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Chapter 2
Key issues around the promotion of sports betting
2.1
Over the course of its inquiry, the committee sought updates on matters
covered by its comprehensive 2011 report, Interactive and online gambling
and gambling advertising, which delved into most of this inquiry's terms of
reference. The key concerns that emerged during the current inquiry centred
around the pervasive nature of the promotion of sports betting, its integration
into sporting commentary and the possible effects on children and vulnerable
people from this high level of exposure.
Wagering industry
2.2
In its 2010 report, the Productivity Commission (PC) estimated that
sports betting represented 1.2 per cent of the $19 billion spent on gambling
and that sports wagering has experienced continued rapid growth since the mid
1990s.[1]
The committee's previous report cited research that for the 12 months to
September 2011 sports betting expenditure increased from $0.4 billion to $0.8
billion.[2]
2.3
Mr Cormac Barry, Chief Executive Officer, Sportsbet and Chairman,
Australian Wagering Council[3]
(AWC) told the committee that the members of the AWC collectively have two
million members.[4]
While acknowledging the significant increase in the amount of advertising, Mr
Barry added that the annual growth in wagering turnover over the past five
years has been in line with the growth of the economy at four to five per cent
per year. He informed the committee that within overall wagering there has been
a shift from the traditional channels for placing bets through retail TABs, by
telephone and at racetracks to online betting.[5]
40 per cent of Australian wagering now takes place online, 40-45 per cent
takes place at the TAB and only a small proportion occurs over the phone.[6]
2.4
Mr Barry stressed that the ability to advertise, along with increased
competition and improvement in products, has led to more Australians placing
their bets with onshore operators.[7]
High levels of sports betting advertising
2.5
The committee recognises growing community concern with the
proliferation of sports betting advertising over recent years. During a
sporting broadcast there are not only sports betting advertisements, and live
odds updates but betting in some cases became part of the sporting commentary.
Even at venues sports fans are exposed to gambling advertising, including live
odds updates and sports betting signage.
Battle for market share
2.6
The AWC explained that the high levels of sports betting advertising are
a function of a highly competitive market. Customers have low brand loyalty and
are on the lookout for the best deals given the low costs of switching between
domestic and international providers. In addition:
Due to restrictions placed on the industry from operating
land-based outlets, advertising is essential to enable the industry to
genuinely compete with land-based retail outlets, such as TABs.[8]
2.7
Mr Cormac Barry provided further background and told the committee that
the high levels of advertising reflect a 'battle for market share within the
wagering sector' following the 2008 decision of the High Court which opened up
advertising for corporate bookmakers. He submitted that 'sports betting is a
niche pursuit' which in his view will remain the case 'no matter how much
advertising the industry does'.[9]
He emphasised that the number of people gambling on sports is not increasing
but there is a shift from the traditional channels of placing bets to online
betting.[10]
2.8
Mr Barry told the committee that the primary objective of advertising is
to gain market share and take business from competitors within the sector.[11]
He added that this is achieved by the advertising raising brand awareness with
the people who bet: 'it is not necessarily to create new betters'.[12]
To reinforce this point he cited evidence that the wagering industry is not
growing in real terms.[13]
Mr Giles Thompson, Chief Executive Officer, Betfair; and Treasurer, AWC,
confirmed that advertising is targeting 'people who are currently betting' and
'those who are interested in betting'.[14]
2.9
Associate Professor Samantha Thomas pointed out that the argument from
the industry that they are only targeting existing gamblers is counterintuitive
for a business where you would expect they would be looking to grow their
market. She explained that the same argument was used by the tobacco industry:
'they were not trying to get more people to smoke, they were or are just trying
to get people to switch brands'.[15]
The amount of wagering advertising in a family friendly environment
