An example of good practice, possible to follow
By Dan Iliovici, Vice-President ROMBET
Six years ago, in early 2018, I published “Code of conduct regarding responsible communication in the field of gambling”, in an attempt to lay the foundations for a self-regulation of our industry in terms of responsible marketing.
In the meantime, I have noticed that gambling operators in more and more states are adopting such codes of conduct, in an example of responsibility, for the sustainable development of our industry.
Thus, in an attempt to go beyond the specific (laudable) statements and practices of some operators operating on the Romanian market, I will present some such codes of conduct from several European states. I hope that all of this will give operators and affiliates in Romania an impetus to create and adopt such a code of ethics for responsible marketing.
As an introduction, here is what is stated in the preamble of the “Marketing Guide” of the Swedish gambling industry, published and adopted in 2019:
”Marketing is an important part of a functioning market and in order to be able to reach out with information to consumers about their different choices. The fact that this marketing takes place in a responsible manner is particularly important in the gaming industry, since all games can pose a risk to gaming problems.
The Swedish gaming industry’s marketing guidelines (the Guidelines) complement and interpret existing legislation on marketing, for example the Marketing Act, including good marketing practices, the game law, adhering government regulations and conditions in the respective member’s permit / license for the business.
The guidelines are unanimously adopted by the Industry Association for Online Games (Bos) and the Gaming Industry’s National Association (Sper). The purpose of the guidelines is to describe what constitutes a minimum level of good marketing practice in the gaming industry.”
For this first article on the stated topic, we reproduce below the recent “Memorandum for responsible advertising in gaming”, adopted by online gambling operators operating on the market in the neighbouring country, Bulgaria.
Memorandum between licensed online gambling operators on responsible gaming advertising in the republic of Bulgaria
”Today, 12/12/2022, the present Memorandum was concluded between the licensed operators, referred to as the Parties.
Considering that:
• Gambling is a responsible, dynamic and cooperative industry;
• Advertising of gambling games in the Republic of Bulgaria is regulated in Art. 10
of the Gambling Act.
• The online gambling operators adhere to the permitted content of advertising messages under Art. 10, para. 2 of the Gambling Act, taking into account the prohibition of direct advertising and its definition but intends to self-regulate with additional restrictions in view of the public interest.
Having in mind that:
The desire of the industry to establish a practice for the advertising of gambling games in a socially responsible manner to protect vulnerable groups from gambling addiction.
The parties agree to adhere to the following measures and restrictions during the calendar year 2023:
1. The Parties shall not allow persons under the age of 23 to participate in gambling advertisements;
2. The parties will not allow the amount of monetary and/or material prizes and bonuses to be communicated in radio and television advertising.
3. The parties will not allow the positioning of outdoor advertising in the immediate vicinity of schools.
4. The Parties shall not schedule and allow the broadcasting of television advertising of gambling games in the time range 5:00 a.m. – 6:00 p.m., except within the framework of broadcasted sports events.
5. Any advertising broadcasted on radio and/or television will contain responsible
gambling message.
6. The Parties will amend their affiliate program rules to expressly include in each Party’s rules posted on the Site that the partnership will be terminated in the event that the affiliate/partner
advertises/distributes/drives traffic to unlicensed sites for online gambling on the territory of the Republic of Bulgaria.
7. The parties will terminate partnership with affiliates/partners who advertise/distribute/attract traffic to unlicensed online gambling sites on the territory of the Republic of Bulgaria.
8. Parties shall avoid representing participation in gambling as:
• possible solution to social, educational, personal or professional problems;
• an alternative to employment, a solution to financial problems or a form of financial
investment;
• priority in life, for example over family, friends, professional or educational
commitments.
9. The parties agree not to place gambling advertising on children’s and youth sports clothing in the future.
For the implementation of the agreed measures, the Parties will cooperate with the media, the Council for Electronic Media, the National Self-Regulation Council and the National Revenue Agency.
The parties agree to comply with the Ethical Rules for Advertising and Commercial Communication of Gambling Games.
This Memorandum is considered to be a multilateral instrument and all future online
gambling operators are invited to join it after obtaining a license under the Gambling Act.
The Memorandum can be supplemented and amended with annexes, if necessary.
Each of the Parties accedes to this Memorandum by signing a declaration. The
declarations signed by the Parties constitute an integral part of the Memorandum and bind the Parties to its contents.”
I will continue to present examples of such codes of responsible communication in the following issues of Casino Life & Business Magazine, and, as always, I await readers’ suggestions and comments on the Facebook page of the ROMBET association.
As I have shown in one of the previous articles, when we want to identify the effectiveness of measures to limit the negative effects of excessive gambling, it is very difficult to establish the degree to which one measure is better compared to another. This is primarily due to the overlapping effects of different responsible gambling measures, but also the difficulty of obtaining clear data from operators and players.
If in the case of online gambling platforms, a multitude of data on each player can be made available to researchers (time spent playing, amounts bet, win/loss, etc.), for traditional gambling it is much more difficult, if not impossible, to find out all these data, due to the anonymous character of the place.
Finally, even in the case of online gambling things are not simple. Considering the fact that a player can be registered on several platforms, belonging to different operators, the lack of a database that uniquely identifies each player does not allow finding out all the information necessary for the study.
