Unreliable Suicide Claims in Gambling: ABSG’s Questionable Stance

The Great Suicide Deception. Part III – Conspiracy of Silence

Dan Waugh, Regulus Partners. May 2024

The Great Suicide Deception. Part III – Conspiracy of Silence

This is the third in a series of articles examining claims made by state bodies in England about rates of suicide associated with ‘problem gambling’. In the first we demonstrated that estimates of suicide mortality produced, first by Public Health England (‘PHE’, 2021) and then by the Office for Health Improvement and Disparities (‘OHID’, 2023) were irretrievably flawed. In the second, we looked at the behaviour of PHE and OHID, finding indications of a priori bias or inexplicable negligence and unsound governance. In this third article, we examine the conduct of others in positions of authority and ask why so many people who knew that PHE and OHID’s claims were unreliable decided to look the other way. We also recognise those who were prepared to apply critical analysis. Once again, we observe that, while gambling disorder has been recognised as a risk factor for self-harm for more than 40 years, efforts to tackle this are unlikely to be advanced by the use of junk science.

1. Why did the Gambling Commission not ‘do the right thing’?

By April 2022, Britain’s Gambling Commission knew that estimates of suicide mortality published by PHE were “unreliable” and based on “inaccurate” assumptions. This may have been a somewhat uncomfortable finding, given that the regulator had previously described the review as “important and independent”. It had arrived at this opinion despite not having received anything more than an executive summary (which it had not read when it agreed to provide “a supportive quote”). It also knew that PHE was far from “independent”, having been made aware of its intention to apply tobacco-style controls to participation in betting and gaming.

At a meeting in March 2022, Gambling Commission officials admitted that they did not understand how PHE had arrived at some of its estimates (no-one could have been expected to – given the fact that the calculations were mathematically incorrect). In April, these officials circulated a highly critical review of the PHE report, in which they noted that the suicide claims were not based on “reliable data”. The Commission however, elected not to take the matter up with the OHID (which had subsumed PHE upon the latter’s disbandment) or to inform the Secretary of State. The market regulator – which counts “doing the right thing” among its corporate values – elected to suppress its critique. In one rather sinister coda to the Commission’s critique, one official speculated that PHE’s claim of more than 400 suicides might be rescued, if only future prevalence surveys showed a higher rate of ‘problem gambling’ in the population. At this point, the Commission had started work on a new Gambling Survey for Great Britain in the expectation that – as a result of methodological issues – would produce a higher rate of ‘problem gambling’ than reported by tNHS Health Surveys.

 

When asked by journalists whether it considered the PHE claims to be reliable, the Gambling Commission responded that it was not its role to review the work of other state agencies; but failed to mention that this is precisely what it had done. As late as 2023, its chief executive, Andrew Rhodes continued to defend the PHE-OHID estimates, despite being aware of the problems with them; and it seems likely that the market regulator has been involved in disseminating the misinformation via approval of regulatory settlement funds.

2. the ABSG and the irrelevance of accuracy

In the summer of 2022, the OHID wrote to the Gambling Commission’s Advisory Board for Safer Gambling (‘ABSG’) to ask for its opinion on criticism of PHE’s suicide analysis. In her response, the ABSG’s chair, Dr Anna van der Gaag appeared to agree that there were indeed a number of issues. She wrote: “I see their point about basing calculations on the Swedish hospital study leading to an over estimation of the numbers”. She then proceeded to suggest that accuracy in such matters was unimportant and that attempts to apply scrutiny was “a distraction from what matters to people and families harmed by gambling”. This represented a change in attitude from three months earlier when the ABSG had described PHE’s highly exact estimate of 409 suicides associated with problem gambling as a “catalyst towards action”. The Gambling Commission allowed the ABSG to publish this opinion in the full knowledge that it was based on unreliable data. 

The following year, Dr van der Gaag was one of two co-adjudicators responsible for allocating around £1m in Gambling Commission (regulatory settlement) funding for the purposes of research into suicide and gambling. Applicants were specifically directed towards the OHID analysis (i.e. estimates that the ABSG knew were flawed) as well as claims by the activist group, Gambling With Lives (despite the fact that even the OHID had indirectly criticised one of GwL’s claims). One of the successful bids (a £582,599 award to a consortium led by the University of Lincoln) included Gambling With Lives as an active member of the research team. 

3. the Silence of the ‘Independents’

Among those who have supported the claims of PHE-OHID are a number of self-styled ‘independent’ researchers. These include academics from the universities of Cambridge, Hong Kong, Lincoln, Manchester, Nottingham and Southampton, as well as King’s College, London, who have cited the estimates uncritically in their work. Perhaps they considered (naively, if so) that research produced by the Government is unimpeachable; yet the errors made by PHE-OHID are so glaring that no researcher of any calibre could have failed to notice them. The failure to subject such serious claims to critical analysis before repeating them indicates – at the very least – an absence of intellectual curiosity. Much is made of the need for research independence (typically defined solely by an absence of industry funding, regardless of ideology or other affiliations); but independence has little value if it is not accompanied by intelligence and integrity. 

4. Breaking ground

A small number of groups and individuals have been prepared to apply scrutiny and challenge, despite the circumstances. The Racing Post and the think tank Cieo have published a number of our own articles on the problems with PHE-OHID (as well as other issues with research-activism); and a handful of journalists, including Chris Snowdon, Steve Hoare and Scott Longley have been prepared to challenge the PHE-OHID claims. Figures from trade groups, bacta and the Gambling Business Group have spoken out publicly on issues with PHE-OHID.

Officials at the Department for Culture, Media and Sport have displayed a capacity for critical analysis, notable by its absence elsewhere in Whitehall. Their White Paper on reform of the betting and gaming market acknowledged valid concerns about self-harm but conspicuously omitted the OHID figures. Lord Foster of Bath, a stern critic of the gambling industry, has acknowledged that the PHE-OHID claims are not reliable and – in a show of honesty and humility rare in the gambling debate – apologised for using the figures himself. He continues to make the case for self-harm to be treated seriously in a gambling context; but without recourse to spurious statistics. Philip Davies, the Conservative Member of Parliament for Shipley, has challenged unsound statistics in parliamentary debates; and Dame Caroline Dinenage’s select committee for Culture, Media and Sport noted concerns of reliability in its report on gambling regulation. 

One member of the Gambling Commission’s senior management team – Tim Miller – has been prepared to discuss and acknowledge problems with PHE-OHID; an attitude that contrasts sharply with that of his colleagues.

5. ‘Noble lies’ and consequences?

Underlying the PHE-OHID saga is a sense that some people in positions of authority consider it acceptable to publish inaccurate or misleading statistics if the cause is – in their opinion – just. Some have even suggested that scrutiny of misinformation is unethical, rather than its manufacture. In July this year, the Gambling Commission intends to publish statistics on the prevalence of suicidality amongst gamblers. Given its role in PHE-OHID (in addition to major issues with its new survey), it is questionable why anyone should consider these results credible. It has also – via Gambling Research Exchange Ontario – sponsored a programme of research into wagering and self-harm. Given that these studies have been explicitly grounded in the PHE-OHID deception – and the complicity of many of those involved – suspicions of bias will accompany publication. It is the publication of unreliable research – rather than scrutiny of those statistics – that undermines public trust in authority. Attempts to address health harms in any domain will be ineffective if they are based on inaccurate evidence.

An independent and open review should be carried out into the PHE-OHID deception; but it is difficult to see how this will happen. The Department of Health and Social Care and the Gambling Commission are unlikely to embrace scrutiny; and the DCMS will not wish to embarrass either its regulator or another government department. There are too many people in Parliament and the media who have played a part; and too few prepared to break ranks. The gambling industry meanwhile (with a number of notable exceptions) has shown little inclination to challenge. There is one hope – that the Office for Statistics Regulation will be prepared to take an interest in the integrity of public health estimates. Such an intervention would go somewhere at least towards restoring trust in public bodies.