2.10
The committee heard how this avalanche of sports betting advertising is
overly intrusive and ruining fans' enjoyment of the game. However, over and
above the annoyance factor, are concerns which focus on the normalisation
effect of industry marketing strategies, particularly on children.[16]
Evidence showed clear concern about the high level of exposure of children to
the promotion of an adult product in what is marketed as a family friendly
environment.[17]
2.11
During its last inquiry the committee was briefed on research which
showed the high level of exposure to gambling advertising during broadcasts and
at venues and the embedding of marketing strategies in the game.[18]
The research conducted by Associate Professor Samantha Thomas and Associate
Professor Colin McLeod found that supporters at a match were exposed to an
average of 341 minutes of gambling advertising when simultaneous promotions
were counted separately.[19]
2.12
Ms Heather Gridley, Manager, Public Interest, Australian Psychological
Society (APS) referred to this research and stated:
So you are talking about an awful lot of messages. Once
again, they probably would not be there if they were not meant to be effective,
and you cannot imagine that children are immune from that. And I think there is
that aspect of the language itself becoming part of it. It is very hard to talk
about sport now without talking about what are the odds or who you are betting
on, who you are tipping and all those sorts of things. There is nothing wrong
with that in itself, but if that becomes the only language in which we speak
about sport, it is hard to imagine children being immune to that.[20]
Normalisation effect
2.13
During the committee's previous inquiry it heard that while the
advertising is not directly marketed to children and children cannot consume
the product, they are nevertheless absorbing the message. In addition, the
constant promotion of live odds at matches and within game play during
broadcasts may have a normalising effect on children. This is because there is
a blurring between advertising and the game so children may consider the live
odds, for example, to be part of the game. As Associate Professor Samantha
Thomas noted during the previous inquiry when asked about the possible long-term
effects on children:
We can probably make an educated guess, that, as with those
products [tobacco, alcohol and junk food]. Kids are being softened to this. It
is becoming part of their talk...Kids are consuming those messages. They are
consuming the brands. What we do not know is what long-term impact it is having
on them and what will happen over time in terms of encouraging them to engage
in gambling...[21]
2.14
The APS emphasised that the amount of gambling advertising has the
effect of normalising it by making it an integral part of sport which
influences the attitudes of children and young people.[22]
This was confirmed by Dr Christopher Hunt from the Gambling Treatment Clinic at
the University of Sydney who noted that traditionally, sports such as the AFL
and NRL have been marketed towards families and:
By normalising wagering associated with these sports, there
is a high risk that the prevalence of problem gambling will increase as
generations who have grown up with ubiquitous discussions of gambling around
sport reach the legal gambling age.[23]
Brand recognition
2.15
While recognising there needs to be more research on the effect of
gambling advertising on children, Associate Professor Thomas indicated that it
should not prevent action on something that is 'potentially incredibly
problematic for children and vulnerable members of our community'.[24]
She pointed to preliminary data that may be indicative of some of the harm:
For example, one of the things we know from our research with
young people is that they have a very high awareness and recall of brands. This
is unprompted. When we ask young people whether or not they know of any
gambling-industry brands they are able to come up with at least two or three
names of companies.[25]
That is concerning for us. Quite often, children also have a much higher recall
of advertising and brand names than their parents and adults generally. So
certainly we see that children are recognising and are aware of the products
and companies, and this obviously is concerning for us—particularly when
thinking about long-term behaviours and harm.[26]
2.16
The committee notes the picture below,[27]
which shows children obtaining an autograph from Mr Tom Waterhouse. The picture
indicates how well recognised he is.
