How Rank Group is moving beyond standard RG practices towards a safer gambling environment

The Rank Group is one of Britain’s oldest entertainment companies, first established in 1937. Over the last two decades it has embraced a changing entertainment industry, divesting many of its leisure and film-related interests and actively pursuing a business model centred around the gambling industry.

This adaptability has led to it carving out a successful company with statutory revenues nearing £700m during the last year as it aims to become the UK’s biggest multi-channel operator. However, in the highly regulatory attuned market of the UK carving out this niche is becoming a more challenging task, not just for Rank but for any operator trying to reach the top.

A key marker in this step is using that adaptability to cope with changing regulation, something which EGR Compliance discusses with Rank Group director of responsible gambling and compliance Andrew Poole.

EGR Compliance: How has enhanced due diligence changed the way that Rank approaches compliance?

Andrew Poole (AP): Recently we have benefited from bringing central support for all due diligence work into one team, based in our Sheffield Customer Services Hub. Now the central team provides support to the whole business: performing open source checks, gathering due diligence evidence and overseeing the process from start to finish. Our casino general managers and online management team all receive clear and accurate reporting on open due diligence files and outstanding actions, resulting in a more complete and efficient process with less friction and ultimately a better experience for customers.

We’re also far better now at looking at customer risk holistically and not only through the lens of our AML responsibilities. Our customer reviews consider any indicators of problem gambling risk, the use of the various self-management tools and any interactions we’ve had with the customer. In digital, we’ve started the roll-out of modelling based on socio-economic data and demographic information to reduce our reliance on blunt financial triggers. We are working towards an environment where we can work better with customers to set bespoke limits based on affordability, helping ensure that they play within their means and at a level that is safe.

EGR Compliance: The UKGC has said operators should be ‘constantly inquisitive’ about their customers, how is Rank achieving this?

AP: The expectation here from the UKGC seems fairly straightforward: monitor for behaviour outside of the norm, either the norm for that customer or comparing that customer to the behaviour of your wider customer base. We train our teams in the importance of being curious, and always asking the question, “Does this customer’s behaviour make sense, based on what I know of them?” Delivering a consistent level of monitoring like this is, of course, complicated and requires a multi-layered approach which applies as much to our AML responsibilities as it does to our safer gambling efforts.

For safer gambling, we have monitoring and alerts based on criteria such as total deposits along with more sophisticated tools like our digital propensity model, which uses machine learning techniques to monitor for changes in individual customer risk over time. None of these, even in combination, can fully eradicate the risk that we might miss a potential problem gambling issue, but they do increase the likelihood that we’ll detect a customer earlier and be able to make an informed interaction. It remains the case that our people are our biggest asset when it comes to monitoring, especially so in our retail business where relationships are developed on a face-to-face basis; behaviour is witnessed first-hand and that information can be relayed to online colleagues.

Satisfying our curiosity to a consistent and high level or overcoming concerns of problem gambling risk is often challenging: when we engage with customers and discuss with them what we have observed, it can be difficult to accurately know that we’re getting a true picture. A problem gambler may not always be open and forthcoming when invited to reflect on their play or any potential harm they might be experiencing. In no way do we advocate waiting until a customer has incurred a loss that might cause difficulty, but it may be reasonable to believe that, until such a situation plays out, there is a possibility that they won’t be ready or willing to discuss their play or its impact upon them. None of this is simple but we act with best intentions and according to the information we have to hand, which itself is possibly only one part of a customer’s full gambling history if they are playing elsewhere too.

EGR Compliance: How does Rank approach responsible gambling across all of its online brands?

AP: We don’t significantly differentiate across our brands. A Rank customer can expect the same standard of service whether they sign up for Grosvenor or Mecca – we have the same tools, messaging and monitoring in place, and this resonates with the customer-first approach we look to deploy across our entire business; the safeguards are the same.

EGR Compliance: Do you see a point in the future where performance in responsible gambling will become as integral to egaming businesses as financial performance in sustaining long term success?

AP: Already and increasingly, safer gambling is part of ‘business as usual’ in both the mindsets and operations of colleagues across the Rank business. We have come a long way in recent years and are determined to build on these strengths to further embed safer gambling within our culture. Not so long ago, responsible gambling was ‘owned’ by the compliance and customer services teams but the advent of dedicated ‘RG’ personnel in the big gaming firms has brought a heightened level of focus on this critical part of the business.

The approach we are following at Rank is to ensure safer gambling is not a siloed subject. It doesn’t belong to a single team as ‘their’ responsibility but to the entire business. Our safer gambling strategy gives responsibility to everyone in the business – from product heads to marketing campaign heads – for delivering this successfully, rather than relying on compliance teams to oversee everything. Operators are still making that transition, as evidenced by many of the Gambling Commission workshops being filled with compliance and safer gambling personnel, rather than data scientists, marketeers and wider business colleagues who are better placed to address many of the issues our customers face.

The more we do, the more we can measure, and the more we can measure, the more we can set meaningful performance targets. As a Plc, Rank’s board, its shareholders and wider stakeholders all pay very close attention to our progress on safer gambling and customers increasingly do too – even those who never have concerns with their play. They want to play with brands they can trust. In the not too distant future, the brands who are most impressive, thorough and committed to safer gambling will realise safer gambling is an accelerator of good, sustainable custom rather than a drag on revenue.

