Our relationship with our players is paramount. We get to know them and tailor our products around their needs, so that we form long-term bonds that give us more sustainable revenue. The key to this is providing both a fun and safe environment for players to play in, and we are committed to proactively assessing, managing and mitigating the risk of our players developing problem gambling behaviours. We take this commitment seriously and see it as a marketplace differentiator. We’re already seen as a responsible gambling leader and it is one of our five strategic business goals to develop this further this year.
Accountability for the Group’s approach to responsible gambling rests with the Board, who are supported by the newly formed ESG Committee.
We are first and foremost an entertainment company so our products must be fun. We provide a fully rounded entertainment experience and whilst gambling is a significant part of this, nearly half of our website use (46%) is for non-gambling related activities, including free games and chat rooms. Having this breadth of service helps us to cement longer-term relationships with our players.
The quality of our players’ experience is extremely important to us and so we are highly selective about the games we offer. We conduct detailed statistical analysis on the use of our games, but we also rely heavily on player feedback, which we actively use to shape the games we have on site. We gather this feedback in a number of ways:
- Twice-yearly player satisfaction survey: In 2019 the survey questions were refreshed and for the first time we surveyed not only our players but also 3,500 players of 12 other brands. The feedback received was overwhelmingly positive, with an overall satisfaction and net promoter score for all Gamesys’ brands significantly exceeding the peer group average.
- Annual responsible gambling survey: This survey is specifically to understand player views on responsible gambling and the tools we provide.
- Online research community: C.9,000 of our players form our voluntary online research community, ‘VoiceBox’. We use the community for piloting new games, trialling advertising and conducting ad hoc surveys.
- Focus groups: On specific projects we engage focus groups of players and non-players in our dedicated focus group room. Almost 20 of these sessions were held in 2019, some of which were observed by members of the Board.
- Chat rooms: We monitor comments on our chat rooms and use this as a source of feedback, as well as hosting chat room conversations specifically designed to gather feedback.
The player insights we receive are actively used to drive change in the business. For example, when we developed new theme ideas for one of our brands, we tested these on our VoiceBox community. The winning themes were then brought to life by our in-house design team and in a subsequent survey to VoiceBox players, 76% were found to find the games appealing.
Trust is the foundation for our relationship with our players and it facilitates an enjoyable recreational experience. Imperative to this is operating fairly and providing a safe environment for our players to play in. We’re proud of our work in this area and the findings from our latest available player survey showed that, on a scale of 0-10, we were rated as 8.1 for trustworthiness and 8.3 for taking responsible gambling seriously, both industry-leading scores.
We recognise, however, that there is a risk that a small number of our players may lose control of their gambling activity. We’re committed to reducing this risk and as a minimum meet all regulatory and licensing requirements, going beyond these in many instances.
We deliver our commitment to responsible gambling in a number of ways:
- Player-centric product design: We design our products with our players in mind, including territory-specific control mechanisms to ensure players are over the legal age in territory and a range of tools to help control gambling. These tools include deposit limits, session reminders, self-exclusions and cool-off periods. Quarterly communications to players on responsible gambling tools were rolled out globally in 2019. New UK players also receive responsible gambling communications within 24 hours of joining, with additional interactions if their risk profile changes. In our latest responsible gambling survey, 96% of players said it was easy to find and use the tools.
- Responsible marketing: We’re committed to ensuring that we market activities in a fair, transparent and responsible way, whilst maintaining data security and ensuring that our affiliate marketing meets our regulatory obligations. We ensure advertisements only target people over the legal age for gambling.
- Management procedures: We have a robust framework of procedures and processes in place to identify, manage and respond to suspected problem gambling. These are based on the five “I”s.
- Identify: We use complex machine-learning algorithms to continually monitor gambling behaviours, allocate individual player risk ratings and identify potential players at risk. We also have a dedicated email address for employees to raise any concerns they may have about a player. VIP players are more closely monitored and must go through a risk-assessment onboarding process and frequent on-going gambling reviews. Positively, year on year we have seen the percentage of active players considered at risk of, or experiencing gambling-related harm, reduced from 7.7% in 2018 to 7.4% in 2019.
- Investigate: Our skilled responsible gambling teams analyse account information using an intelligent review system.
