More double standards

Any business will target its most numerous customer. I’m not saying whether it’s right or wrong, it just is. You’ll also find more low-rent off licenses, more kebab shops and more charity shops in these areas and fewer Waitrose stores. A higher income area sees more Waitrose, fewer bookies… and that’s how that goes.

And yet somehow, the National Lottery never, ever comes into this argument.

It’s the epitome of gambling normalisation. Its early advertising campaigns were all of the type: “Change your shitty life, win the lottery!” It’s still allowed to advertise with The Guardian, so you know it’s fully accepted by the middle classes and above.

Why am I picking on the lottery? Because the playing field is a long, long way from level and recent news has caused me to think it’s not going to flatten out any time soon.

An exception for the National Lottery

The government recently announced a consultation on a new mandatory gambling levy aimed at raising additional funds for research, education and treatment (RET) for gambling harms.

Culture secretary Lucy Frazer said: “We are taking the next step in our plan to protect those most at risk of gambling harm with a new levy on gambling operators to pay for treatment and research.

“All gambling operators will be required to pay their fair share. This consultation is an opportunity for the industry, clinicians, those who have experienced gambling harm and the wider public to have their say on how the proposed gambling operator levy should work. 

“The introduction of this levy will strengthen the safety net and help deliver our long-term plan to help build stronger communities while allowing millions of people to continue to gamble safely.”

Of course what she said and what she meant are not the same thing. “All gambling operators will be required to pay their fair share” except the National Lottery. For reasons unknown, it’s neither seen nor treated as a gambling operator, despite being by far the biggest. Sure, the distribution of money to good causes is awesome – and it relieves the government of the burden of finding ways to make life less onerous. So everybody wins, right? Well, no.

Because the lottery isn’t just the lottery draw. Retailers also sell scratchcards and that is an entirely different kettle of fish. The problem with this form of gambling is… Where do I start? Dr Mark Griffiths, distinguished professor of behavioural addiction at Nottingham Trent University, wrote in the Electronic Journal of Gambling Issues that scratchcards are a “hard” form of gambling.

This “hard” definition equates them to roulette and blackjack and not the casual, harmless bit of play we might be led to believe.

Accessibility of scratchcards

The lottery itself, despite its many side games, is definitely soft gambling – small event frequencies ensure this is the case. Even the side games in the UK adhere to this.

But scratchcards? Their very design often emulates fruit machines or similar and their characteristics “have the potential to induce excessive gambling regardless of the gambler’s personality, environment or genetic make-up. These characteristics include the capability to produce psychologically rewarding experiences in financially losing situations – particularly the psychology of the near miss,” in Professor Griffiths’ words.

So what’s the big deal? It’s a combination of that normalisation and the number of outlets. There are just over 6,000 retail bookmakers in the UK; that’s about one bookie for every 10,000 people. Yes, I know, they’re not divided up by population/proportion. It’s just to illustrate the idea.

The National Lottery has over 43,000 outlets, and they all sell scratchcards. The operator Camelot proudly told me that 94% of the UK population live or work within one mile of a National Lottery terminal.

I tried to get a breakdown of their numbers and type by demographic and geography, but understandably, this was not forthcoming “because the release of more granular, commercially sensitive sales data would enable competitors to target particular areas of the UK for their own commercial advantage, disadvantaging Camelot in fulfilling our overriding objective to maximise returns to good causes.”

Or, as I like to say, it would disadvantage Camelot in selling as many tickets.

The overriding objective of any gambling operator is profit and anyone that says otherwise is bullshitting. The good causes aspect is just the way that the lottery operator gets around the punitive guidelines the rest of us have to follow.

Protecting under-18s

And not releasing that information also gets around the scrutiny of the proliferation of outlets by area because – and I’m sticking my neck out here – I’d bet real cash money that it would mirror the density of retail bookies and proportionately dwarf them.

Camelot stressed to me the work they put in to ensure that retailers are adhering to the law, to not selling to under-age people and asking for ID and it’s quite impressive.

A spokesperson emailed me to explain: “Although National Lottery games are very different from those offered in the wider gambling sector, it’s crucial that we and our retail partners continue to do everything we can to prevent underage and excessive play.

“For example, in 2022-23, we made over 11,600 retailer visits as part of ‘Operation 18’ – which uses people who are over 18, but who look younger – in order to avoid retailers inadvertently breaking the law during a test visit. If a retailer fails a mystery shopping visit on three occasions, their National Lottery terminal will be suspended and is likely to be removed.

“And I’m pleased to report that a record-breaking 92% of National Lottery retailers correctly asked for ID on first visits during the 2022-23 ‘Operation 18’ mystery shopper programme – demonstrating their ongoing commitment to selling National Lottery games responsibly. The best-ever results are particularly impressive given that the age to play The National Lottery only changed from 16 to 18 years of age in 2021.”

Potential bad habit

The spokesperson continued: “We also have a range of other training initiatives as part of our commitment to healthy play. For example, in 2022-23, our retail team made over 160,000 contacts to National Lottery retailers – via phone calls, face-to-face visits and emails – to offer advice on preventing underage play and how best to support healthy play in store.

“Elsewhere, our ‘Healthy Play’ mystery shopping initiative involved over 4,000 additional store visits, helping to educate retailers on the signs of potential unhealthy play among their customers.”

To be fair to them, that goes further than most other gambling operators when you add in their retail team visits to advise on supporting healthy play in store and all that comprises. And the operator also stated that they train retailers to spot “unhealthy” behaviours.

But as Professor Griffiths says: “It is not hard to see how scratchcard gambling could become a repetitive habit between its integrated mix of conditioning effects, rapid event frequency, short payout intervals and psychological rewards and the fact that scratchcards require no skill and are deceptively inexpensive, highly accessible and sold in ‘respectable’ outlets.”

That puts the phrase “National Lottery games are very different from those offered in the wider gambling sector” into a better and more realistic context. They’re not all so different, it seems.

The spokesperson concluded: “As a result of the rigorous protections we have in place, it’s widely and independently recognised that the inherent risk of problem play associated with National Lottery games is very low.” I have to argue this one – if you group all the games together as one type then I suspect the problem play aspect of the main game would bring the figures right down.

Include the National Lottery in the RET levy

But I don’t think anyone has looked at scratchcards specifically and, with the nature of retail and the player, I do not believe there is any way to monitor dangerous behaviours with this game type.

What has arguably shocked me the most, however, is that I and the Betting and Gaming Council are in full agreement on this. After the RET consultation announcement, they said: “We believe it [the levy] should apply to all operators including the National Lottery, without affecting good causes, who are not immune to having problem gamblers gamble with their products like scratchcards and instant win games.”

Imagine, with their vast network of outlets all chipping in, and levies across all game types, how much more good could be done by including the National Lottery in the RET levy?

Like I always say, if it’s a problem, treat it like it’s a problem. Don’t be selective just because you like something.