Genting UK Safer Gambling Strategy 2019 2021
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Foreword Paul Willcock President & Chief Operating Officer Genting UK Genting are rightly proud of their track record in respect of Safer Gambling, however we are aware we cannot stand still and must continue to make progress in this area which is at the heart of everything we do. To that end we have set out our strategy for the next three years in this document. Key to achieving our ambitions will be our staff, their engagement with this strategy, their knowledge and experience of gambling and above all else their focus on our customers. We will ensure they receive the best possible training and have the latest safer gambling tools available so they are empowered to make a difference at the front line of our operations. This is not about ticking boxes to be compliant; we have to set higher standards for ourselves. With this strategy we commit to funding research, education and training (RET) in safer gambling over and above any minimum guideline or future levy. We will strive to identify projects that benefit and protect the communities in which we operate and seek to be at the forefront of innovation in safer gambling. A keystone in our efforts to prevent and reduce gambling related harm is our work with technology partners on behavioural analytics in respect of our slot machine players, and our “safer gambling” initiative driven by our in house data scientists. These projects will enable us to identify potentially at risk gamblers at the earliest possible stage and undertake an interaction, empowering the customer to reflect on their behaviours and ensure they retain control. This strategy sets out our high level plans and priorities to make our vision a reality and Genting Casinos the safest place to gamble. Paul Willcock December 2018
Vision, Mission & Values Vision • Our vision is to eliminate gambling related harms and for gambling to be a safe, fun and entertaining experience for all who participate. We will become the safest place to gamble Mission • To provide education and information on gambling, together with tools that will enable our customers to be more informed of the risks and to better understand their gambling • To continue to fund research, education and treatment projects, over and above any minimum guideline or future levy, with particular focus on innovation and projects within the communities in which we operate • To continue to develop systems which enable targeted early interactions with customers, ensuring we act before any potential harm is caused • To harness the knowledge and first-hand experience of our staff, to empower and give them a voice through education and control systems to make a difference at the front line of safer gambling • To continue to play a leading role with ‘Playing Safe’, the responsible gambling programme of the National Casino Forum • To be at the forefront of learning, training and development of our people and products • To continue to work with our customers, staff and key stakeholders in providing a safer gambling environment Values • We will not trade profit for risk, to customers or our own reputation • We will not be afraid to trial experimental and innovative methods of harm reduction • We will share our safer gambling knowledge, successes and failures, with our competitors, and embrace the learning experiences any failures bring us • We will continue to strive for improvements in safer gambling • We will continue to put customers’ safety first
Genting – Strategic focus on safer gambling The Vision Education Early Enhanced & Information Interactions Funding Strategic Focus Creation of new tools and Continued development Identifying suitable delivery of information of systems that enable RET projects in our that ensures players targeted early interactions communities and new remain in control with customers to innovative approaches to prevent harm safer gambling Staff engagement, training and empowerment Cross-Cutting Themes We will not trade profit for risk We will share our safer gambling knowledge We will strive for continuous improvement Continuing our work with ‘Playing Safe’
Introduction With this document we set out an ambitious strategy that embodies our vision and priorities on providing a safe and entertaining experience for all customers. Gambling is a form of entertainment and a mainstream leisure activity. The majority of people who gamble do not experience any adverse consequences; however others do experience harm. Genting is committed to reducing then eliminating gambling-related harms and protecting vulnerable people with a combination of research, innovation and training; we strive as a licenced operator to be the industry’s safest place to gamble. We will constantly evolve and develop our methods with evidence based findings, embracing changing guidance and best practices. Genting will continue to work with a wide range of bodies including regulators, leading experts, academics and charities in the identification, reduction and removal of gambling related harms. As a licence holder we continue to uphold the licensing objectives; • Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime • Ensuring that gambling is conducted in a fair and open way • Protecting children and other vulnerable persons from being harmed or exploited by gambling This is more than simply a regulatory requirement for us, as a company we understand the need to create a sustainable business. Our vision will see us become the safest place to gamble and ensure that our customers, old and new, are able to participate in gambling in a safe way. We understand that an effective approach to safer gambling requires every person in the company to work together and feel empowered to make a difference. We set the tone “from the top” and lead a culture of compliance that is committed to putting the customer first. Problem gambling prevalence While research into problem gambling has increased over the last two decades, as a relatively new area of research it is difficult to accurately assess the scale of the problem gambling among our customers. The latest health survey data, drawn from field research carried out in 2016, shows that the rate of problem gambling across Britain was 0.7%, with a further 2.4% classed as low risk gamblers and 1.1% as moderate risk gamblers. Problem gambling rates have remained largely stable, being at 0.6% in 2012, 0.8% in 2015 and 0.7% in 2016. Whilst there is a 0.1% decline overall from 2015 to 2016 in realistic terms the prevalence rates have remained constant and more work is required to reduce this figure. Our clear and stated ambition is to reduce and ultimately eliminate problem gambling to make sure no one is harmed by gambling. Our strategy aims to identify at risk customers and intervene at the earliest opportunity to reduce these figures. We as a company will not stand still on this, we see many changes we can implement immediately but we are also looking towards the longer term. We will strive to innovate and seed a number of research projects to ultimately have them grow to support our aims, continually building and making our strategy deliver in the short, medium and long term. As further research is conducted into the area we will be able to refine the estimates we use in our research. It is likely that as larger data sets and sample populations become available we will find that there are other characteristics, behavioural traits and trends that can assist identify problem gamblers.
