More Double Standards

## More Double Standards – Lottery – iGB

One of the most frequent criticisms aimed at the gaming sector is its tendency to target individuals with limited financial resources. We frequently hear about the worst culprits being UK betting firms, writes Jon Broomfield.

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More Double Standards
Every business strives to reach the largest possible customer base. I’m not suggesting this is inherently positive or negative, it’s simply the nature of things. You’ll also find a higher concentration of inexpensive, unlicensed stores, kebab shops, and charity shops in these areas, alongside a lower presence of upscale grocery stores. Wealthier neighborhoods tend to have more upscale grocery stores and fewer betting shops… it’s just how things operate.

However, the National Lottery has somehow never been included in this conversation.

It serves as a prime illustration of how gambling has become commonplace. Their initial advertisements focused on the theme: “Transform your life for the better, win the lottery!” They’re still permitted to advertise in The Guardian, indicating its complete acceptance by the middle and upper classes.

Why am I emphasizing the lottery? Because the rules are not equitable, and recent developments suggest that things are unlikely to change in the near future.

The National Lottery Exemption
The government has recently announced its consideration of a new tax on gambling, where everyone would be required to contribute. These funds would be allocated towards research, education, and treatment (RET) of gambling issues.

The Arts Minister, Lucy Fraser, declared that they are taking further actions to safeguard those most susceptible to gambling and are implementing a new levy on gambling businesses to finance treatment and investigation.

“All gambling businesses must take accountability,” she stated. “This discussion is a chance for the industry, medical professionals, those impacted by gambling, and the broader public to voice their opinions on the suggested method of taxing gambling operators.

“The implementation of the tax will bolster the safety net and assist in achieving our long-term objective of building stronger communities, while enabling millions to continue gambling responsibly.”

However, her statements don’t entirely align with her genuine intentions. The phrase “all gambling businesses will be required to contribute their fair share” does not encompass the National Lottery. For reasons unknown, the National Lottery is not regarded or treated as a gambling operator, despite being the largest operator by far. Naturally, allocating funds to worthy causes is a positive development – it also relieves the government of the burden of finding ways to alleviate the cost of living. So everyone benefits, right? Not quite.

Because the lottery is not simply a lottery draw. Retail outlets also sell scratch cards, which are an entirely different matter.

Where is the issue with this type of wagering? Where should I even start? In the *Journal of Gambling Issues*, Dr. Mark Griffiths, Professor of Behavioral Addiction at Nottingham Trent University, writes that scratch cards are a “tough” form of gambling.

This “tough” classification places them alongside roulette and blackjack, not the casual, harmless games we might be led to believe they are.

The ease of access to scratch cards
Lotteries themselves, despite having numerous accompanying games, are definitely gentle gambling – the low event frequency ensures this. Even the UK’s accompanying games follow this pattern.

But scratch cards? They are often designed to imitate fruit machines or similar machines, which feature “the potential to lead to excessive gambling, regardless of the gambler’s personality, surroundings, or genetic makeup. These features include the ability to generate a psychologically rewarding experience in the face of financial losses – particularly the near-win experience,” says Professor Griffiths.

So, what is the major concern? It’s a combination of normalization and sales locations. There are over 6,000 retail betting companies in the UK; about one betting company per 10,000 individuals. Yes, I know, they are not distributed by population/proportion. This is simply to illustrate the idea.

The National Lottery has over 43,000 sales points, all of which sell scratch cards.

The Camelot Lottery organization boasts that a vast majority of UK citizens reside or work within a short distance of a National Lottery sales location.

I attempted to obtain data categorized by population groups and location, but as expected, this request was denied. The rationale provided was that divulging more detailed, commercially sensitive sales data could enable rivals to target specific regions of the UK for marketing purposes, which would harm Camelot’s primary goal of maximizing contributions to charitable causes.

Or, to put it more plainly, it would hinder Camelot’s ability to sell more lottery tickets.

The primary objective of any gambling enterprise is to generate revenue; anyone who claims otherwise is speaking utter nonsense. The charitable aspect is merely a tactic employed by lottery operators to circumvent the stringent regulations that the rest of us must abide by.

Safeguarding Young People
Withholding this information also avoids scrutiny of the proliferation of sales outlets in various areas because, I’m taking a chance here, I’d wager it reflects the concentration of retail gambling businesses and is disproportionately higher than them.

Camelot emphasized their efforts to ensure retailers adhere to legal requirements, such as not selling to minors and demanding identification, which was quite impressive.

A representative communicated with me electronically, stating: “Although National Lottery games differ significantly from those offered by the broader gambling sector, we and our retail partners must persistently strive to hinder underage and excessive participation.

“For instance, in the fiscal year 2022-23, we executed over 11,600 inspections of retail outlets as part of ‘Operation 18’ – which employs individuals over the age of 18 but with a youthful appearance – to prevent retailers from unwittingly violating the law during test visits. If a retailer fails three covert shopping assessments, their National Lottery terminal will be suspended and likely removed.

“I am delighted to announce that in the 2022-23 ‘Operation 18’ mystery shopper program, an unprecedented 92% of National Lottery retailers correctly requested identification on the initial visit – showcasing their unwavering dedication to selling National Lottery games responsibly. This achievement is particularly noteworthy considering that the minimum age for participation in the National Lottery was only recently increased from 16 to 18 in 2021.”

**Potential for Unhealthy Practices**
The representative continued: “As part of our dedication to promoting responsible gaming, we have a variety of other training programs. For example, in the fiscal year 2022-23, our retail team established over 160,000 connections with National Lottery retailers through phone calls, in-person visits, and electronic correspondence – providing them with guidance on preventing underage participation and the most effective methods for supporting healthy play within their stores.”

The National Lottery asserts they’ve taken more steps than many gambling companies to encourage responsible gaming. This includes over 4,000 visits to stores to inform vendors about potential signs of problematic gambling. They also educate retailers to spot “unhealthy” actions.

However, Professor Griffiths notes that scratchcards, a National Lottery product, are especially susceptible to addictive behavior due to their repetitive nature, quick payouts, and low price. This contradicts the National Lottery’s assertion that their games are distinct from those offered by the broader gambling sector.

The National Lottery representative maintains that the risk of addiction linked to their games is very low due to their safety measures. However, this argument appears flawed when considering the addictive potential of scratchcards. Including the National Lottery in RET taxes would be a reasonable step to recognize the similarities between their games and other forms of gambling.

Nevertheless, I was taken aback to discover I was in complete accord with the Gambling Commission’s perspective. After the release of the RET consultation announcement, they stated: “We believe [taxation] ought to be applied to all operators, encompassing the National Lottery, without negatively impacting charities, who are not impervious to problem gamblers utilizing their products (such as scratchcards and instant win games).”

But I doubt anyone has specifically researched scratchcards, and considering the nature of retail and players, I doubt there’s any method to monitor risky behavior with this kind of game.

Envision the potential for good if the National Lottery was included in the RET tax, and if their extensive sales network was fully engaged, and a tax was imposed on all game types?

As I frequently mention, if it’s a problem, it should be addressed as a problem. Don’t selectively choose because you have a preference.

Jon Bluford has been involved in the gambling industry for over 17 years, serving as Executive Editor of International Casino Magazine and currently as Publishing Director of Gambling Room, collaborating with Kate Chambers and Greg Saint. He owns a large canine companion with a sensitive digestive system, and he dedicates his leisure time to learning how to remove stains.

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