Vulnerability of children to
advertising
2.17
The committee heard that young people are at risk as they are particularly
susceptible to advertising. In 2010 the Productivity Commission pointed out
Canadian research that found:
42 per cent of youth reported that gambling advertisements
made them want to try gambling and that 11 per cent of males and 3 per cent of
females sometimes or often gambled after seeing an advertisement (Derevensky et
al 2007, p. 27).[28]
2.18
The Victorian Responsible Gambling Foundation agreed that the concern
about exposing children to high levels of gambling advertising is valid
because:
- research shows children under 11 have difficulty distinguishing differences
between advertising and program content. In particular, children under 10 have
difficulty understanding the persuasive intent in advertising;
- recent research indicates that it is successful in creating an
attitude in those aged 13-18 that gambling is 'entertaining, harmless and
convivial' which undermines the development of a responsible approach to
gambling;
- the use of sports stars or media celebrities to promote gambling
and the use of social media contributes to the difficulty young people have
separating marketing material from neutral content.[29]
2.19
The APS summarised that young people are particularly at risk of harm
because:
-
they are already more susceptible to gambling advertising
(Lamont, Hing and Gainsbury, 2011) and vulnerable to gambling, with research
showing that a substantial proportion of secondary students indicate that they
gamble online (Delfabbro et al, 2005);
- of their familiarity with and widespread use of emerging
technology (particularly mobile phones) in all aspects of their lives;
- of fewer checks for age appropriateness in forms of sport
gambling (apart from the use of a credit card), and the likelihood it can be
engaged in in isolation from others (such as parents or other adults);
-
the use of young people's sporting 'heroes' by sporting
organisations to promote gambling opportunities; and
- young people growing up with sports betting as an integral and
'normal' part of their experience of sport, particularly those sports that are
popular among young people (such as AFL). This includes the likelihood that
young people have witnessed their parents and other adults wagering, so are
more likely to see it as a socially acceptable activity.[30]
2.20
The APS advised that, while there has not been a lot of research on the
possible effects of the increased availability of gambling opportunities and
the promotion of sports betting, gambling research generally shows that:
...an increase in exposure to gambling advertising and
opportunities is a risk factor for the development of gambling problems,
particularly among vulnerable groups in the community.[31]
Minimising possible harm
2.21
Associate Professor Thomas emphasised that the approach to gambling
marketing should be to minimise and, more importantly, prevent harm:
While industry claims that the point is that advertising
should not target children, in my opinion the actual point is that children
should not be exposed to advertising for this potentially harmful product—this
includes in sporting matches, which are, as you know, marketed as being family
friendly. The national preventative task force argued in relation to obesity,
alcohol and tobacco that, where the market is failing, or governments need to
act to protect our health, particularly the health of children and adolescents,
standards need to be established, regulations imposed where necessary and
consumer education provided. They go on to say that balanced, effective
regulation and legislation, usually alongside effective and sustained public
education, has been an essential element of most prevention programs to date
and there is no reason this should not also apply to gambling.[32]
2.22
This was supported by the APS which spoke about the need to restrict
advertising to ensure less harm:
I think that we have dealt with tobacco. It is a really good
example, because people still smoke and smoking is not illegal. But we have
really restricted advertising and, lo and behold!, people—the television
stations and sporting organisations—have managed to get sponsorship from other
places. They haven't gone under. So I think it ought to be possible to do
something different with these kinds of things. Without being a nanny state, it
should still be possible to look at restricting these things to the point where
they are going to do the least harm, and if they were going to do the least
harm then probably they would not be worth investing in as advertising. So
there is a balance there.[33]
2.23
Relationships Australia believes it is logical to conclude that any
problems created by exposing children to gambling advertising can only grow as
the amount of such advertising increases:
In spite of lack of evidence, it is reasonable to surmise
that early and frequent exposure to sports betting is likely to have
significant influence on the gambling habits, and therefore future wellbeing,
of young people.[34]
Concerns about other subgroups
2.24
Concerns were also expressed about the effects of the high level of
exposure to wagering advertising on the gambling behaviour of young men and
problem gamblers.[35]
Young men
2.25
The Victorian Responsible Gambling Foundation advised that the profile
of those betting on sport is primarily young men in their twenties and early
thirties.[36]
The committee heard through its previous inquiry that sports betting
advertising has contributed to young men watching sport through a 'gambling
prism'. Research showed that young men felt bombarded, targeted and unable to
escape the advertising.[37]
As argued by FamilyVoice Australia, sports fans, predominantly young men, 'now
talk more about "the punt" than the game.'[38]
2.26
Associate Professor Samantha Thomas told the committee her research
indicated that young men talk about feeling isolated from their peer group if
they do not gamble. She pointed out this is concerning as it is similar to alcohol
'when you did not want to be the only guy in the group that did not drink'.[39]
She reported that young men will choose a sporting match to attend where team
preferences are not an issue and use gambling on the match as a mechanism for
socialising. Associate Professor Thomas indicated that as with other public
health issues, these social elements make such behaviour harder to change.
