UK LEGAL
the Commission, in order to check whether the number of customer interactions is, at a minimum, in line with this level.” At the moment, this provision still links to data from the NHS Health Survey, however it stands to reason that the new figures should now replace this data, as the GSGB has replaced the NHS data as the official statistics. Of particular note, if this change is made, is that online casino providers would need to have safer gambling interactions with 21.2% of casino games customers and 24.5% of slots customers, compared to the current 8.5%. This will inevitably require significant investment in new systems and team members. Whilst these interaction requirements do not apply to premises-based operators, casino operators should take note that the Commission’s survey has found that 21.4% of respondents who played casino games at a casino were found to be problem gamblers and the majority of such respondents (56%) displayed some indicators of harm. According to the guidance, this should not be grossed up to the whole population until further work is completed.
NEW SPORTS SPONSORSHIP CODES OF CONDUCT One of the recommendations from the Gambling Review White Paper was a cross-sponsorship code of conduct. The overarching cross-sport code is yet to published; however this now appears to be being implemented through individual sports publishing their own codes of conduct which are based on four core principles: protecting children and young people, socially responsible promotion, reinvestment in sport and maintaining
sporting integrity. At the time of writing, codes of conduct for football and horseracing have been released. A key point of the football code is that football clubs will need to ensure that “a reasonable and proportionate portion of gambling sponsorship inventory promotes responsible gambling messaging, which may include social media posts, websites, perimeter boards and/or match day programmes.” This will impact gambling sponsors, as it is likely to reduce the amount of time their brand is visible. Clubs will also need to ensure that supporters can buy kits which do not include gambling logos, and that family areas of the stadium do not display gambling logos or promotional material. At the end of each season, each football competition (for
example the Premier League) will need to publish a statement detailing how the competition and relevant clubs have implemented the code including a list of gambling agreements and examples of arrangements which have complied with or breached the code.
Similarly for horseracing, the British Horseracing Authority will publish an annual summary of actions taken to implement that sport’s code, with specific examples. As is the case with football, there is an obligation to reinvest the proceeds of sponsorship arrangements into the sport. These codes and their implications for the value of sponsorship deals should be carefully considered by any gambling operator with existing sponsorship arrangements, or looking to enter such arrangements.
Melanie is a gambling regulatory lawyer with 13 years’ experience in the sector. Melanie advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control. She has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and novel product ideas.
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