A Very Public Deception: On the manufacture of mortality statistics in gambling

Part II – Why did public health get things so badly wrong?

n the first in this series of articles, we examined the problems with claims made by state bodies – specifically Public Health England (‘PHE’) and the Office for Health Improvement and Disparities (‘OHID’) that up to 496 deaths by suicide each year in England are associated with ‘problem gambling’. We demonstrated that the basis for these claims is irretrievably flawed. Analysis of the Swedish dataset upon which they rely concluded that “gambling disorder did not appear to be a significant risk factor for the increase in suicide” (Karlsson, 2023). PHE and OHID researchers overlooked critical research findings and clear warnings about the advisability of their approach. While gambling disorder has long been recognised as a risk factor for self-harm, the estimates published by PHE-OHID are categorically unsound.

Read Part One: Lost in Translation?

In this second article in the series, we attempt to understand why PHE and the OHID persisted in following such a clearly problematic approach in the face of strong evidence of its unsuitability; we examine a number of issues of governance; and consider whether officials may have deliberately misled policy-makers and the public.

The Tobacco Road: why did PHE make such unsound claims?

In May 2018, at the conclusion of its review into gaming machines and social responsibility, the British Government’s Department for Culture, Media and Sport asked PHE to “conduct an evidence review of health aspects of gambling-related harm to inform action on prevention and treatment”.  More than three years later, in September 2021, PHE responded with the publication of five reports on the subject. One of these reports (‘The economic and social cost of harms’) claimed annual costs of £1.27bn a year associated with ‘problem gambling’ – with roughly 50% attributable to deaths by suicide.

It was this rather speculative document, rather than PHE’s more robust quantitative review of evidence from NHS Health Surveys, that officials chose to emphasise – prompting Britain’s Gambling Commission to surmise that PHE’s goal was, “to ensure gambling is considered as a public health issue.”

The Gambling Commission had already been given a glimpse of what “a public health issue” would entail. In a draft press release (seen by the Commission), PHE officials called for:

“a public health approach to gambling…similar to how we tackle tobacco consumption or unhealthy food consumption…”.

In the summer of 2022, the PHE researchers (now transferred to OHID) spelt out what this tobacco-style offensive would involve. Their paper, published in the Lancet Public Health, contained 81 measures for state intervention in the gambling market. The list included prohibitions on: all gambling advertising and marketing (including at racecourses); all in-play betting; and the sale of wine, beer and spirits in bingo clubs and casinos. It also included limits on the number of people permitted on a website at any one time, annual tax increases above the rate of inflation and even ‘plain packaging’ for all gambling products (no colours, logos or images permitted on playing cards, gaming machines, National Lottery tickets and so on).

There were other indications that PHE’s endeavours were not entirely objective – or morally neutral. In 2020, for example, its project leader stated that “more research is required to support advocacy and action” against gambling – hardly a statement of impartiality or scientific rigour. Meanwhile, documents made available under the Freedom of Information Act (‘FOIA’) reveal that PHE had agreed to be part of a research group set up by the activist charity, Gambling With Lives (‘GwL’) during the review period – an engagement it failed to disclose within its report.

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Why did OHID publish its report…and did officials mislead?

In January 2023, the Department of Health and Social Care (‘DHSC’) withdrew the PHE report and published an updated set of cost estimates – this time in the range of £1.05bn to £1.77bn a year (underpinned by a choice of 117 or 496 deaths). OHID described the decision to review PHE’s work as “a standard approach for previously published reports ”; but this seems to be untrue. The decision to re-examine the PHE cost estimates alone (none of the other four reports was reviewed – despite the presence of errors) was taken in July 2022 and announced to Parliament shortly afterwards. We have found no evidence that reviewing state agency reports within ten months of publication is a “standard approach” or that any such policy exists.

Disclosures made under FOIA reveal the true reason for review. On 26th July 2022, an unnamed DHSC official circulated a memorandum, stating:

“We are going to need to make changes to two of the evidence review reports as an error has been spotted, and as it’s a change to results, its [sic.] probably what you would classify as a major change.”

Given that the PHE report contained quite a few errors, it is difficult to know which particular mistake prompted re-examination; but the decision was certainly not part of a “standard approach”. This raises the possibility that OHID may have deliberately misrepresented the grounds for review.

The Gambling Commission and the Advisory Board for Safer Gambling were both told by OHID researchers that “nothing in the report has changed substantially”; but this is incorrect. In fact, every single line item in the OHID cost estimate differed from the PHE version – in some cases substantially. Its estimate of direct costs to the Government was £234.1m lower than PHE’s – a reduction of more than one-third. This was masked by the introduction of a new area of intangible costs, relating to depression and several revisions to the suicide calculation. OHID’s estimates were also based on a ‘harmed population’ 59% smaller than in PHE. As chart 1 (below) shows, the claim that ‘nothing changed substantially’ appears misleading.

In August 2022, the then Health Minister, Maggie Throup MP advised Parliament that the PHE report would be reviewed and that the calculations underpinning its estimates would be published. The review however, has never been made public and – according to disclosures made under FOIA – no such document is held by the DHSC. Contrary to the minister’s pledge, the PHE calculations have still not been released. To do so would reveal a number of errors, such as the fact that PHE’s suicide figure was based on a 21% over-statement of the population prevalence of ‘problem gambling’.

The mystery of the OHID expert panel

OHID was at least prepared to admit – with a heavy dose of understatement – that its estimates were “uncertain”. It relied on a study of hospital patients in Sweden with a clinical diagnosis of gambling disorder (among many other health issues) to estimate the health risks for people in England with no diagnosed mental or physical health conditions whatsoever. In consequence, OHID leaned heavily on the opinion of its expert panel of health economists and academics who, it is claimed, approved the approach.

There are, however two problems where this opinion is concerned. The first is that one member of the expert panel, Dr Henrietta Bowden-Jones of the NHS had publicly criticised the PHE-OHID methodology. At a fringe meeting of the Conservative Party Conference in September 2022, Dr Bowden-Jones stated: “we cannot extrapolate from Swedish studies, from Norwegian studies – it doesn’t work”.

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The second issue is that the meeting of the expert panel – to discuss the most significant matter in the OHID report – is entirely undocumented. In February 2023, the DHSC admitted that:

“there was no agenda or papers shared before the meeting or minutes circulated afterwards”.

It is difficult to understand how this panel of experts might have been expected to review OHID’s work without access to any documents; and why officials did not consider it necessary to record the panel’s deliberations on this critical point.

Why did public health get things so badly wrong?

Inappropriate behaviour?

The task attempted by PHE-OHID was always going to be challenging, given the dearth of actual data available. This does not explain or excuse the large number of errors and omissions made by researchers and officials:

  • PHE and OHID ignored warnings by Karlsson & Håkansson about the representativeness of the sample in the 2018 Swedish study (upon which they relied);
  • PHE and OHID ignored findings in the 2018 study of high rates of mental and physical health comorbidities.
  • PHE and OHID ignored the follow-up study by the Swedish researchers (Håkansson & Karlsson, 2020), which found that risk of suicide attempt was significantly mediated by the presence of other disorders.
  • PHE and OHID ignored the opinion of Dr Anna van der Gaag, chair of the Gambling Commission’s Advisory Board for Safer Gambling, that the PHE calculation was likely to be inaccurate.

A large number of issues with the PHE-OHID reports were brought to the attention of its Director-General, Jonathan Marron in July 2022 and again in September 2023. On both occasions, Mr Marron promised to investigate. Last year, he wrote that he would provide “a proper explanation” for the errors and methodological flaws; but more than seven months later, none has been forthcoming. In what may well be a breach of the Civil Service Code, OHID officials resorted to ad hominem disparagement of their critics – including one national news media outlet – rather than engage constructively.

What is particularly disturbing about the PHE-OHID scandal is not the fact that researchers (presented with an unenviable task) made so many mistakes; but that state officials proved so unwilling to confront them – responding with hostility to legitimate scrutiny.

Next week, in our third article, we will consider the behaviour of others in positions of political or moral authority who variously connived in the deception or turned a blind eye to it. We will reflect on what this means for their future involvement in research and policy-making.

Dan Waugh

May 17th 2024

Regulus Partners

If the Government does not want consumers to be asked to produce bank statements and tax returns in order to spend their own money, why is this happening?

‘If the Government does not want consumers to be asked to produce bank statements and tax returns in order to spend their own money, why is this happening? ‘

Great Britain: Regulation – Will Commission‘s slight return strike a blue tone with bettors?

