Bingo Association AGM 2024 - Andrew Rhodes speech
10 May 2024Speech by Andrew Rhodes
This speech was delivered by chief executive Andrew Rhodes at the Bingo Association Annual General Meeting (AGM) 2024 on 9 May 2024.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Thank you for that introduction and thank you everyone. It is great to be back with you at the Bingo Association AGM and to have a chance to update you on the Commission’s work. Since I last spoke at your AGM, we have seen the Gambling Act Review White Paper published and had twelve months to push forward with its implementation. So I’ll give you an update on that important work, highlighting areas that are of particular interest to Bingo.
I’ll touch on our work with Department for Culture, Media and Sport (DCMS) and their work to implement the White Paper and I’ll discuss our efforts to work collaboratively more widely as well. A large part of delivering the Government’s White Paper is also about getting better data and better evidence about gambling in Great Britain. So I’ll discuss what this means and why the Commission is so determined to push on in this area. Given our new Corporate Strategy was published last month, I’ll also look a bit further into the future as well. But first, back to the here and now. Where are we with the Gambling Act Review.
I do not think anyone would argue that we were all waiting a little while for the White Paper ahead of its publication in April 2023, just over a year ago. And ever since its publication, I and my team at the Commission have been clear that its implementation will not be a matter of a few months work, but will be with us for a number of years. That is okay. The White Paper and the Government policy it contained was a signal moment for gambling in Great Britain and a once in a generation opportunity to deliver positive change for gambling across England, Scotland and Wales and for all people impacted by it. So getting the implementation of it right is vital.
For our part at the Commission though, that doesn’t mean that we will not deliver at pace. By the time we published our first round of consultations last Summer we had already delivered on a couple of commitments in the White Paper. Since then we have published a second round of consultations and made great strides on improving the evidence base. We are also looking forward to publishing another consultation this Summer as well. More on that later.
Those consultations last Summer included the topic of Financial Risk Checks that drove so much coverage and interest. As a result, it took us longer to respond to them. Some people still seem to be surprised, but we do study and consider every response to our consultations and each one helps us form a view and take the final decisions that we publish. But I am pleased to say we have now published the responses to those consultations last week.
Whilst many of you have online facing parts of your business as well, for those of you who are primarily or exclusively offering bingo in bricks and mortar clubs up and down the country, the responses that you should pay most attention to are probably the tightening of age verification, the extension of roles needing personal management licences and changes to direct marketing. In particular on age verification, we are introducing new rules which mean all gambling land-based licensees, including smaller licensees, must carry out age verification test purchasing.
It will also change the good practice code to say licensees should have procedures that require their staff to check the age of any customer who appears to be under 25 years of age, rather than under 21 years of age. These new elements of the Licence Conditions and Codes of Practice (LCCP) will come into effect at the end of August 2024.
More widely, we are staggering the implementation of the changes from these consultations with implementation in five stages starting in August 2024 and running through to February 2025.
I also wanted to highlight a further change that, whilst important has not caught the attention like some of the other changes I have spoken about. That is the changes we are making to our Regulatory Returns. This is the core data that all of you as gambling businesses have to provide to us each year and recently we announced we are moving to collect this data quarterly from all operators instead of the previous set up that only asked for data annually for many operators. At the same time we are also reducing the number of questions operators have to answer. These changes will come into force from 1 July 2024 for all licensees.
What this means is that the first set of quarterly regulatory returns – those relating to the quarterly return period 1 July 2024 to 30 September 2024 - must be submitted by all licensees by 28 October 2024. If anyone hearing this or reading it later has questions, get in touch with us. We want to get this right. Later this year and likely this Summer, we will be publishing the next round of consultation responses and then moving forwards with a third consultation, this time focussing on land-based sectors entirely. But this work is not operating in a vacuum and so the exact timings will to some extent be dependent on other work elsewhere.
