Sell division: Responsible marketing and advertising by the gambling industry

Over the last few years there has been a great deal of speculation over the role of advertising as a possible stimulus to increased gambling, and as a contributor to problem gambling (including underage gambling). Various lobby groups (e.g., anti-gambling coalitions, religious groups, etc.) claim advertising has played a role in the widespread cultural acceptance of gambling. These groups also claim casino advertising tends to use glamorous images and beautiful people to sell gambling, while other advertisements for lottery tickets and slot machines depict ordinary people winning loads of money or millions from a single coin in the slot.

Around the world, various lobby groups claim that advertisements used by the gambling industry often border on misrepresentations and distortion. There are further claims that adverts are seductive, appealing to people’s greed and desperation for money. Real examples include: ‘Winning is easy’, ‘Win a truckload of cash’, ‘Win a million, the fewer numbers you choose, the easier it is to win’, ‘It’s easy to win’ and ‘$600,000 giveaway simply by inserting card into the poker machine’. Lobby groups further claim that in amongst the thousands of words and images of encouragement, there is rarely anything about the odds of winning – let alone the odds of losing. It has also been claimed that many gambling adverts feature get-rich-quick slogans that sometimes denigrate the values of hard work, initiative, responsibility, perseverance, optimism, investing for the future, and even education.

Those promoting gambling products typically respond in a number of ways. The most popular arguments used to defend such marketing and advertising is that: (i) the gaming industry is in the business of selling fantasies and dreams, (ii) consumers knows the claims are excessive, (iii) big claims are made to catch people’s attention, (iv) people don’t really believe these advertisements, and (v) business advertising is not there to emphasise ‘negative’ aspects of products.   While some of these industry responses have some merit, a much fairer balance is needed.

Statements such as ‘winning is easy’ are most likely (in a legal sense) be considered to be ‘puffery’. Puffery involves making exaggerated statements of opinion (not fact) to attract attention. Various jurisdictions deem it is not misleading or deceptive to engage in puffery. Whether a statement is puffery will depend on the circumstances. A claim is less likely to be puffery if its accuracy can be assessed. The use of a claim such as ‘winning is easy’ is likely to be considered puffery because it is subjective and cannot be assessed for accuracy. However, a statement like ‘five chances to win a million’ may not be puffery as it likely to be measurable.

Most of us who work in the field of responsible gambling agree that all relevant governmental gambling regulatory agencies should ban aggressive advertising strategies, especially those that target people in impoverished individuals or youth. It is also worth pointing out that there are many examples of good practice. Responsible marketing and advertising needs to think about the content and tone of gambling advertising, including the use of minors in ads, and the inclusion of game information. There has to be a strong commitment to socially responsible behaviour that applies across all product sectors, including sensitive areas like gambling. Socially responsible advertising should form one of the elements of protection afforded to ordinary customers and be reflected in the codes of practice. Children and problem gamblers deserve additional shielding from exposure to gambling products and premises, and their advertising. Many codes that regulate gambling marketing and advertising across the world now typically include special provisions on the protection of such groups.

Gambling advertising also plays an important role in ‘normalizing’ gambling. Content analyses of gambling adverts have reported that gambling is portrayed as a normal, enjoyable form of entertainment involving fun and excitement. Furthermore, they are often centred on friends and social events. The likelihood of large financial gain is often central theme, with gambling also viewed as a way to escape day-to-day pressures (one gaming company’s advertising even had the strapline “Bet to forget”). Research has found that there is a large public awareness of gambling advertising, and that problem gamblers often mention advertising as a trigger to gambling.

An example of good practice is that of Canadian gaming operator Loto-Quebec. They did a thorough review of its advertising code and some of the key aspects in terms of responsible marketing and advertising of gambling included:

• A marketing policy that (i) prohibits any advertising that is overly aggressive, (ii) rejects concepts liable to incite the interest of children, and (iii) prohibits the use of spokespeople who are popular among youth, and (iv) prohibits placement of advertisements within media programs viewed mainly by minors.
• The odds of winning are highlighted. This is being done in response to the suggestions expressed so frequently by various groups interested in knowing their chances of winning.
• Television commercials for new products devote 20% of their airtime to promoting the gambling help line and to presenting warnings about problem gambling.
• A policy that prohibits the targeting of any particular group or community for the purposes of promoting its products. For example, one of their instant lotteries used a Chinese theme to stimulate interest. However, the Chinese community did not agree with making references to its customs in order to promote the game. Out of respect for this community, the game was immediately suspended.

As various national and international advertising regulation bodies have advocated, socially responsible advertising should form one of the elements of protection afforded to ordinary customers and be reflected in the codes of practice. Personally, I believe that gambling advertising should focus on buying entertainment rather than winning money. Gambling problems often occur when an individual’s primary reason to gamble is to win money.

Many countries have strict codes for gambling advertisements, and good codes (like those in the UK) recommend that gambling advertisements must not: (i) exploit cultural beliefs or traditions about gambling or luck, (ii) condone or encourage criminal or anti-social behaviour, (iii) condone or feature gambling in a working environment (with the exception for licensed gambling premises), (iv) exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of under-18s or other vulnerable persons, (v) be likely to be of particular appeal to under-18s, especially by reflecting or being associated with youth culture, and (vi) feature anyone who is, or seems to be, under 25 years old gambling or playing a significant role.

Quite clearly it is appropriate and necessary for the gaming industry to advertise, market, and promote its facilities and products. However, I believe that all advertising and marketing should be carried out in a socially responsible manner as it is good for long-term repeat business.

Dr Mark Griffiths, Professor of Gambling Studies, International Gaming Research Unit, Nottingham Trent University, Nottingham, UK

Further reading

Adams, P. (2004). Minimising the impact of gambling in the subtle degradation of democratic systems, Journal of Gambling Issues, 11. Available at: http://www.camh.net/egambling/issue11/jgi_11_adams.html.

Binde, P. (2007). Selling dreams – causing nightmares? On gambling advertising and problem gambling. Journal of Gambling Issues, 20, 167-191.

Griffiths, M.D. (2005). Does advertising of gambling increase gambling addiction? International Journal of Mental Health and Addiction, 3(2), 15-25.

Griffiths, M.D. (2007). Brand psychology: Social acceptability and familiarity that breeds trust and loyalty. Casino and Gaming International, 3(3), 69-72.

Griffiths, M.D. (2010). Online ads and the promotion of responsible gambling. World Online Gambling Law Report, 9(6), 14.

Griffiths, M.D. & Wood, R.T.A. (2008). Responsible gaming and best practice: How can academics help? Casino and Gaming International, 4(1), 107-112.

Hanss, D., Mentzoni, R.A., Griffiths, M.D., & Pallesen, S. (2015). The impact of gambling advertising: Problem gamblers report stronger impacts on involvement, knowledge, and awareness than recreational gamblers. Psychology of Addictive Behaviors, in press.

Korn, D, Hurson, T. & Reynolds, J. (2004). Commercial Gambling Advertising: Possible Impact on Youth Knowledge, Attitudes, Beliefs and Behavioural Intentions. Report submitted to the Ontario Gambling Research Centre.