You don’t have to have the solution,

You’ve got to understand the problem,

And don’t go hoping for a miracle,

All this will fade away.”

‘Slight Return’, the Bluetones (1995)

The long-awaited publication of regulatory policy on affordability checks for gambling consumers in Great Britain may have provided clarity of a sort – but last week’s announcement was also notable for what it did not contain. 

The Gambling Commission’s intention to run a six-month pilot of financial risk checks had been well-trailed. It was surprising therefore that its announcement contained so little information about how the tests would be conducted; by whom; and what criteria would be used to determine success. In 2017, the Gambling Commission’s Responsible Gambling Strategy Board published an Evaluation Protocol, based on the principles of ‘robustness and credibility’, ‘proportionality’, ‘independence’ and ‘transparency’. As things stand, it is unclear to what extent – if at all – the Commission intends to comply with its own protocol (or indeed the Government’s Magenta Book).

The Protocol states, for example, that good evaluation “should include a clear articulation of what an intervention is intended to do, the outcomes it is intended to achieve, and how it is envisaged these outcomes will come about”; and also that it “has data collection which is planned before the intervention is implemented – so that, if necessary, baseline data can be collected before the policy starts.”  

The Gambling Commission has stated that the purpose of the new regulation is to create greater consistency for consumers; to regularise the patchwork quilt of trigger points and thresholds for checks that currently exists. At the same time, it has been remarkably incurious as to why this system of checks came into being in the first place and what effects it has had. If the Government does not want consumers to be asked to produce bank statements and tax returns in order to spend their own money, why is this happening? How has the existing system affected consumers, the functioning of the licensed and unlicensed markets and the finances of British horseracing? Without understanding this, how will we know that the Commission’s new system is better? Without robust analysis of the problem the policy is intended to solve, how will the success or otherwise of the pilot and any succeeding regulation be assessed?

The results of the 2021 ‘short survey’ into consumer attitudes towards affordability checks is another significant omission. Last year, the Gambling Commission committed to publish “the results from the survey”, which was completed by 12,125 individuals, thought mainly to be bettors (horserace bettors in particular were encouraged to submit their views). Instead of this, the Commission has published what might best be described as a narrative description of responses to the overall call for evidence – which is not at all the same thing. The market regulator’s reluctance to publish the actual results will prompt speculation that it perceives the views of consumers to be inconvenient or of marginal relevance to its mission. The Commission may find that a failure to do what it said it would, hinders rather than helps its goals of increasing transparency and building trust.

Last year, the Gambling Commission denied a request, made under the Freedom of Information Act, to release the survey results. It claimed that the “necessary preparation and administration involved in publishing the information” outweighed the “legitimate public interest in promoting the accountability and transparency of public authorities”. What had seemed a doubtful excuse at the time now seems highly implausible. It is difficult to believe that the composition of a single webpage on responses to the 2020/2021 call for evidence involved very much “preparation and administration”. Having been forced to wait for more than three years for publication, this single page may strike the thousands of people and hundreds of organizations who took the trouble to respond as a rather slight return. Those who believe that the Commission has no interest in the views of recreational consumers are likely to feel vindicated. In a paper published in 1999, Bill Eadington, the father of modern gambling studies, described the way that gamblers are often treated as “customers whose demands are not fully respected in the public policy formulation process.” He had a point.

Dan Waugh

E:  dan.waugh@reguluspartners.com

W:  www.reguluspartners.com

A Very Public Deception: On the manufacture of mortality statistics in gamblingA study of suicides in gambling, are we being told the truth? Part 1

Public Health England was closed down because it was incompetent and was too easily distracted by lifestyle issues when it should have been focusing on public health. It was more of an in-house lobby group than a serious scientific agency. It seems that closing it down and re-opening it under a new name (OHID) with the same staff was not enough to make the leopard change its spots.

Dan Waugh- Regulus Partners

In recent years, the claim that up to 496 deaths a year in England are associated with problem gambling has become a staple of the debate on gambling market reform. The estimates originate from a 2023 report by the British Government’s Office for Health Improvement and Disparities (‘OHID’) and have been used to support demands for a wide range of additional controls on consumers and the market. There is just one problem – they are based on junk science.

While it has long been recognised that people with gambling disorder are at elevated risk of self-harm, the specific estimates produced by OHID – accepted uncritically by many in Parliament and the news media – rely on a number of ‘flat-Earth’ assumptions.

In this series of articles, we examine the methods used (and errors made) in calculating these figures and consider the conduct of those who have propagated them. In this, the first article, we demonstrate why the OHID estimates are unsound. In subsequent weeks we will describe the behaviour of the public health officials responsible for their manufacture; consider the actions of other notionally responsible bodies; and ask what public benefit is served by the generation of spurious statistics.

The first state-sponsored estimate of gambling-related suicides in Britain appeared in September 2021 with the release of Public Health England’s (‘PHE’) report, ‘Gambling-related harms evidence review: the economic and social cost of harms’. It contended that, in England, 409 suicides a year were “associated with problem gambling only”. In January 2023, the PHE report was replaced (due to identification of errors) by an update from OHID. It offered a choice of either 117 or 496 suicides “associated with problem gambling”.

Both the PHE and OHID estimates were based on a 2018 study of the medical records of patients treated in Swedish hospitals between 2006 and 2016. Dr Anna Karlsson and Professor Anders Håkansson from Lund University found that patients in the dataset with a clinical diagnosis of ICD-10 ‘pathological gambling’ (renamed gambling disorder in the ICD-11) were on average, 15.1 times more likely to die by suicide compared with the general population. PHE applied suicide mortality ratios from this study to NHS Health Survey estimates of the prevalence of PGSI ‘problem gambling’ in England to produce a figure of 409 deaths a year.

In 2023, OHID repeated the exercise, using precisely the same information, and produced figures of either 117 or 496 deaths (the lower figure based on the application of the Swedish mortality ratios to the population prevalence of DSM-IV ‘pathological gambling’). In doing so they ignored critical information and clear warnings that their methods were unsound. The hospital patients whose records were analysed in the ‘Swedish study’ suffered from a wide range of diagnosed mental and physical health conditions (see charts 1 and 2, below). As a group, they were at elevated risk of self-harm, regardless of the presence or absence of gambling disorder. PHE-OHID thought otherwise – assuming that  health risks for hospital patients in Sweden with a wide range of illnesses were the same as for people in England with no diagnosed health disorders whatsoever. In other words, they made the ‘flat-Earth’ assumption that there is no association between mental and physical ill-health and risk of suicide.

In making this assumption, PHE and OHID ignored a clear warning from Karlsson & Håkansson. Their paper advised that the hospital patients whose records they had studied were likely to suffer from particularly severe and complex disorders:

“It is therefore likely that results may be skewed toward a population of individuals with more severe forms of GD [gambling disorder]. It is likely that this once again implies that this study sample might contain patients with higher mental health comorbidity, as well as individuals with more severe forms of GD, since these individuals are more likely to receive specialized psychiatry care”.

The PHE-OHID researchers also ignored findings from the follow-up to this study (the second in a series of five undertaken by the researchers from Lund University). Håkansson & Karlsson (2020) showed that comorbid health conditions were even higher within the group of patients who had attempted or completed suicide (see chart 3).

Professor Håkansson and Dr Karlsson showed that risk of suicide attempt was five times higher for patients with gambling disorder if they also had diagnoses of alcohol use disorder and drug use disorder. Of those patients who had made a suicide attempt, 70% had a diagnosis of alcohol use disorder or drug use disorder or both. The researchers at Lund University provided a range of adjusted odds ratios based on the presence of other diagnosed mental health conditions (see table 1). This study – which was published ten months prior to the PHE report – indicated that suicide risk for patients with gambling disorder was halved where no alcohol use or drug use disorders were diagnosed. Even before adjusting for other risk factors, these findings clearly demonstrated the inappropriateness of PHE’s approach.

A third study assessed the effect of socioeconomic factors on risk of suicide attempt. In the fourth study, a control group was used to identify discrete risks associated with gambling disorder. It concluded that:

“gambling disorder did not appear to be a significant risk factor for the increase in suicide and general mortality when controlling for previously known risk factors”.