And I think this is a fair point to reflect on the strength of our collaboration with our sponsoring department, DCMS, and we will continue to do so. Given the range of issues that DCMS has also consulted on it is important that the implementation of changes is done in a managed and co-ordinated way. So we are working closely with our colleagues in the Department to finalise the publication dates for next steps on all of these White Paper proposals.
An area where DCMS are responsible for the implementation of the White Paper that I know, speaking to Miles, is of interest to you, is the Statutory Levy. As I say, DCMS are fully responsible for how this will look and we look forward to seeing their response on this consultation, as I know you do too. What I can say is that the Gambling Commission remains committed to working with Government, operators and everyone in the Research, Treatment and Prevention sectors to make this work. And that is important. When Government sets out the timetable for the introduction of the Levy everyone will need to pull together to get it established. It will be important to provide certainty for the people up and down the country who rely on those services as well as for the organisations and charities that provide them.
The importance of pulling together to achieve outcomes we can not alone is, of course, something you have likely heard me talk about before. At the Commission we want a constructive relationship with the industry we regulate. Where we can we want to be able to collaborate with you, in good faith, to make quicker progress than we could by relying on our formal powers alone – extensive as they are.
For our part, myself, my senior team and everyone else at the Commission are looking to move the dial towards a more constructive, grown up relationship with you. We are currently running a pilot on how our Operations teams – Compliance and Licencing in particular – can work with operators on account management. Actively setting up better ways for us to communicate with you and hear what you have got to say about the fundamentals about your business in return. I have held roundtables with operators and various land-based sectors, including Bingo, and will continue to do so, giving you and the Bingo Association a place to raise issues directly with me and my Executive team. And we have committed to being out there meeting you, visiting your businesses and seeing your impact for ourselves more than before too. Last financial year, myself and my senior team had over 250 meetings and visits with stakeholders, the largest proportion of those being with gambling companies. So we are committed to this approach. But we can only pursue this whilst industry compliance is meeting our level of ambition.
Over recent years you do not need me to tell you how many headlines we have seen about enforcement cases and negative stories about the conduct of some in the industry. What we are seeing today, compared to previously is a very significant increase in the number of larger operators in particular being found to be compliant at the point of their assessment by the Commission. What we saw last year was the rate of operators achieving compliant first time outcomes in our assessments more than doubled and the compliance rate of the largest operators has almost trebled in the past 2 years.
So we are making progress and that needs to continue. But a more grown up relationship, does not mean things are always easier. Often it means you just have the space to tackle even more difficult issues, which have no shortage of in the delivery of the Government’s White Paper.
One of those more complicated issues that I mentioned is arguably how we improve the evidence base around gambling in Great Britain itself. For the Commission this is complicated because it takes a lot of work and expertise to look at how the types of data we want to collect can be obtained and then how to best review it, present it and make it available to stakeholders like you, the public and the research community as well. For some, the complication appears to come from what any change in what statistics tell us may mean for how they, or others, see the world.
Now I think it is a fairly uncontroversial thing to say but at the Commission we are certain better evidence - better data - will lead to better regulation of the gambling sector. The better our evidence the better decisions we can make. This in turn, will lead to better outcomes for everyone involved: consumers and operators included.
So making sure we strengthen the evidence base as much as we can is an important piece of work for the Commission. Last year we published our three-year evidence gaps and priorities project, highlighting six key areas where we want to see more research. They are:
early gambling experiences and gateway products
the range and variability of gambling experiences
gambling-related harms and vulnerability
the impact of operator practices
product characteristics and risk
illegal gambling and crime.
In March we held a one day conference titled ‘Better Evidence, Better Outcomes’ that took a closer look at some of these areas as well. You will continue to hear more from the Commission on this as it progresses. But we also shared at the conference detailed updates on our new methodology for participation and prevalence statistics that we have called the Gambling Survey for Great Britain (GSGB).