Young men also talk about sports betting as a skill rather than luck based
activity.[40]
Problem gamblers
2.27
Dr Christopher Hunt noted that the confluence of wagering and sport has
existed in horse and dog racing for many decades but most other sports have
existed independently of wagering. If wagering is seen as part of the sport
there is a high risk that over time wagering will be taken up by more people
than presently engage in it. Dr Hunt noted that while not everyone who takes up
wagering will go on to develop a gambling problem, a proportion will and
therefore the incidence of problem gambling is likely to increase over time.[41]
This view was supported by the APS.[42]
2.28
The Victorian Responsible Gambling Foundation indicated that information
from the Foundation's counselling services databases and feedback from
counsellors is providing 'indicative evidence that gamblers presenting for help
with sports gambling are growing in total numbers and as a percentage of all
clients'.[43]
2.29
The Royal Australian and New Zealand College of Psychiatrists indicated
there is strong evidence of the relationship between the advertisement of
products that lead to gambling and subsequent problem gambling behaviour.[44]
Integration of gambling into the match
2.30
Associate Professor Thomas emphasised to the committee that the issue is
not just about the promotion of live odds but there is a 'relative tsunami of
the promotion of gambling products through multiple marketing channels within
our sporting matches'.[45]
Associate Professor Thomas explained that in line with their expectations they
have seen a shift towards increased embedding of advertising within sporting matches.
She expressed particular concern about marketing promotions that seek to create
'brand awareness' through the integration of promotional activities with match
broadcasts. Evidence from the areas of alcohol and tobacco indicate that it is
more difficult for individuals, both adults and children, to separate out and/or
avoid these 'embedded' forms of marketing.[46]
She added:
It is suggested that by the age of about five the majority of
children are able to differentiate between programming content and television
commercials, although they may not be able to understand the persuasive intent
of advertisements until they are about seven or eight years of age. However,
the commercial intention behind sponsorship is conceptually less well
understood by the children. Only when they reach the age of about 12 [do] they
understand the role of sponsorship in influencing consumption attitudes and
behaviours.[47]
2.31
The Gambling Treatment Clinic at the University of Sydney noted that the
'constant intrusion of wagering into the sporting discourse has the effect of
making wagering appear to be an integral and normal part of enjoying sports'.[48]
Committee view
2.32
The committee shares the concern in the community about the promotion
and advertising of sports betting and the influence it may be having on
children and young people. NRL and AFL in particular market themselves as
family friendly sports and there are legitimate concerns about the longer term
effects of exposing children to such a high level of sporting betting
advertising. The committee acknowledges the intention by the industry and
sports not to market directly to children but with the high level of gambling
advertising and the many forms of marketing (signage, uniforms, general
gambling advertising etc) the committee is also concerned about the level of
indirect marketing on children and its possible effects. It believes a cautious
approach is necessary. The current rules around broadcasting and exemptions for
gambling advertising are detailed below as well as the policies of wagering and
sport in relation to children and vulnerable groups.
Current broadcasting restrictions and exemptions for gambling advertising
2.33
Free TV informed the committee about current broadcasting restrictions
which have been targeted to ensure that gambling and sports betting
advertisements are not placed in programs likely to have a substantial audience
of children. While gambling advertisements are not permitted during G
classification periods, exemptions are made for news, current affairs and
sporting programs.[49]
Broadcasters pointed out that these restrictions have resulted in low levels of
complaints.[50]
2.34
The Productivity Commission advised that the exemption appears to be
inconsistent with the general principles concerning exposure to gambling by
children and noted:
That inconsistency may be becoming more marked as the
frequency of in-commentary gambling promotions during televised sport increases
(through, for example, continuously posted odds and the conspicuous
identification of betting agencies).[51]
2.35
Free TV argued that sporting events on free to air TV are primarily
watched by adults. Children aged 5-17 made up less than 12 per cent of the
total viewing audience of any of the top 10 sporting events in 2012. In
addition, of those watching, the majority[52]
were viewing with an adult.[53]
Mr Andrew Maiden, Chief Executive Officer, Australian Subscription Television
and Radio Association (ASTRA) stated that to put the data in context:
...the average number of children under 18 watching any of
those top-50 li[v]e sports broadcasts last year was something like 39,000. So,
relative to our reach—which is 2.2 million homes, or seven million Australians—we
submit that number is relatively small.[54]
2.36
Ms Bridget Fair, Group Chief, Corporate and Regulatory Affairs, Seven
West Media admitted that there are likely to be more children watching a
sporting program like the AFL than a program directed specifically at children.
