Why commercial and safer gambling interests don't need to clash

It was surprising to be subject to a Twitter thread which debated the rationale and suitability of my new role at Oddschecker Global Media. The thread explored the perceived conflicts between a firm’s commercial ambitions and its efforts to create an online environment which fosters safer gambling.

A gambling affiliate’s commercial and safer gambling interests need not be at odds with one another. While working in the City in the aftermath of the great financial crisis, I remember clearly the preponderance of compliance professionals who emerged and multiplied from the ashes. Traders complained that they were no longer able to ‘swing the bat’, yet compliance teams ensured that very few would go on to ‘blow up’ – an all-too-common scenario in the early noughties where risk tolerance led to a proliferation of traders with scant regard to risk who ended up losing the lot on a bad bet, but who seemingly found it all too easy to find new employment at a rival bank.

I see distinct parallels to the gambling industry but where the consequences of such insouciance to risk would lead to far more devastating outcomes. Our industry deals with real people and the real damage that gambling-related harm can cause to the gambler, their friends and their families.

Compliance, health and safety, safer gambling. Employees in these sectors aren’t there to annoy, upset or disrupt commercial activity; they’re there to protect the very people from whom commercial performance is realised.

Commercial strategy must be more than merely EBIT accretive. It must also be sustainable – that is working towards a multi-year horizon, not just that of the next quarter. It also needs to garner buy-in from across the business. It’s no secret that there’s a stigma attached to our industry; do I tell my mates and family that I work in digital marketing or do I tell them exactly what I do? We need to work hard to ensure it’s the latter, and a set of coherent and effective safer gambling policies should allow for this.

By taking safer gambling seriously, I am confident I can deliver sustainable growth to the bottom line while also offering protection to the millions of people each month who use our products. Ten percent of UK bets are influenced by oddschecker; if we were a bookie we’d be in the big seven. That’s why affiliates shouldn’t be overlooked in the forthcoming Gambling Act 2005 review and why oddschecker via RAiG (the responsible affiliates body which we co-founded in 2019) made a submission to government following the call for evidence.

To understand how seriously RAiG are taking the review, just last week I had a meeting with Sir Iain Duncan Smith MP and Carolyn Harris MP who head up the APPG on gambling-related harm. This was a great opportunity for me to explain the role affiliates play in the betting ecosystem, and the scale at which we operate. Around one in five new players arrive at an operator’s site or app via affiliates.  Given the trust that punters bestow on affiliates such as oddschecker and the Racing Post, we made it very clear to the parliamentarians how important a vehicle a well-regulated affiliate sector is in arriving at a regulatory steady state which is safer for UK players.

As the recently departed UKGC boss Neil McArthur was all too keen to stress, punter trust in operators is at a nadir. It’s therefore a tall order to expect punters to digest messages from entities in which their confidence has been so damagingly crippled. Make no mistake about it, Sir Iain Duncan Smith and Ms Harris are not anti-gambling abolitionists; they just want to create protections for those most at risk.

Safety mechanisms

Operators are aware of this, and instead of pushing boundaries and waiting for retroactive punishment, they’re now purposively testing their systems to see if they can arrive at better outcomes. Kindred is overtly telling the City what proportion of its revenue is from ‘high-risk players’ (~4% for those who are interested), meanwhile Sky Bet is trialling mandatory deposit limits for all 18- to 21-year-olds and Flutter is testing £10 maximum stakes on slots for all their UK-facing brands. Half a million Sky Bet punters now set deposit limits.

These measures aren’t without cost – or to be more accurate forgone revenue – by way of example Entain is guiding to a £20m impact from its Advanced Responsibility & Care programme.

If operators can demonstrate that they can pre-empt problematic behaviour by discreetly intervening in the player experience (slow play, limit deposits, time outs) to avoid potential issues, it’s likely they’ll be able to avoid headline-grabbing measures which are less likely to have a meaningful impact when it comes to the end goal: the safety of UK punters.

Such activity would have seemed alien even three years ago, now it’s common practice, and it means that operators can engage with the review suitably equipped with player behavioural data, rather than nuanced anecdote and opinion.

The listed firms’ ESG ambitions are now all too obvious: pick up a 2010 annual review and compare it to 2020, it makes for startling contrast. The words safe, safer, safest and safety appeared in William Hill’s 2020 annual report 153 times – a 700% increase to the 19 references made to those same words in the 2010 iteration. Instances of ‘responsible’ have more than doubled.

This is real progress and it must be lauded but the two gaps which I hope the Gambling Act 2005 review will seek to address: first, the harmonisation of safer gambling standards and, second, the licensing of the affiliate sector.

I mentioned earlier that the trust affiliates enjoy from punters was a positive and most of the time it will be (albeit a significant responsibility too) but if that trust is misplaced and a rogue affiliate is able to send UK players to non-licensed UK entities (i.e. the black market) then the reputation of our entire sector is tarnished. We’re only as strong as our weakest link. The operators have done a great job of striking off bad actors from their affiliate programmes (Paddy Power Betfair more than halved its affiliate partner pool in 2019); now it’s the government’s turn to help banish rogue affiliates from the UK completely. Effective licensing is the only means to do this.

Blind spot

Licensing would give accredited affiliates the opportunity to access Gamstop, thus eliminating the unintentional messaging of gambling-related content to self-excluded customers. Right now, we have no visibility of a customer’s status and for me this is one our sector’s biggest blind spots.

We too are looking to develop diagnostics across our platforms so that we can identify player behaviour which we deem to be at risk and therefore warranting of intervention. We see a punter’s activity in the rounds rather than the solus operator level lens through which bookmakers must appraise behaviour and make decisions. We have a more complete picture.

Some argue that the affiliate commercial model needs to be looked at and that an ongoing revenue-share mechanic doesn’t encourage the right behaviour. I wholeheartedly disagree. Revenue share is paid on “net” revenue, so all safer gambling ‘costs’ are already deducted. As such, affiliates benefit from customers with healthy betting behaviour and, in turn, are not incentivised to chase the quick unsustainable ‘buck’ that a CPA-only model would foster, a model which is more likely to lead to the proliferation of traffic with ‘at risk’ characteristics.

The importance of affiliates in protecting punters from harm should not be overlooked and a well-regulated affiliate sector has a vital role to play in protecting the wellbeing of UK punters.

Having led the oddschecker commercial team for five years, Guy Harding was recently promoted to director overseeing the commercial strategy across the group. As a founding director of RAiG, he also spearheads oddschecker’s safer gambling efforts.