This finding creates a dilemma for OHID and those who have propagated its claims. If one believes that analysis of the Swedish National Patient register by Karlsson & Håkansson provides a reliable basis for assessing suicide risk in England, then one must conclude that – contrary to PHE-OHID assertions – gambling disorder is not “a significant risk factor”. If on the other hand, one does not believe this is a suitable approach, then the PHE-OHID claims also cannot stand because they rely entirely on the mortality ratios from the first of the Swedish studies.

The fact that PHE and OHID got things wrong does not mean that underlying concerns about gambling disorder and self-harm are misplaced – or that gambling operators, treatment providers and policy-makers should ignore the issue. It has long been recognised that people with the disorder are at elevated risk of suicide, even if the precise nature of the relationship is complex. A number of recent inquests in England have determined that excessive gambling contributed to loss of life. Operators should do more to promote positive mental health and to address risk of self-harm among their customers and employees – whether gambling is involved or not. The PHE-OHID claims are, however, irretrievably flawed and should be disregarded by policy-makers. There is simply no coherent logic that allows them to stand.

In next week’s article, we will consider why PHE-OHID produced such obviously flawed findings and examine potentially serious issues of governance attending their publication.

List of abbreviations

DSM-III: The third edition of the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Health Disorders.

DSM-IV: A screening questionnaire published by the American Psychiatric Association within the fourth edition of its Diagnostic and Statistical Manual of Mental Health Disorders

OHID: the Office for Health Improvement and Disparities. Part of the Department of Health and Social Care.

PGSI: The Problem Gambling Severity Index. A screening instrument developed by Ferris & Wynne (2001).

PHE: Public Health England. A state agency, reporting to the Department of Health and Social Care. It was disbanded in 2021.

Dan Waugh is a partner at the global strategic sports and leisure advisory firm, Regulus Partners.

Sample Bias – the new normal

 
Great Britain: Regulation – Is the Great British Gambling Debate heading for a Terminal solution?


Last week’s House of Lords debate on gambling advertising was in many respects the same tired old combination of mistruths and moral indignation; but it was notable for providing a glimpse into the next phase of gambling policy discourse in Britain. Lord Foster of Bath, who instigated the short debate told the House that:
 
“I suspect public concern is about to rise because, in July, the Gambling Commission will release new figures about gambling harm. The Gambling Minister in the other place has already indicated that they are likely to show that 1.3 million people will classify as ‘problem gamblers’ and that a further 6 million are at risk. If confirmed, these figures are far higher than those used to inform the Government’s work on their White Paper. This is a real cause for concern, further strengthening the call for action.”


 
The intent could not be clearer. If the publication of the Gambling Survey for Great Britain (‘GSGB’) in July reveals a markedly higher rate of ‘problem gambling’ than the estimates relied upon by the Government in its White Paper, then the wisdom of the policies contained therein will be open to question. Lord Foster’s point is a fair one. In its White Paper, the Government relied on the 2018 Health Survey for England, which reported a ‘problem gambling’ prevalence rate of 0.38%; and the current Official Statistic (from the HSE 2021) is 0.25%. The Final Experimental Stage of the GSGB reported a figure of 2.5% – between six and ten times higher than the HSE. If the Government and regulator are confident that results obtained from the GSGB are reliable, concern groups will justifiably ask for a re-run of certain policy decisions (and possibly even Judicial Review, given the litigious bent of some activists).
 
The problem is, of course, that the Gambling Commission does not appear to be at all confident that results obtained from the GSGB will be reliable. Each of the new survey’s iterations – from the Pilot Survey in 2022 to the Experimental Stages in 2023 to Wave 1 of the official survey in 2024 – has revealed signs of sample bias. In an independent review (‘independently’ funded by the Gambling Commission), Professor Patick Sturgis of the London School of Economics, commented on the “non-negligible risk” that the GSGB would “substantially over-state the true level of gambling and gambling harm in the population”. He also urged caution, warning that “until there is a better understanding of the errors affecting the new survey’s estimates of the prevalence of gambling and gambling harm, policy-makers must treat them with due caution.” Such advice appears lost on the Commission (which prefers to gloss over inconvenient opinions). In addition to rates of ‘problem’ and ‘at risk’ gambling’, it plans to release survey findings in respect of suicidality, violence and abuse, mental ill-health and use of food banks – in the knowledge that the figures may very well be incorrect and misleading. Just when the Department for Culture, Media and Sport might have thought it was nearing the end of a long and tortuous journey on gambling reform, the Commission is throwing down new track.


 
The threat to the licensed betting and gaming market in Great Britain is severe. The public health establishment (including senior figures within the Department for Health and Social Care) has signalled its intention to “tackle gambling” (all gambling and not just harmful gambling) in the same way that it has dealt with tobacco smoking. Demands for total bans on advertising (including at racecourses), the sale of beer and wine in bingo clubs and casinos and the imposition of ‘plain packaging’ for all gambling products (no colours, logos or images – farewell Queen of Hearts), will intensify. In Scotland, it is reported that the SNP plans to raise the legal age of gambling if it achieves independence (presumably with a carve out for anti-gambling vitriol in its Hate Speech legislation) but this is only a stop along the route rather than a final destination. It is far from obvious however, that the industry realises the perilous nature of its current position. Tone-deaf advertising on bus stops and at railway stations only strengthens the ground for those seeking a terminal solution.

In the hands of a narcissist.

The latest from Regulus partners

 
Great Britain: Regulation – The Invisible Hand of Gambling Market Regulation 
Some years ago, Britain’s Gambling Commission announced that it had banned the term ‘responsible gambling’. At the time it seemed like an odd move. Notwithstanding legitimate concerns about the misuse of ‘responsible gambling’ by some licensees (see for example, http://regulusp.blogspot.com/2014/11/the-recklessness-of-gambling-responsibly.html), there is generally something a little unsettling about state agencies censoring language.  
 
Based on recent statements, one could be forgiven for thinking that the concept of responsible regulation might also have had its day. In an interview for the Smart Betting Club, GB Gambling Commission CEO, Andrew Rhodes appeared to wash his organisation’s hands of any responsibility for devising affordability checks; claiming that the current informal regime is the result of licensees reacting to enforcement cases rather than regulatory diktat. The theory of ‘spontaneous adoption’ however requires us to overlook the fact that in 2020, the Commission warned licensees that: “customers wishing to spend more than the national average should be asked to provide information to support a higher affordability trigger such as three months’ payslips, P60s, tax returns or bank statements which will both inform the affordability level the customer may believe appropriate with objective evidence whilst enabling the licensee to have better insight into the source of those funds and whether they are legitimate or not.”
 
Mr Rhodes’s assurance that the Government does not want gamblers to produce payslips might be more convincing if it were not for the fact that this is precisely what the Gambling Commission has demanded of them. During the podcast, he described plans for financial risk checks and financial vulnerability assessments as Government policy, which the regulator has been asked to execute. This much is true; but it is also the case that the Commission has been the principal architect of that policy. Rhodes suggested that the Commission’s own plans for checks had been overtaken by the Government’s review of the Gambling Act, stating that: “a lot of people were saying that this is a really big policy topic and it’s really a matter for the White Paper – the Gambling Commission shouldn’t be trying to address this. And we agreed.” The fact is however, that when the Commission launched its call for evidence on affordability checks in November 2020, it did so in the full knowledge that the Government’s own review was imminent. Papers released under the Freedom of Information Act show that the Commission had originally expected the DCMS call for evidence in October – a month before its own was launched. Its refusal to publish the results – including the views of 12,125 individuals (understood to be mainly customers) – cannot be justified by reference to the White Paper alone. The Commission’s view that there is “no outstanding public interest” in releasing the information (1,169 days later and counting) is unlikely to be shared by those who took the trouble to respond.


 
Mr Rhodes also confirmed his expectation that “the black market in the UK will grow because it is being targeted” by unlicensed operators. There was little recognition however, of the contribution – positive or negative – of market rules to the creation of conditions in which illegal activity expands, rather like governments printing money and then blaming commodity prices for inflation. He also claimed that coverage of black-market issues by the Racing Post had been not “entirely helpful” – but it wasn’t clear what this was intended to convey. One possible interpretation is that the RP’s coverage may itself have encouraged bettors to use unlicensed bookmakers – a claim that requires substantiation if it is to be advanced (we stress that we do not know what Mr Rhodes meant by the remark; merely that this is one reasonable interpretation).
 
