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Phillip Graf
Chair of Gambling Commission
[email protected]
[email protected]
[email protected]
18 August 2014
Dear Mr Graf
I write regarding the Gambling Commission’s current consultation on socially responsible gambling
with specific reference to a current example of an issue which I think is inequitable and also
socially irresponsible. The matter I highlight I feel has specific reference to paragraph 11.28 of the
consultation:
http://www.gamblingcommission.gov.uk/pdf/Proposed%20amendments%20to%20social%20respo
nsibility%20provisions%20in%20LCCP%20consultation%20August%202014.pdf
The Act specifically gives the Commission the power (section 81(1)) to set general licence
conditions to be attached to an operating licence which could, ‘in particular, restrict or otherwise
make provision about the making of offers designed to induce persons to participate, or to
increase their participation in, the licensed activities’.
The Sun newspaper recently launched it Dream Team fantasy football competition which I
understand from their website is regulated by the Gambling Commission. I have seriously
concerns about a date with a page 3 model being offered as a socially responsible incentive to
gamble.
Bluntly, if you break it down to its building blocks: it’s a symbolic consumption of gender in 2014, a
tourist gaze on women. How creepy does that sound never mind the reference to a “creepy uncle”
in the website!. Then over the weekend we saw further distortions in the vision/consumption of
gender, with even fantasy football, sexualised to male presumably heterosexual and unmarried,
titillation in terms of giving as an incentive a date with a page 3 girl!
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The literal and symbolical consumption of women via page 3 has to stop and using it as a
marketing for something licensed and regulated by the Gambling Commission seems highly
inappropriate. It’s part of a continuum of consumption, objectification, violence and abuse of
women, if we are serious about ending serious issues of social harm e.g. violence against women,
we need to take a long-term preventative approach. to all aspects of gender equality, page 3 is
one of the visual icons of gender inequality, a sign! I’m aware getting rid of page 3 won’t equalise
society completely, stop violence against women overnight but it’s a good and valid place to start
and offering it as an incentive to gamble seems plainly wrong!
In a debate in the Scottish Parliament led by Jackie Ballie MSP, the now Cabinet Secretary for
Equalities at the Scottish Government Shona Robison MSP noted the link between sexualised
images of women and the likelihood that sexual predators and criminals will act on a view of
women that they are no more than a summary of body parts. Therefore it doesn’t seem to me that
offering a date with a girl as an incentive to gamble is particularly socially responsible.
The consultation goes on to outline that the Commission’s approach to fair and open marketing
and advertising should be seen against the backdrop of the wider Government review of gambling
advertising. This review, announced in March 2014 seeks to ensure that the regulatory controls
are properly examined, especially in relation to children and other vulnerable people. In relation to
the latter category I would hope that you will have cause for concern to act.
Also given a number of page 3 models are reported in the Sun newspaper to be under the age of
25 I would welcome your consideration now and as part of the consultation analysis of whether
such an incentive is within the current spirit of the ordinary code provision 5.1.6 [pages 78-79] and
should the advertisement have to make this clear in the current “incentive” information!
Marketing communications must not include a child or young person. No-one who is, or seems to
be under 25 years old may be featured in gambling. No-one may behave in an adolescent, juvenile
or loutish way. However, the restriction on allowing people who are, or seem to be, under 25 years
old (ie: those in the 18-24 age bracket) to appear in marketing communications need not be
applied: However, the particular restriction on allowing people aged under 25 to appear in adverts
need not be applied:
a. In the case of non-remote point of sale advertising material, provided that the images used
depict the sporting activity that may be gambled on and not the activity of gambling itself and do
not offend any other aspect of the advertising codes.
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b. In the case of remote gambling, provided that the images ‘appear in a place where a bet can be
placed directly through a transactional facility, for instance, a gambling operator’s own website.
The individual may only be used to illustrate specific betting selections where the individual is the
subject of the bet offered. The image or other depiction used must show them in the context of the
bet and not in a gambling context’ (as provided in CAP code rule 16.3.14).
On the basis of this concern I have also copied this response to the Secretary of State for Culture,
Media and Sport given the current wider review. Also, given it relates to a live issue which gives
me cause for complaint I have also copied this consultation response to the Remote Gambling
Association, Ofcom and Advertising Standards Authority for their consideration of my complaint
and concerns.
I look forward to your reply and hope that your consultation will seriously consider the social
responsible gambling marketing has not to promote violence towards women or the objectification
of women as prizes/incentives to gamble.
Kind regards
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