Taking stock and pushing forward Genting are committed to working in a socially responsible and ethical manner with sensitivity towards social, cultural, economic and environmental issues. We want safer gambling to be the norm for all. In providing a safe gambling environment we want to empower customers to make informed choices, and to be aware of the risks and tools that are available to ensure they remain in control. Measuring gambling related harms (Wardle et al, 2018) defined gambling related harm as; “Gambling-related harms are the adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society”. Gambling related harm refers to more than just ‘problem gamblers’, research indicates that someone with a gambling problem can affect other individuals. It can have a negative effect on communities, potentially leading to crime and money laundering, so although only a small percentage (0.7%) of the UK may have a gambling problem the effects can be far reaching. So how do we stop customers becoming problem gamblers and persons at risk of being problem gamblers? Behavioural analytics is the primary method to gain an insight into who is showing signs of being at risk. The use of data science techniques incorporating key variables or ‘markers of harm’ enables individuals to be risk scored. Models can be built to predict whether customers are at risk, or will be at risk if they continue to engage in gambling to the same extent. We are working with experts in this field and with research companies who have prior and proven success in the area of behaviour analytics. We will also innovate and invest from within, using our dedicated data scientists and safer gambling experts to drive this forward. The most important aspect is to have evidence based findings, to assess and to re-evaluate; improving at every stage; we want the right answer and the right answer may not be found straight away. Effective research takes time, and failures are expected. Genting will continue to innovate and develop now and in the future in the pursuit of market leading standards. Once identification of players at risk has been revealed, we need to interact; importantly, we need to interact effectively. Interactions or interventions can come in a number of forms including conversations, measures and tools. Different interaction types will be more appealing and effective for different people, having a number of options will seek to cover all customer preferences. All customers, regardless of status, can potentially have or develop a problem with gambling. We understand that problems with gambling can occur at any level, no matter how big, or how small. We are driven to help and make sure all customers maintain safer gambling practices. Understanding our customers, carrying out behavioural analytics, testing of interactions, and building of systems and processes will assist Genting in developing a holistic view of how to manage and engage with all Genting customers in regards to providing a safe gambling environment.
Enhanced funding for research, education and treatment Genting commits to funding research, education and treatment into safer gambling over and above any minimum guideline or future levy that may come into force. When evaluating projects for investment we will prioritise those that directly benefit and protect the communities in which we operate and those that are at the forefront of innovation of safer gambling. Some of our current projects that directly benefit our local communities include our work with the Young Gamblers Education Trust (YGAM), a UK-registered charity with a social purpose to ‘inform, educate and safeguard young people against problematic gambling & social gambling’. Funding provided by Genting has enabled YGAM to recruit an Education Manager and two part time jobs for students as University Community Development Workers. All three positions are located in the West Midlands and reach out to a minimum of 17,600 young people annually. Lee Willows, the Founder and Chief Executive of YGAM said “We are delighted to be working alongside Genting Casinos as one of their charity partners to specifically launch our education programme in the West Midlands. We have made a good start with almost 100 teachers and practitioners now trained and Person certified to deliver our programme locally. We are also about to start the recruitment of Peer Mentors to work in the West Midlands, which will give students an opportunity for a meaningful part-time job to complement their studies. Genting Casinos have made a two-year commitment to working with YGAM, with a view to potentially rolling out a wider education programme as part of their RET (Research, Education and Treatment) donation. “ In the South of England we are funding a pilot of the ‘whole family approach’ of treating problem gambling, work undertaken by Parent Support Link. Systemic family work is not a new practice, it is well documented as a way to tackle the myriad of problems that can affect and be detrimental to family life. The positive outcomes of engaging this system are acknowledged by many providers of social and health services. However, using this system as an approach to supporting families with gambling issues is, as far as we know, a new approach. We are an active participant within the Chinese Safe Gambling Liaison Group (CNHLC), working to create training and literature for staff to interact effectively with Chinese speaking customers. The work is being led by Chinese speaking gambling councillors who work under the GambleAware umbrella. Funding has been provided during 2018 towards GamCare’s ‘Computerised CBT for Problem Gambling’. Cognitive Behavioural Therapy (CBT) is an effective evidenced-based approach that is currently used in the treatment of problem gambling. GamCare uses CBT in its model of care and currently provides problem gamblers with a range of CBT support options, which include access to treatment support online, via telephone and in person face-to-face. The provision of options helps to remove potential barriers to treatment and accommodates individual circumstance and personal choice.