Andrew Rhodes cuts an increasingly frustrated figure these days – often giving the impression that everything would be fine if only people could be made to understand.  He deserves credit for agreeing to take part in the SBC podcast. Engagement with a wide range of stakeholders is an essential ingredient of good market regulation. For it to be meaningful however, engagement requires a willingness to deal frankly with difficult issues, even if this involves occasional admission of responsibility or fallibility. To err is human; to evade is political. If the Government really wishes to sort out the mess of affordability checks, it should initiate a review to identify how the current system came into being and what the effects have been (in terms of harm prevention, consumer behaviour, law-breaking and market functioning). The truth is that a series of pilot schemes for affordability checks has been running for several years now. The effects of this programme should be independently assessed and evaluated – but this seems unlikely to take place. The lack of curiosity from officialdom about the origins and effects of affordability checks is telling.
 
Watch the podcast here: https://youtu.be/WnGvzO7F0pw?si=bSl_3LBWBCq8SvuH

Cracking the Code: Exploring the role of the Regulators’ Code in Britain’s gambling market 

By Dan Waugh, Regulus Partners

To what extent should the Gambling Commission be guided by the Regulators’ Code in discharging its duties? To what extent does it comply with the Code and how would we ever know? Does this matter? This is the discussion that we hope to stimulate with the publication today of our new report, ‘Questions of Principle: Assessing the Gambling Commission’s compliance with the Regulators’ Code and the Nolan Principles’. At present, there is considerable uncertainty about what influence, if any, the Code should exercise on the regulation of Britain’s betting and gaming market; and the perpetuation of this uncertainty, we argue, is unlikely to be in the best interests of consumers.
 
The Regulators’ Code was introduced in 2014 by the Department of Business Innovation and Skills. All statutory regulators in Great Britain – including the Gambling Commission – are required to “have regard” to the Code in exercising their duties – a phrase that accommodates a high degree of subjectivity. Last year, the Commission’s chief executive, Andrew Rhodes described the Code as “not a long document – just seven pages”; and “a sensible set of guiding principles” – a characterisation that drew rebuke from the legal community. On leading lawyer responded: “I am sure Andrew Rhodes wouldn’t like to see gambling operators treating, for example, its seven page Industry Guidance on High Value Customers as just a ‘sensible set of guiding principles’”. The exchange highlighted an unhelpful difference of opinion between the market regulator, its licensees and licensing lawyers.


 
The Code itself consists of six provisions:Regulators should carry out their activities in a way that supports those they regulate to comply and grow;Regulators should provide simple and straightforward ways to engage with those they regulate and hear their views;Regulators should base their regulatory activities on risk;Regulators should share information about compliance and risk;Regulators should ensure clear information, guidance and advice is available to help those they regulate meet their responsibilities to comply;Regulators should ensure that their approach to their regulatory activities is transparent. 
Regulators are required to adhere to the Code in the context of their wider statutory roles and they may exempt themselves from certain provisions, so long as they explain why. 
 
Our analysis suggests that, while the Gambling Commission (which has not announced any Code exemptions) is often compliant, there have been instances where it appears to have breached code provisions, sometimes on a repeated basis. Our report highlights particular concerns with regard to the Commission’s observance of the first and sixth Code provisions – supporting compliance and growth; and ensuring transparency.
 
The first of these Code provisions is often misinterpreted as a requirement for the Commission to encourage economic growth at all costs – something that is clearly incorrect. The provision is however, more nuanced than this. It asks that regulators “avoid imposing unnecessary regulatory burdens”; and that they “assess whether similar social, environmental and economic outcomes could be achieved by less burdensome means”. They should also “understand and minimise negative economic impacts of their regulatory activities”; “improve confidence in compliance for those they regulate, by providing greater certainty”; and “ensure that their officers have the necessary knowledge and skills to support those they regulate, including having an understanding of those they regulate that enables them to choose proportionate and effective approaches.”
 
These are sensible requirements for any market regulator; and yet we were able to find little evidence that the Commission actively pursues them. Its public consultations rarely (if ever) suggest active consideration of the need to understand and minimise regulatory burdens. Last year, the Commission’s chief executive, Andrew Rhodes observed (correctly) that “growth must come when the business is compliant, not instead of it”. This is undoubtedly true, but the fact is that most licensees are compliant (if they were not then they would cease, at some point, to be licensees). No market – even a monopoly – is likely to be 100% compliant all of the time; and it is clearly not the intent of the Code that regulators should withhold support pending universal compliance. It is also unclear why the Commission would see non-compliance as a reason to ignore its duty to “understand and minimise negative economic impacts” of its regulatory activities, or to “ensure that their officers have the necessary knowledge and skills” – particularly when it is often the customer who ‘pays’ for impacts and deficits. 
 
Our report highlights a number of instances where the Commission appears to have fallen short of the standards set by the Code. These include:The approval of regulatory settlement grants for organizations and individuals openly engaged in anti-gambling advocacy;The misuse of statistics and research – and the withholding of key evidence -in public consultations on regulatory reform;Inconsistent and often opaque approaches to policy determination (arising from public consultations);A failure to apply evaluation or scrutiny to the award of £90m of regulatory settlements between 2019 and 2023. 
In addition, as we note in our article for Cieo this week (Help! I have become an ‘issue’ – Cieo), we have uncovered indications of bias within the Commission’s Advisory Board for Safer Gambling, as well as the existence of secret meeting notes which should, in our view, have been published.  
 
Any review of compliance is necessarily selective – and no organization is perfect. It is important not to lose sight of the many achievements of the Commission in supporting a generally well-functioning market, characterised by low rates of illegal and underage gambling and a world-leading approach to sports integrity. The rate of ‘problem gambling’ is also very low by international standards, with 0.25% of adults estimated to be PGSI ‘problem gamblers’. This, at least, is the case at present – although the Commission’s plan to replace the ‘gold standard’ NHS Health Survey with its experimental Gambling Survey for Great Britain seems certain to result in much higher – and far less reliable – reported rates of ‘problem gambling’. 
 
The Regulators’ Code is a valuable document, designed to help market regulators to focus on their statutory roles, without getting distracted by alternative, often incompatible political agendas. The Commission has the opportunity to make far greater use of the Code by stating explicitly how it guides its strategy; by actively monitoring and reporting on its compliance (as some other regulators do); and by establishing a mechanism for constructive engagement with licensees and others in regard to suspected breaches. The absence of such measures will inevitably give rise to confusion and cynicism – neither of which is in the interests of the consumers who the Gambling Commission was established to serve.Please see our full report here:

Questions of Principle: Assessing the Gambling Commission’s compliance with the Regulators’ Code and the Nolan Principles
Disclaimer; The analysis provided in this report represents the opinions of the authors. Any assessment of trends and change is necessarily subjective. The information and opinions provided herein are not intended to provide legal, accounting, investment or policy advice, nor should they be used as a forecast. Regulus Partners may act, or have acted, for any of the companies and other stakeholders mentioned in this report.
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Don’t forget to gamble responsibly..

Watching the Oikball the other night, sitting next to my Sons, I observed West Ham sporting their snappy outfits pressed and laundered by Betway. Newcastle were sponsored by those nice people that lend money – Wonga. The stadia was adorned with Betway bunting. The adverts during the game were predominately sponsored by companies claiming their users ‘gambled responsibly’ – Especially Ray Winstone, who I doubt has had a tenner on anything in his life. But it’s great viewing for children. Honestly

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If you like to watch sport, you’ll get used to this. If you like your late night telly – you know – stop camera action from the police force in Reading, the best looking penis, or shows about cars with fabulous emission ratings, you’ll also have become used to proliferation of gambling adverts. Some of whom sound almost heroic.
Of course we’re encouraged to ‘gamble responsibly’ by the yellow sign that tells us all (subliminaly) that when we’ve had enough FUN FUN FUN – we must learn to stop.
In other words, when you’ve run out of cash, maxed out every credit card you’ve got, kicked the fruit machine to bits, mortgaged your home to the hilt, turned your Missus into a Lesbian, and of course made the BBC documentary on ‘Britain At The Bookies’ – the home for all genuine sad acts, – then you’ll have truly arrived in the worlds of Bet365 and William Hill
If you’re in the minority, like me, the Mary Whitehouse types, you might pause for a moment and wonder what effect this siege of advertising has on our phsyche- not to mention those of our children. I mean we stop cigarette adverts, so why is it permissable that EVERY ad break tells us we have to spin to win? And sometimes more than once a break?