However, she stressed that the viewing experience is very different.[55]
Mr Scott Briggs, Director of Commercial and Regulatory Affairs, Nine
Entertainment Co. advised the committee that for a Friday night NRL game there
would be around 50,000 children aged 17 and below from an audience of 700,000.
He indicated this would be the same numbers for some of their children's
programs.[56]
2.37
The committee notes data indicating that AFL is one of the top three
television programs watched by children under 14 years.[57]
Wagering sector
2.38
The AWC accepted that advertising must be conducted in a socially
responsible manner 'and must be of a reasonable limit so as not to contribute
to the encouragement of gambling, particularly amongst the most vulnerable'.[58]
It stressed that 'AWC members do not directly target their industry advertising
and promotional strategies to children'.[59]
Mr Cormac Barry, Chief Executive Officer, Sportsbet Pty Ltd; and Chairman, AWC,
informed the committee of the sophisticated mechanisms in place to verify the
age of people who bet with them. In addition they use responsible gambling
messages in the promotion of their product.[60]
2.39
Mr Barry highlighted the data from Free TV indicating that there are low
numbers of children watching sport and most are accompanied by an adult:
I think there is a role here for parents to educate children
about the risks associated with gambling, and that would be consistent with
other products in society, such as alcohol or other adult related issues, like
sex education and so on. I do not think it is possible in the modern age for us
to create a bubble around our children, where they will not be exposed to adult
products.[61]
2.40
Mr Giles Thompson, Chief Executive Officer, Betfair, and Treasurer, AWC
concluded that:
The key thing here is that advertising should not be targeted
at children. That is the key. That is the fundamental point. Banning it in
G-rated program is a way of trying to achieve that. That does not necessarily
mean that it is the best way to do it, but it is a way of trying to achieve
that. What are we trying to achieve? We are trying to make sure that
advertising does not target children.[62]
Sport
2.41
In relation to the exposure and influence on children, the Coalition of
Major Professional and Participation Sports (COMPPS) commented:
The COMPPS members are aware of concerns that the promotion
of live odds during sports coverage risks normalising gambling behaviour. This
was a factor in the recent decision to remove references to live odds from
in-play broadcasts and in stadia, and to restrict commentators from discussing
live odds. There was a sense that some commentators were seen as role models
and that it was inappropriate for them to be involved in discussing live odds.[63]
2.42
Sports emphasised that guidelines have been put in place to ensure that
sports betting should not be targeted at minors or provide products targeted at
minors.[64]
The NRL highlighted their wish to take a proactive and cooperative approach to
put agreed principles and safeguards in place.[65]
Mr John Brady, General Manager, Media and Communications, NRL, acknowledged the
difficulty with developing the right messages given the wide audience:
We are very, very mindful of and absolutely committed to the
integrity of our game. We are very mindful of and very committed to the welfare
of our community participants—the people who play the game at a junior level;
the people who come to the game—and we try to have systems in place that
communicate a responsible message to those people. To go to the point that was
raised earlier in this hearing, some of those messages can be difficult because
ours is a game that transcends every age group and a large part of society. We
do work very hard to internally regulate, and we do very often work with
government to try and make sure that we are heading in the right direction.[66]
Committee view
2.43
The committee supports the approach of not directly targeting children
but is concerned with the high level of indirect marketing and its effects on
children. While the industry[67]
and sports[68]
argued it is a legal product, gambling advertising is all around us and it is
difficult to ensure it does not reach children; the committee makes the point
that what is promoted at the game is able to be controlled by the stakeholders.
The industry argued that policies need to be based on evidence.[69]
As policy can often take time to catch up with new marketing strategies,
quality peer reviewed research takes time and given the possible effects could
include increased problem gambling, the committee believes a precautionary
approach regarding the exposure of children and vulnerable people to gambling
advertising is warranted. Chapter 3 will detail the response underway.
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