Strategy for preventing excessive play

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					23/07/04 2004 Final Strategy to prevent Excessive Play



                    Strategy for preventing excessive play

1      Introduction, Definitions & Context

    1.1 Camelot seeks to be a leader of best practice in preventing excessive play.
        This is an important element of our business strategy and our regulatory
        environment.
       We are committed to operating as a socially responsible company, meeting our
       commitments to all our stakeholders.

       Our strategy is based on relevant measurements of the immediate and potential
       harm that lottery products may do to vulnerable people.


    1.2 In the context of The National Lottery, pressure groups and professionals
        express concern in two main areas: excessive play and illegal play. This
        strategy is concerned with excessive play.

       Excessive play means

       -   gambling addiction. An accepted formal definition for gambling addiction
           is ‘A progressive disorder characterised by a continuous or periodic loss of
           control over gambling; a preoccupation with gambling and with obtaining
           money to gamble; irrational thinking and a continuation of the behaviour,
           despite adverse consequences’ (Rostenthal 1992)

       -   low income players. There is a concern that low-income players may
           spend a disproportionately large amount on lottery products so as to
           adversely impact upon the quality of their lives

    1.3 All existing assessments of problem gambling indicate that The National
        Lottery is at the least harmful end of gambling and causes few problems for
        the majority of players.

       In August 2002, The National Lottery was 16% of the gaming market.

       The National Gambling Prevalence Study published in 2000 showed that 0.8%
       of the population was classified as problem gamblers. The problem gambling
       prevalence among people who have only played The National Lottery is 0.1%.

       Number of problem gamblers as a % of people who have participated in this
       activity in the last 12 months:-

              The National Lottery main draw game           0.7%

              Scratchcards                                  1.5%

              Bingo                                         2.0%



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               Fruit machines                               2.6%

               Horse races                                  1.8%

               Dog races                                    3.7%

               Other events with a bookmaker                5.8%

            Of the calls to the GamCare helpline in 2002/3, 0.4% quoted problems
            with lottery draws and 0.2% quoted problems with scratchcards.


    2   Overall Approach
    We work closely with our stakeholders, in particular with pressure groups
    representing vulnerable people, to develop and deliver our strategy, policy,
    procedures and practice in preventing excessive play.
        The aims are:

               to promote responsible play;
               to prevent excessive play;
               to support treatment where problems cannot be prevented;
               to learn from international experience.

3       Camelot’s commitments to preventing excessive play

    3.1 Regulatory requirements

    Camelot Group plc is the operator of The National Lottery and is regulated by the
    National Lottery Commission (NLC).

    The duties of the National Lottery Commission under the National Lottery Act are
    threefold:

       To ensure The National Lottery is run with all due propriety.
       To ensure that the interests of every participant are protected (this includes
        people under 16 and vulnerable people).
       Finally, provided the first two obligations are met, to maximise the proceeds to
        the Good Causes.

    Licence Condition 9-(28)-a.) states:

    The licensee shall adopt, maintain and implement a strategy to prevent excessive
    play on the National Lottery. Such strategy shall first have been approved by the
    National Lottery Commission and shall in particular deal with game research
    and design, marketing, public information and education, accessibility, staff




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   and distributor training, monitoring and support for the treatment of problem
   gamblers.

   3.2 Related Policies & Guides

   The main policies relating to the strategy are:
      Promoting responsible play policy – developed in full consultation with
       stakeholders, this policy describes what we mean by excessive and under-age
       play and outlines our existing strategies to prevent both. This policy presents
       our approach across research, marketing and sales strategies to protect the
       image of The National Lottery and retain public and pressure group
       confidence in our social responsibility.
      strategy to prevent underage play – the strategy to prevent excessive play
       should be read in partnership with the strategy to prevent underage play which
       focuses on preventing illegal play
      community involvement policy - ‘Social Responsibility in our Industry’ is one
       of our focus areas within our Community Involvement Policy. We are
       committed to help tackle the need for people to play responsibly. This might
       include :
          supporting research on gambling addiction;
          education in youth clubs and schools about responsible gambling;
          supporting organisations tackling gambling addiction through prevention
           programmes and advice, guidance and counselling; and
          supporting organisations that provide debt counselling.
      Advertising and Sales Promotion Code of Practice – contains a wide range of
       measures to take player protection into account in developing our advertising
       and sales promotion strategy.
      The Player’s Guide – advises players to play responsibly and suggests players
       call the GamCare helpline if they are concerned about playing too much


   3.3 Camelot infrastructure and ownership of the preventing excessive play
       strategy

       Within Camelot the cross-functional ‘Promoting Responsible Play’ group
       develops the strategy, policies and actions governing our work in minimising
       excessive play and preventing under-age sales of National Lottery products.
       The Directors of Security, HR & Social Responsibility, Sales and Game
       Development sit on this group, along with other senior managers.
       The Director of HR & Social Responsibility owns the Preventing Excessive
       Play strategy and monitors delivery against commitments within the strategy
       and key indicators.
       Our ongoing social reporting process contains a range of indicators that
       measure our performance in this area.