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And of course, as every independent bookmaker and decent minded citizen knows- The UK’s ‘watchdog’ – the Gambling Commission, with all its fees and hype – does absolutely nothing. Nothing at all, to justify its very existence. ‘To protect the vulnerable.’

The ‘vulnerable’in this case appear to be online gaming giants

Little known- but worth mentioning, back in April I challenged Paddy Power on promotions headlined with the banner ‘money back’ on certain wagers. This was a headline grabber and peddled widely in the press. I invited them to desist from encouraging customers to wager under the entirely false assumption certain stakes would be refunded, when in actuality the customers were being refunded in ‘free bet stakes’. Of course the two are entirely different offers

Paddy Power declined to remove promotions with said headlines.

I challenged this with the ASA as misleading and wholly false. The challenge was upheld and they were ordered by the authority to cease free bet promotions with the headlines money back.

Paddy Power were not alone – Many firms were doing exactly the same, and in direct contravention to an earlier ASA ruling against Betfair for the same type of claims. These firms were directly contravening an earlier ruling

The question is this. Why did the Gambling Commission, the custodian of fair gambling and the vulnerable, not step in at any stage to order such promotions to be withdrawn? Is this agency actively complicit in protecting such firms from basic licensing conditions? Were said firms not in fact contravening several codes in licensing practices with such claims?

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I think I’m a fair minded bookie. I try to give my customers a better class of service and compete on odds with the high street. And as a bookie you might expect me to side with my own. I mean I do have a gambling site. But I don’t bombard people with adverts at 2am about it, and if I were to shove it on my occasional trips to Channel 4, where I upset the establishment for your viewing entertainment, I’d get my backside kicked off pronto.
I’m deeply uncomfortable with what goes on. I feel for those who are suffering. I favour a UK wide ban on anyone who self excludes – not backed by the Gambling Commission. I disagree with the use of credit cards to fund gambling. I disagree with Gibraltar outfits shoving their ‘online’ products to Racing. Although I scoff at the BHA’s lack of backbone in any department, all sound bytes.
I hear a lot of complaints from punters, some of whom could accurately be described as ‘bonus junkies.’ The new breed of professionals who scour the bookie websites for top of the market hits. I have some sympathy with the bookie view that a lot of those types of customer are worthless to us in business.
BUT. If Paddy Power are to offer even money each of two in a Rugby match, with just the outside chance of a handicap ‘tie’ to save them, if Skybet are to offer a loss leading 6 places on the Cambridgeshire, if Coral are to offer 6/1 each of 2 in a tennis match to new customers only – and all of them make money, then I know they’re not getting fat on those sports, especially the increasingly worthless racing product.
So they’re fattening on gaming. – NAP

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Bet365 seem totally content to treat their customers with err, uhm contempt, by offering a customer, their customers, a £1 wager. They don’t care about the PR implications of being described by the same as ‘total frauds’ for describing themselves as ‘Bookmakers.’ Because they’re global. And for every clued up punter they treat so poorly over here, there are perhaps 5% of these new accounts they dig up that make the whole exercise of pushing for new business worthwhile. And deeply profitable. One can admire their bottom line, if not their methodology
Should we feel sympathy for those professional types who complain so vociferously? Clearly we care about the genuine punters who fluke a 16/1 winner and find their next wager batted down to 36p. But the pros?
For myself, I never keep a customer on if I’m not prepared to lay him or her a bet to lose at least £50 as a minimum, and remember that’s my minimum, not the average of what we’re prepared to lay. But that’s because I have standards. I may not like what some customers get up to, but if I do, I close them down with a fair explanation of why it’s been done. We do not hide behind ‘trading decisions’
But the big companies are the ones peddling the prices and offers. They’re continuously driving for new gaming custom and fully prepared to be ‘best odds guaranteed’ or ‘best prices for all Channel 4 races’ – even if it guarantees a loss. It’s a bit like the supermarkets claiming they make nothing from milk, because they choose to sell it so cheap to get the customers into the stores in the first place. They don’t care if the dairy farmer ends up out of business.

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These ‘companies’ have created the bonus and offer culture. The free bet. I heard recently Coral offering a guarantee to lay any horse to lose a decent amount, I’m uncertain if it was Coral’s diminutive UK division or their Gibraltar arm making the offer, because its hardly clear who you’re wagering with when you call up ‘Coral.co.uk’ . They’re not prepared to offer it online, nor even on their phones. Once again a headling grabbing offer that turns out not quite as good as it sounds. But in a way I support any move towards a sensible lay to lose – I’ve always advocated £100 as a startpoint. Coral stand alone in proferring any sort of guarantee to date, even if it’s only in their shops.
But they’re a multi million pound outfit, still un prepared to offer their advertised odds to all of their customers. A bit like Waitrose saying it’s 50p for that Cadbury’s flake, but not to everyone. Isn’t this sort of thing a trading standards issue? And of course pretty much all of the other outfits are exactly the same. Complaints litter about what they don’t do, far more than what they do. Now why is that?
So the next time you think about grabbing yourself a ‘free bet’ for a tenner. Ponder awhile. If you can afford not to support firms who behave with such overall disdain for large sections of their customers, why would you support them with your business? If you want change, you have to be prepared to boycott those firms you consider place little real value on loyalty.
And should they be mandated, as they are in parts of Australia, to lay a fair bet to any price they offer?
Well the Gambling Commission don’t agree with you, but I most certainly do.

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Bing Bong – Pay Pay – the Bookies view of Ascot..

Anyone that describes racing as dull has to be an astronaut. If the highlight for your average rocket man involves periods of sheer terror sitting on tonnes of high explosive jet fuel, punctuated by moments spent trying to work out the on board toilet then I suppose racing falls somewhere between the two. Racing provides so much more gripping entertainment. My week started with ten minutes of fame on Channel 4. The director in my ear telling me to ‘pipe down’  – this is fairly standard. Two large security guards stand off camera ready to drag me off set.

So we chat about Gosden Horn, sitting in the sun, with forecast temperatures of 18 degrees. Lucky asks if I feel the greatest horse on the planet will take his chance. Now, I’m supposed to have done my research, which includes looking at this horse’s form.. – Unless I’m mistaken, the brute beat none other than Storm The Stars at Nottingham on ground described as good to soft- soft in places. Add the paltry 700 grand on offer, the thousands who had paid to see him, the kudos in doing the Derby-George double, that the horse had travelled, that the field was inferior, and that I’m paid to speak my mind – I said I was confident he would indeed take place.

Everyone knows I’m rarely wrong.

A gaggle of press accompanied Lord John on his perambulation around the track, sporting a knitting needle to stick in the muddy bits and accompanied by Anthony Oppenheimer, -carefully dipping his cheque book into the ground. And yes, indeed, race fans – it came up ‘moist’. Of course I jest – it was his credit card. Breeding beats prize money, there’s no appetite for a tussle anymore amongst the top owners

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Feature of Ascot’s excellent support card – a big sprinty thing where they split into 9 groups and the commentator takes a pot shot at who’s actually in front. Now this gets entertaining! Unless you’re an official

History says Speculative Bid travelled the course without the jockey because Spencer was sitting on the stalls rather than the horse. Perhaps he was practicing his dismount? Starters don’t react to cries of ‘No No No’ these days- nor do they speedily inform the stewards of the status of the horse in this age of walkie talkies.

Now I know you’re dozing off here- because who gives a monkies if the bookies done more of their money than they should? Rub of the green. But there’s a strong message here – and it’s important not only to learn from it, but hold the BHA properly to account, because that is how we progress change. Of course folks make errors, but what struck me  was the abject lack of taking responsibility or a will to apologise. A thorough lack of understanding from one of the most professional group of stewards in the game, that they’re responsible to the betting community and the general public- most of whom have had a bet.