The GSGB - as we have inevitably started calling it - started its development via a consultation way back in December 2020. Since then we have invested significant resources - money, people and time – and worked alongside experts in the field, to develop the best consumer gambling survey that we can. Through our stakeholder engagement panels we have also made sure to keep industry, those with lived experience, academics and policy makers and others informed at every step of the journey. This of course included the Bingo Association and I want to thank Miles for the constructive engagement on this topic we have had.
We also commissioned Professor Patrick Sturgis, Professor of Quantitative Social Science at the London School of Economics, to undertake an independent review of the Gambling Survey for Great Britain methodology. This was published in February. Professor Sturgis has some key recommendations for the Commission to consider to ensure the quality and robustness of the statistics continues to build confidence and we will deliver against those. We are of course pleased he has described our work developing this methodology as ‘exemplary in all respects’, but we also note the risks he identified in having a new methodology and the caution that should be applied when seeking to draw precise conclusions, including the potential for the over-reporting of participation and prevalence of harms as the survey is refined over time. He has been equally clear though that persisting with the current approach is not viable.
Some of you may be worried that the new methodology, when it reports for the first-time, official statistics on the impacts of gambling this Summer, may have negative consequences. Now, as I said, we note the risks and will provide full briefing to the media, stakeholders and publish guidance on how the new data should be used or interpreted. And of course, we will continue to develop the GSGB over time. But there is no turning back the clock on this and nor should there be. Professor Sturgis makes clear, previous methodologies are no longer delivering like they used to. It simply is not credible to persist with a methodology that is outdated and has the gaps in evidence we have experienced. The Commission has taken the steps we have in order to both safeguard and improve our data and we will continue to do so.
Before I finish, when we were discussing today’s event, Miles made an observation that - whilst a serious point - made me smile in how he put it. I hope you do not mind Miles but I wanted to share it before I answer the question it contains. Miles asked: “Will there be a ‘peace dividend’” or a “a period of relative quiet and reflection soon or are we on the treadmill of continuous change for good and is this the new reality?”
The first thing I would say to answer this is to point to our new Corporate Strategy, that was published last month. In addition to continuing to deliver our core regulatory work, over the next three years, the Strategy presents a series of commitments under the following areas of strategic focus:
using data and analytics to make gambling regulation more effective
enhancing our core operational functions
setting clear evidence-based requirements for licensees
being proactive and addressing issues at the earliest opportunity
regulating a successful National Lottery.
And our approach to stakeholder engagement runs through the strategy throughout. Delivering these commitments will ensure that we improve the way we work to ensure gambling is safer, fairer and crime-free for the benefit of consumers, the wider public, and licensees. But whilst it contains important steps forward across these areas of focus, I would not say this is ushering in a further era of regulatory change. Alongside our Business Plan for the current year, it is very much focussed on continuing to implement the White Paper. That is because we know we are in a period of pretty full on change at present. Having waited a little while for the Government’s White Paper we are all now racing to implement it. Trust me, I and my team at the Commission understand the pressure that creates for you.
It is of course difficult to predict anything like this. We all know we are less than twelve months from a General Election and I know you are hearing from Shadow Minister, Stephanie Peacock MP, later on. We also know that circumstances can change quickly, so it would be foolish to make any strong predictions.
We are fully focussed on the implementation of the Review, but as things stand today, the Commission itself does not expect the pace of change that we are experiencing this year to be a ‘new normal’. Nor would that be good for regulation. The Commission and DCMS are fully committed to the evaluation of the changes made as a result of the Gambling Act Review, so we will evaluate the reforms that are in the process of being implemented now. That is not to say we will not consult on changes to the LCCP going forwards. We absolutely will where we see a need, but I do not think we are on the treadmill you describe Miles.
So I’ll end it there. Thank you for your time today and I am looking forward to any questions you may have for me. The Gambling Commission is fully committed to the implementation of the Gambling Act Review and building a more constructive relationship.
Thank you.
Last updated: 10 May 2024
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