambleAware (Figure 5). Yet the charity also uses Atlas Partners as a political lobbyist, the latest statutory Register of Consultant Lobbyists (October to December 2016) reveals. The charity website fails to disclose the firm’s function as political lobbyist. Although the published board minutes document last year’s appointment of Atlas Partners, they don’t explicitly refer to political lobbying, either. Given how close GambleAware is to the gambling industry, there’s an urgent need for the charity to prove that it isn’t actually lobbying for the industry.

    Figure 5. Atlas Partners: media contact for GambleAware at 6 February 2017

    Figure 5. Atlas Partners: media contact for GambleAware at 6 February 2017

  21. On the hidden lobbyist, Mr Corby said in an email: “I do take your point that, because we only list Atlas as a contact number for journalists, our website may not make it clear that Atlas have a wider brief than just media management, so I will add something to that effect.” He added: “GambleAware does not lobby on behalf of the gambling industry. Atlas Partners does not work for any gambling industry organisations, because these would be considered a conflict with their work for GambleAware.” So that’s alright then. Nevertheless Ladbrokes’ Mr Mullen isn’t alone on the board: half of the current trustees, five of the ten, hold senior positions in the domestic gambling industry! What’s more, the composition of the board contravenes GambleAware’s stated policy of “maintaining only a minority of trustees with any direct interest in the gambling industry” (trustees’ annual report with the latest accounts).
  22. ACKNOWLEDGEMENT: I’m grateful to Iain Corby, Director of Operations and Development at GambleAware, for being responsive and willing to engage in discussion.