Bing Bong

Error one – ‘we’re looking into an incident at the start- but the placings are unaffected

Wrong.

If you’re enquiring into the status of the favourite as a runner, you’re most definitely affecting betting markets. Why not mention what you’re actually discussing?

Bookies paid out dutifully and swiftly without deducting one fifth of winnings as rules dictate.

Bang Wong

‘Weighed in’ –Now we all know someone didn’t do their job here. Who to blame? Perhaps the stewards themselves for taking so very long to find out what happened to the favourite

Bing Bong – Bing Bong Along

‘Stewards Enquiry – we’re looking into the status of the favourite and whether he was a runner or not’   – Say what??

Bing Ding Dong

‘The favourite was a non runner’ customers can get their money back – oh right, sure thing.

So we pay everyone out on the favourite. Which was an illegal instruction. In the meantime the Betting ring managers are besieged with confused customers. Although most bookies had paid out. Not to have done so under the instructions given by the stewards would have been unprecedented – would have potentially resulted in loss of licenses – and would have most certainly caused a riot.

90 minutes pass, during which time the betting ring manager high tails it to the stewards secretary to remind him that what they had done was an illegal instruction under the rules of racing and explain what a bet is. Oh and what ‘weighed in actually represents..

Ding-A-Lang Dong

‘Stewards now instruct that Speculative Bid was in fact a runner for betting purposes ‘ tra la la la la – go back to the bookies for more

Those few who had had rule 4’s deducted took the opportunity to return for another refund. Tee hee. (not all I would add- most realised the bookies were as much victims here- and behaved impeccably)

Jamie Stiers took to Racing UK to explain what went on, roughly. He refused to apologise. Not in his remit.

Here is the ‘decline to apologise video’ – this from the BHA’s head of regulation – so we should expect a polished performance. Instead it adds to the shambles by giving the impression even he didn’t understand the rules- or know what was occurring. ‘I am advised a rule 4 should have come with the withdrawal of the favourite’ – this is a staggering remark. I believe my 12 year old knows this one! As head of regulation he clearly had to have the rules of betting explained to him.

http://www.racinguk.com/news/article/36742/bha-to-launch-bid-inquiry

The stewards made enquiries and in their report they mentioned those findings would be shared with the Authority. Oh, I’ve heard this one before. The brush.

the official report from Ascot:-

The Stewards held an enquiry into the start to ascertain why SPECULATIVE BID (IRE), ridden by Jamie Spencer, failed to start and eventually left the stalls rider-less. They heard evidence from the rider and the starters. Spencer stated that the gelding was loaded late as he was known to be difficult in the stalls and just prior to the stalls being released SPECULATIVE BID (IRE) got his head over the adjacent stall 23. He added that when the stalls were released he was off the horse. Having heard their evidence and viewed video recordings of the start, they found that SPECULATIVE BID (IRE) was deemed not to have started and, under Rule (B)10.5, ordered the gelding to be withdrawn.

The Stewards further enquired into why the Weighed In signal was given before the enquiry into the start of the race had been concluded. They heard evidence from the Stipendiary Steward, the Clerk of the Scales and the Racecourse Announcer. Having heard their evidence they forwarded the matter to the British Horseracing Authority for further consideration.

Look, I can take a joke as much as the next man. I can easily accept errors are made. My problem with the Authority here is the abject lack of transparency, a failure to immediately apologise and take ownership of the problem. All businesses pay for their errors- except the BHA it seems. They want the bookmaking community not only to foot the bill, but take the flak, the assaults that took place on my colleagues, the inconvenience and the loss of face. In the meantime they will conduct internal inquiries and ‘move forward’. If moving forward is to set a precedent whereby we pay for their shambolic and ill informed stewarding – then I have one answer.

No

I’m sorry, but I’m tired of the simple lack of accountability for errors and the high minded attitude that comes with. Appalling race planning, 8 flat meetings on a Saturday in July, 3 jumps meets on a Sunday. Embarrassing integrity enquiries taking years to prosecute in which video of races are lost.The head of integrity is still in his post – headlines ‘we’re consulting ourselves into how we’re doing’. Yup. Race planning is for five year olds, yet its head sits in her chair. A general lack of consultation with the general public. The mundane press releases in the place of open press conferences like other sports in which journalists have an opportunity to test their performance.

I should say it makes me deeply uncomfortable to have to challenge the organisation. But I feel a clear need to defend my colleagues  even if the actual cost to myself is minimal. Let’s hope they behave in a manner befitting new management and the promises made by Nick Rust to come together. Here’s your chance Nick

Of course the BHA have registered successes – more so from it’s rather under funded commercial arm – REL. The Champions series, Qatar involvement, marketing on a shoe string budget. This leaves the authority actually responsible for planning, integrity and regulation. It lacks any clear authority over racecourses to the detriment of the sport – and everyone has a job for life.

Why?

I’m convinced amongst appreciable talent in the BHA are a few individuals without the necessary qualities to represent the sport. In every walk of life it’s critical for performance to be achievably measured. Failing employees and managers to be moved out and replaced with stronger people. And what’s with employing a board lacking in any appreciable experience in racing? So they can be bullied?

A line from excellent columnist Rich Lee – worth quoting –

“ ~~’Has there ever been a racing authority that was not incompetent, lacking in imagination and dynamism, or out of touch with the industry’s needs?’  Guardian racing writer Chris Hawkins…asked this rhetorical question in 1996.”  Plus ca change…!

In between times ‘Britain at the Bookies’ – little to say about this, rather dull if you’re not in betting- and feels like an advert for gamblers anonymous. Can’t help feeling this wasn’t a good idea

Goodwood. ‘Appointment with fear’ my Old Man used to say. A graveyard for bookies, some of whom are buried under Trundle Hill. Good news for the betting men with Hughesie retiring. He’s cost us a pretty sum over the years.. good luck to the legend in his new venture – a gentleman jockey.

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And so we trundle on to York. Another track with a sense of style. A possible meeting for Golden Horn and Gleneagles? On a strip of council land. If you want to get in free, climb under the gate at the ten furlong marker and look like you belong..

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Royal Ascot – 2015 – The Bookies View

www.geoff-banks.com/register.asp

Driving around Ascot is a pretty harrowing experience- streets full of burnt out Bentleys. Every once in a while you’ll pass a Waitrose, and really know you’re in a bad area.. they don’t do Tesco here – no matter what they make (? insert amount ??)

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The trick to Ascot is finding somewhere convenient to park- there’s an exit one way system which sends you back to Sunninghill (a mile away) via Biddlecombe (286 miles away)-  You have to know the system or you’re stuck in the High Street for several days

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Flick knives and knuckledusters  dutifully handed over, you’re greeted by throngs of gatemen. First thing you notice is how polite they are, they check what socks you’re wearing and smile. You see, at Royal Ascot- everyone feels like a Lord for the day – even if you’re entirely potless. Bookies enter with money, – they’re x-rayed on the way out to ensure they’ve left it all with the punters..

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One enters the truly vast terminal- had it’s detractors when it was built, but these days thanks to ‘green fingers Barnett’ – the place resembles an advert for house and garden. Full of comfy armchairs- nooks and crannies to enjoy your glass of champagne. Uber civilised.Quality extends to every enclosure, a track run by toffs- but to everyone’s benefit – no enclosure escapes the personal touch – and you can escape the beer swilling hordes if that’s your bag

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They don’t do Pomagne here!

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And yes,  they actually serve a bottle of champagne in an ice bucket, not a bag, and with a glass should you so desire. You see, if you’re not at Ascot, York or Goodwood, where they do things with panache- most tracks think you deserve a bowl or tumbler to drink your champagne from.  Odd sort of business plan for your best spending customers wouldn’t you agree? Ascot hasn’t dipped standards to the banal trick of hiding customer service values behind health and safety.  .

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Ascot also don’t do themed evenings for people dressed in football shirts..possibly because they take the view their long standing real racing fans might object to spending their days with Yah Yahs..