At the very forefront of our safer gambling practices, we are rightly proud to be the first operator to undertake the new GamCare accreditation process. We as a company see this as a priority, this new assessment is extremely important, not only for the company but for the whole industry, as this will raise the levels of safer gambling practises across the industry. This new kite mark recognises gambling operators who go above and beyond the requirements of gambling industry Codes of Practice. The new standard reviews policy and procedures, digital interactions, corporate governance and the culture of the business regarding its approach to social responsibility. Genting play an active role within ‘Playing Safe’. Playing Safe is an independent organisation comprised of academics and industry experts, which researches, recommends and evaluates responsible gambling projects and programmes in the casino sector. Its accreditation panel (ACE) inspects the casinos of all the major operators to ensure they are adhering to the core Playing Safe principles and that a commitment to responsible gambling is at the heart of their business; inspections are carried out on a rolling basis and more than 80% of operators have been assessed. The Playing Safe team evaluated the casino sector’s self-exclusion scheme SENSE and is planning to conduct further research into the programme. It also plans to engage more directly with customers. Educating and empowering consumers We are developing different ways that customers can be informed, make choices and be aware of risks. Genting are currently undertaking the following projects in this area; • Revising the Genting App • Revising the Genting Website • Redesigning the Safer Gambling link In redesigning the Safer Gambling link, we are adding interactive elements; which will include: • Instructional videos • Gambling budgeting tool • Gambling diary • Questionnaires These questionnaires will cover a number of areas including: • Problem gambling • Depression • Understanding gambling These tools will not just be for the gamblers; there will also be separate section for friends and family, where tools and information will be available for them. We aim to monitor and measure the uptake of these tools, to evaluate their effectiveness.
Targeted early interactions to reduce and eliminate harm Genting safer gambling project We are working with our dedicated in-house data scientists and safer gambling experts to utilise our available player data to pre-emptively identify customers whose gambling may cause them harm in the future. This is the second iteration of this work, the first research having taken place in 2017. We have now evolved this project to include historic information from customers who have previously self-excluded; we have reverse engineered the data to identify commonalities and trends between these individuals. Interactive Genting safer gambling project Further utilising our dedicated in-house data scientists and safer gambling experts, we are building a predictive model for our online customers. This is a major piece of work and we are planning to adopt a staged system of interactions. It has been identified that having a staged system approach may be an optimal way to drive safer gambling practices. Interactive customers are currently subject to predictive ‘markers’, these alert when customers reach certain trigger points, initiating a review and where necessary an interaction. This element is continuously being developed and refined as we evaluate the effectiveness of the markers. Focal project Focal Research is an industry wide project that Genting have been part of since 2015; we are part of a five operator strong trialling team that is testing the effectiveness of the Focal system. We are trialling this within five Genting Casinos nationwide. This is concentrating on Slots play, using mathematical analysis of player data to identify Gamblers of Interest (GOIs) who are potentially engaging in high-risk gambling behaviour. The model finds changing playing patterns that otherwise may be invisible to others, including the player. With the use of the Focal system we are able identify GOIs and have early interactions and drive safer gambling practices.
Methods of interaction We interact with our customers in a multitude of ways; however discussing an individual’s gambling can be a sensitive subject. To that end we are trialling various additional methods of communication and evaluating the effectiveness of how and when to best get the safer gambling message across. Interacting Structure The contents of the interaction, including questions asked. We want these to be effective, thus we are using findings from research. Modality Predictive How best to deliver and present Interactions with customers interactions to customers, via findings from our predictive including emails, via iPads and analysis, identifying where a via one on one conversations. customer may be showing signs We understand that different that may lead them to a problem individuals will prefer a different if left unchallenged. delivery method.
Staff training We will continually invest in the pursuit of industry leading standards when it comes to training. We believe that well trained staff are the cornerstone to providing a safe and entertaining environment. We will source and work with leading experts in different fields, these currently include; • Training in conjunction with GamCare • In-house training delivered face to face by our safer gambling experts and online via ‘Genting Academy’ • Training issued by Playing Safe • Training issued by CNHLC (Chinese National Healthy Living Centre) We will ensure we are delivering up-to-date and relevant information to all staff, and that we have the right people with the right skills developing our understanding of how to protect our customers, and how to eliminate harm. Continued work and longer term vision The above represent the keystones of our safer gambling strategy; however we are not focused on them in isolation and continue to raise standards in every area of our operation; Limit setting • Development of our proprietary slots software to implement customer configurable play limits • Trial and evaluation of mandatory deposit limits within gentingcasinos.com Messaging • Working with other operators to develop effective messaging • Development of integrated safer gambling slots messaging • Review and update of responsible gambling literature available within clubs • Safer Gambling marketing campaigns Training •Continued development of safer gambling training – including different types of mental illness and the different psychologies behind online and land-based Gambling • Enhanced training for managers in regards to interactions • Advanced education and training in Addiction / Behaviour Change Studies Self-exclusion schemes • Continued participation in the land-based and online multi-operator self-exclusion schemes • Effective self-exclusion system for customers who do not wish to participate in an industry wide scheme
Genting UK Safer Gambling Strategy 2019 – 2021
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