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4    How Camelot prevents excessive play

    4.1 A socially responsible game research and design framework

    The Game Design Protocol provides a tool for risk-managing the introduction of
    significantly different new games. The tool enables us to classify new games as
    having a below-average, average or above-average potential for creating excessive
    levels of play among vulnerable players. We will take preventive measures
    proportionate to the level of risk. These measures include amending the game
    structure, introducing specific preventative measures or deciding not to launch the
    game.
    The product licensing procedure takes into account the need to incorporate the
    principles of social responsibility into research for game design before submission
    to the National Lottery Commission.


    4.2 Socially responsible marketing and sales strategies


    We demonstrate our commitment to the promotion of responsible play through
    our Advertising and Sales Promotion Code of Practice and Broadcast Policy.
    These were finalised after extensive consultation with the relevant stakeholders
    and reflect our socially responsible marketing strategy. We will determine all
    future advertising spending by weighing up several factors including social,
    economic and demographic considerations.



    4.3 Player information

    We carry a responsible play message in the Player’s Guide and promote sources
    of help i.e. the GamCare hotline.
    National Lottery Line staff are also able to refer callers to sources of help if they
    require this.


    4.4 Research to understand the potential for excessive play

    We also fund research from independent sources, which for example has included
    the national gambling prevalence study co-ordinated by Gamcare with support
    from the Home Office and work with Salford, Nottingham Trent and Warwick
    Universities.


    4.5 Preventing excessive play in interactive channels



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    Research indicates that in interactive environments there is a heightened risk of
    excessive play. We aim to ensure that our interactive games prevent vulnerable
    players from gambling excessively while not imposing unreasonable restrictions
    on the majority of players.
    To achieve this we will:
          build into the system a broad range of adaptable controls and warnings that
           can be set to operate at different levels or be turned off completely. The
           areas covered by these controls include:
               - limits on play, set by the player by day or week
               - opportunity to for self-exclusion from some or all games
          design the system to allow players to exclude themselves completely from
           some or all games, and also include a reporting system to enable players to
           review the way they have been gaming online;
          check with stakeholders that this new system takes into account their
           understanding of potential risk, where appropriate.

    More detail can be found in COR-P-018 Functional Requirements Specification
    Playing the National Lottery Interactive Games.


    4.6 Appropriate staff training for those who sell tickets to players

    Retailer training covers a retailer’s responsibilities in respect of under-age sales;
    provides advice on how to refuse a sale effectively without causing offence; and
    provides information on support organisations for people with gambling problems.
    It also covers excessive play, encouraging the retailer to consider the issues and
    determine the best ways of tackling problems.
    We include reminders of this training in relevant retail communications, for
    example in communication designed to remind retailers of their mandatory
    responsibilities.

    4.7 Support of problem gamblers

    We support the treatment of problem gamblers through, for example, helping
    organisations such as Gamcare and Gordon House, and we work with other
    appropriate research and support organisations.
    We also contribute to the Responsibility in Gambling Trust.
    National Lottery Line staff are able to refer callers to appropriate support
    organisations.


5      Monitoring & measuring success by evaluation and comparison

5.1 Monitoring of player behaviour

We monitor a range of indicators in the area of problem play, as follows:-



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                 Average player spend
                 Average per capita spend
                 Proportion of calls to GamCare helpline concerning problems with
                  National Lottery play

We have set upper limits on average player and per capita spend.

These are reported to the Promoting Responsible Play Group.

5.2 Measuring the awareness of and satisfaction with our strategy, policy and
    approaches among stakeholder groups

      Through our social audit, we ensure that our dialogue with stakeholders covers
      preventing excessive play and measures the success of the strategy. Stakeholder
      consultations with pressure groups, retailers and the public review the policy and
      strategy and suggest further initiatives. These consultations are undertaken at
      least annually.

5.3      Comparison against other lotteries world-wide
We provide figures to relevant studies of lottery performance world wide and we
participate in international knowledge forums to share ideas and best practice.

6 Summary

Camelot’s performance in both promoting responsible play and stemming problem
play is judged against regulatory requirements laid down under licence by the
National Lottery Commission. Our performance is reviewed by the National Lottery
Commission. We are committed to working together with the National Lottery
Commission in achieving our goals. In addition, we measure our social impact
through our social audit and report, which forms an essential part of our annual
reporting. The full performance results are available in our social report on our
internet site (www.camelotgroup.co.uk/socialreport2003).




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