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But I digress

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When they rebuilt the old Ascot – some of the members said they’d never return. Well I suppose if you’re pushing up daisy’s and by extension possibly not reading this – that could indeed be true. For the rest of the ‘I’m never going again’ mob – it appears to my inexpert eye, that Ascot have built one of the world’s best sporting arenas –  outstanding restaurants, bars and service. In a racing environment obsessed with sand , it’s refreshing to walk into an Ascot or York where the focus still remains what goes on around the track – not (perhaps) in a betting shop.

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I spot Nick Rust, the new BHA chief exec in the throng – clearly his suit was made for someone bigger – he’s chatting to someone about ‘coming together’. I wonder idly if he’s explaining why they dug up Newcastle to create a terribly interesting series of races in a straight line. For this week though, exceptionally and perenially, we have the best racetrack in the world.

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The first race rolls around – there’s a lump from Hong Kong – ‘Able Friend.’ Our Gallic friends have sent over a Goldikova clone. Most bets are in euros, as the far east specialist proves more suited to racing at the back. Solow wins well and Maxine Guyon flicks a V sign at the toffs as he passes the post. I don’t blame him. The bookmakers rename the winner ‘Sorrow’

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The rest of the day degenerates into the stuff of nightmares for the bookie types as the Festival lurches from Prince this and Queen that . If it’s not the favourite, it’s the galactically talented Ryan Moore sweeping the board. That won’t go down well on the High Street.

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People that know me understand I’m one for speaking plainly. I have listened to several respected scribes eulogising on about the rather evident talents of Mr Moore. Little question he’s probably the most talented jockey we’ve witnessed on the flat. It goes along the lines of ‘isn’t he magnificent? What a rider! And to those that know him – apparently quite a wit’

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Well, to the rest of us, who’d rather a jockey smile when he nails a Derby – he’s a thoroughly morose character – he doesn’t endear himself – nor promote the sport that makes him several millions in any way, shape or form. So no, I don’t find him admirable as a human being. Two weeks ago, we saw a brilliant horse take a Derby with a pilot who will do more for headlining the sport than Golden Horn himself. Leaping out of the saddle and engaging the crowd. That cost me a rake, but I smiled when I saw it. That’s what the fans want – not the taciturn one. He’s for betting – not for Racing. Shape up Ryan! Dettori, McCoy, Hughes, Walsh amongst many happily give of their time –  you can’t manage a smile??

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When you look at the results, you could easily conclude they didn’t look that bad for the bookies, but I suppose it was the combination of several favourites going in – and if they got beat, it was either Moore or Dettori on top. Thursday I think was the most entertaining betting day – with Moore bashing the firms with a 14/1 opener followed by a 5/1 winner. Payouts could potentially dwarf the Mullins quad at Cheltenham.. (Thanks Annie)

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One major off course layer went into hyper drive sending nearly a quarter of a million back for Kingfisher in the Gold Cup- all those 10p accumulators, at guaranteed odds, I expect suddenly come to haunt. This time it was Maxine Guyon to the bookies’ rescue as he held Moore on his inside – causing him to switch paths at the critical stage. For me the week’s unlucky loser. For the major bookie involved- several pence retained on their share price. I expect they were not alone in hiding under their sofas as Kingfisher turned for home..

Racing festivals haven’t been that great for the firms over the last few years. Most lead with fabulous offers and price boosts created by their marketing departments. Combine that with a dip in on course margins – polarisation of expensive horses shared by a select few jockeys and trainers, and you have a problem for those betting on the product. Expect you’re reaching for a Kleenex right about now

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Racing starts every day with a race for the Royals from the mile start in their fancy carriages. Now I’ve watched this for more years than I can remember- never once has anyone tried to pass the one in front. Surely I can’t be the only one who’s spotted the biggest bunch of non triers in racing?? Fair enough, they put on a good show, the whole event surely organised to give the bookies another betting heat to do their brains in – namely the colour of the Boss’s hat. But I’d like to see more effort from those in behind..I know I speak for all concerned who back the second carriage every year

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God save our Queen..you won’t see a pageant like that at Goodison Park..a uniquely British summer scene.

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I took one wander down from the Royal enclosure towards the Silver Ring. Ascot is so vast, the silver ring is nearer to Egham. As enclosures go, it’s really quite well turned out. I walk as far as is possible before the waft of chips overtake that of Chanel.. There are bookies all the way down the racetrack, making noise, taking bets. I wonder what will happen to the very flavour of racing when the tracks inevitably take over the betting. Don’t think we don’t know what you’re about, with your expansive plans for data charges etc etc – we’re on to your tricks!

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Racetrack bet however, could do well at the festivals, I don’t think the punters are in any way price savvy, we know that from Chester – they just want service. But the diet of midweek racing we’re fed by tracks-horsemen-BHA, has leant itself to poor attendances from both customers and bookmakers. What’s the future without the ring? My dream we wake up before it’s all too late – the major betting firms have deserted racing for football and roulette. I suppose then the sand will go back to the bunkers. No Big Jim, Barry Dennis, Victor Chandler

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Imagine a world where an exec at Channel 4 suddenly decides the network should quit racing, in the face of the often ridiculous criticism of a show affording the sport 44 cameras and the best coverage it has ever experienced. By comparison the BBC with its almost ‘cottage’ coverage. Racing feeds the network a diet of 5 runner group races almost weekly and wonder why the numbers are down- then makes it awkward for them to show alternate meetings in its coverage and ignores Channel 4 in any decision making processes at the highest level. Remember,  they can make more money for less hassle from ‘Everyone loves Raymond.’. Don’t think the BBC will come back to save Racing from itself – they barely mention the National

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Racing has an awful lot invested in very few options. Royal Ascot is amazing, but if Aston Villa play Scunthorpe it’s likely to pull in more sponsors, viewers and press coverage. The next few weeks Racing will go into its shell from Sunday to Friday, bang on 7 meetings on the Saturday, and bolster attendances with pop concerts and a grotesque obsession with selling as much beer as possible. Hmm, get back to the Racing. Ascot leads for me with the right balance and never loses sight of its focus on the Sport

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It’s not supportable, but with a regulator fascinated by commerce, rather than how is the sport best served and gels together, – a board of novices to do as they’re told? As Nick Rust so accurately describes- the underlying trends are declining. He’s just not going to do anything about it. Sorry Nick, I don’t do sound bites. I did enjoy your BHA seminar though, with Rod Fabricious harking on about artificial insemination.. not sure who he wanted impregnated though..

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Fortunately there’s enough quality in York, Goodwood, Cheltenham, Chester and Ascot to name a few to keep British Racing at the very top of the world order, British racing has a unique calendar of major Festivals. I wonder if there’s an RCA man reading this, sympathetic to the view most racetracks are struggling with an identity crisis? A racetrack, a greyhound track or just a vast pub. Here’s one to mull over – try proper segregation of long standing racing fans, who don’t feel to have beer spilt over their girlfriends, or even the often threatening environment, from the oiks that do, – rather than selling all in sundry a pass to the members enclosure, keep some areas with civilised folk in mind. Possible? I think also a lot of racetracks need to integrate their thinking with the words ‘social responsibility’ rather than ‘sales’

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Early evenings at Ascot are spent gate crashing car park parties and pretending you’re one of the owners. Everyone standing quaffing champagne, leaning on their Astons, in an age old and endearing slice of the great meeting. It’s my time to get asked by people stuffed with my cash, how much I’d won that day.. (where’s that sharp knife?) Everyone turns up without being invited – ‘Who ARE you – and why are you stealing my champagne?’

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How good was the meeting? Well to my mind pretty outstanding. How does it compare to Cheltenham? Well they’re rather chalk and cheese. Ascot is very much more about the social scene. But there’s no loss in focus on the racing. Quipco have stepped in. There’s a new Group one sprint attracting foreign raiders that really works. It has management focussed on quality at every turn. Entrance charges to the meeting aren’t steep – considering what is delivered. Cheltenham has a different feel. Far more the betting event, with months focussed on it’s feature races. The two great events provide balance. Is it a bit toffee nosed? I don’t think so, sure the babies are on Smoked Salmon, and they tow away Ford Escorts, but one has to keep the Riff-Raff out 🙂

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See you at York – could it possibly get any better?
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