- Interact: Where there are concerns for a player, our response is tailored procedurally to the level of need. For example, interventions may begin within 15 minutes for urgent cases, or for more minor concerns, phone calls, automated emails and site pop-ups may be used.
- Intervene: Where we believe problem gambling exists we will provide advice and support to players, and immediately close their accounts. One of the benefits of the majority of our products now being hosted on proprietary technology is that we can do this in real time. For UK players we will directly transfer their call to counsellors at GamCare (we were one of the first in the industry to do this), fund GamBan (device software which blocks access to gambling) on our player’s behalf and talk players through how to register on GAMSTOP (which stops players being able to play on other gambling sites). We do not allow players registered with GAMSTOP to use our websites. Players who wish to return after an agreed self-exclusion (minimum duration six months) has lapsed must speak to our support staff and be supervised through their return to play with deposit limits also put into place.
- Impact: We use our dedicated insights team to examine the impact of our interventions. For example, in a recent analysis they found that 84% of players who received an intervention call from our responsible gambling team saw a reduction in their algorithmic risk rating after seven days. The insight team’s latest research is continually used to hone our algorithms, thresholds, limits and other responsible gambling tools.
- Resources: All of our employees are trained in responsible gambling and we instil a culture of care through our Gamesys DNA. We operate two dedicated responsible gambling support teams, covering all markets and, for our largest market, the UK, these are available to players 24 hours a day. Our 23 responsible gambling team staff are extensively trained in their specialist skills, with such training designed by third-party experts
Problem gambling is an industry-wide issue so we proactively work with our peers, industry experts and charities to share information and drive change. Our commitment to collaboration is reflected in our recent decision to join the Betting and Gaming Council (‘BGC’), an industry body championing progressive, beyond-regulatory standards of responsible gambling. We actively support their goals and senior Gamesys Group employees participate in three BGC sub-committees.
Another important peer group collaboration we’re involved with is being led by EQ-Connect. This pioneering project involves sharing player data with other participating companies in order to better facilitate the early identification of at-risk players. We are one of the first companies to have engaged with this scheme.
In a new two-year partnership with Wolverhampton’s Citizens Advice Bureau we are sponsoring an apprentice to run a web chat service providing advice on debt management. In return we will be given access to anonymised data on debt issues and the relationship between gambling and debt, for our insights team to analyse. The Citizens Advice Bureau will also be providing our staff with training on financial debt management.
It is one of the Group’s five strategic priorities, ‘Putting the player first’, to continually evolve our approach to responsible gambling and keep ahead of the pack. Headline achievements in 2019 include rolling out the GamCare call transfer service, removal of credit card payments in the UK (prior to the required effective date) and new research into how to most effectively communicate on responsible gambling. The latter research, which was conducted by behavioural science experts, will be used to trial, iterate and improve player communication over the coming months.
Following the uniting of our two companies, the Chief Product Officer has taken responsibility for spearheading the streamlining and progression of responsible gambling initiatives, supported by a newly appointed project manager. Progress updates are regularly provided by the Chief Product Officer to the ESG Committee and the CEO. Our multiple improvement workstreams centre around three focal areas – learn, care and inform.
Invest in research to understand the drivers of problem gambling so that we can make a real difference.
Creating a caring environment by investing in education and support whilst applying globally and locally defined player care standards.
Develop a ‘Player Care’ sub-brand, widely known by our players.
We operate a robust risk assessment and mitigation process to prevent the business being used for money laundering. Core to this is knowing our players, and we operate both automated and manual methods to verify a player’s age, identity and source of funds.
Anti-money laundering (‘AML’) risk assessments are conducted at a minimum on an annual basis, with additional assessments for significant business changes (e.g. launch of a new product, expansion of operations to a new jurisdiction etc.). Where significant risks are identified (e.g. a politically exposed person, presence of sanctions etc.), mitigating controls are implemented. Responsibility for our AML procedures rests with our two money laundering reporting officers, who together cover all markets.
All employees receive training on their responsibilities relating to AML and additional targeted training is given to roles relating to higher risk areas. Gamesys Group successfully completed a corporate evaluation by the UK Gambling Commission at the end of 2019.