EGR Compliance: How does Rank incorporate UKGC changes to the Licensing Conditions and Codes of Practice (LCCP) into its online platforms?

AP: Where changes to the LCCP are suitably signposted with realistic lead times, we are confident in our ability to prepare fully, allowing the business to adjust properly. Through calls for evidence and consultations, it can be possible to prepare in advance, but this is not always the case. After satisfying the compliance requirements we seek to ensure, as far as we are able, that incoming changes which are likely to have a commercial impact are managed across the business. The fairly recent ‘verification’ LCCP change arrived – after consultation – with a three-month timeline for implementation which was particularly challenging, especially given our view that we would require six months for effective and thorough implementation.

The intensity of effort required in that three-month period saw us attempt to improve the overall customer journey once we had satisfied the compliance requirements. Despite more stringent requirements, we’re arguably in a better place now than we were beforehand.

[quote]The approach we are following at Rank is to ensure safer gambling is not a siloed subject. It doesn’t belong to a single team as ‘their’ responsibility but to the entire business [/quote]

EGR Compliance: How important is it that Rank has a good relationship with the UKGC?

AP: The UKGC is the regulator and we don’t seek to cultivate any kind of relationship which could be mistakenly perceived, in any way, as preferential. Instead, what we are fully focused on is ensuring we are exceptional in our approach to compliance, as well as being a transparent and accessible operator. That is a non-negotiable position for our business. Beyond that, we have a duty to our customers, colleagues and shareholders to maximise the competitive advantage we are able to leverage through safe gambling venues, products and services.

EGR Compliance: What responsible gambling initiatives does Rank operate in its other operational areas i.e. Spain?

AP: The regulatory landscape and frameworks in Spain are noticeably different to those we work with here in the UK. As such, it is important to refrain from adopting a ‘lift and shift’ solution whereby we would simply impose the UK model on our Spanish business. Instead, we are working on a tailored programme of safer gambling work to increase our impact and effectiveness in this space. We have a positive culture and commitment to customer support and experience, and we are working hard to ensure that the differences in product and customer risk profiling in Spain are fully understood and included in our safer gambling plan.

Ultimately, Rank is an international operator with ambitions to further expand globally; we therefore want all Rank brands to offer a consistently high level of consumer protection and assurance, irrespective of geography. In Spain, the success of the initiatives we are working on will be dependent on our Spanish colleagues setting and owning their roadmap while at the same time learning from the insight we have gained in recent years from our work in the UK.

EGR Compliance: What responsible gambling led enhancements does Rank have planned for the rest of 2019?

AP: We’ve just refreshed our UK safer gambling strategy and plans, so we’re working through the detail of bringing it to life at the front line of our business. This is a significant undertaking within Rank and it has been integrated into the Group’s wider transformation programme, which will ensure the appropriate benchmarks, targets and deadlines are reached and reviewed. Never before have we been clearer about the need for every Rank colleague to own safer gambling in their day-to-day work – at every level of the business. Embedding this more deeply into the culture of Rank is at the core of the plan and will ultimately determine whether or not we are able to be even more successful in delivering a safer gambling experience to all our customers.

More specifically, we’re among a small number of land-based casino operators trialling a series of algorithms developed by the expert team at Focal Research that helps us detect potentially at-risk customers among our machine players and aim to be live across the whole estate late in 2019 or early 2020.

In the online space, we’re making good progress on affordability checks; using available socio-economic and demographic data to warn us when individual customers may be playing beyond their means. We will be refining the model in the coming months, but these are clearly important steps as we move away from a reliance on traditional thresholds based only on financial triggers, which run the risk of missing problem gambling risk at lower levels.

Centrally, we will continue to build expertise across the Sheffield team who are sitting within our frontline to field incoming and outgoing contacts in relation to safer gambling. With the launch of our Grosvenor One (G1) single account and wallet proposition, we are also confident that the visibility we require to improve our cross-channel risk management will be enhanced.

EGR Compliance: Should operators be made to make an additional voluntary financial contribution to cover the cost of problem gambling treatment in the UK?

AP: Our position with regards to funding of treatment (and research and education for that matter) has been consistently clear: we believe that currently the treatment of problem gambling in the UK is probably underfunded and we would be willing to increase funding in line with a properly scoped and costed solution provided by and delivered by expert treatment providers. Starting with the need rather than with the number is a sensible approach to such an important aspect of the industry.

EGR Compliance: What would you say was the biggest learning point from Rank’s UKGC fine?

AP: With over 8,000 colleagues across almost 150 venues, there is the possibility that more mistakes may be made and we remain keen to distinguish between individual mistakes and systemic failings.

Nevertheless, we have made substantial improvements to the safer gambling function and its role within the business. Our customer risk management, review committees and wider controls are more sophisticated, and our people are more accountable and better trained. Before we self-reported to the UKGC, we had conducted a thorough internal review to establish where we had to make improvements and had already started work on remediation. We have accelerated that process in the past year.

EGR Compliance:  Does Rank’s approach to responsible gambling change when dealing with so-called high-roller players?

AP: No. The risk of problem gambling can be equally present regardless of a customer’s relative financial status. We make no assumptions that affordability alone negates the risk of a problem. Having completed certain KYC, EDD and safer gambling checks and had relevant conversations we may, of course, be more comfortable with certain customers playing to higher levels, but this does not mean that we stop being curious or watchful for markers of harm.