Affiliate marketing is expected to fall under the spotlight after the UK Gambling Commission (UKGC) sought widespread contributions towards the development of a new National Responsible Gambling Strategy, inbound for March 2019.
The UKGC has called for input from “as many people and organisations as possible” as it prepares to replace the current three-year strategy with one that will better protect under-age audiences as well as those susceptible to gambling-related harm.
Prior to the release of the current strategy – published in April 2016 – the UKGC concluded that while “the rules governing gambling advertising were broadly adequate”, they have “flagged a number of areas of possible concern, including digital marketing through social media and misleading advertising of free bets”.
One outcome of this was an announcement by the Industry Group for Responsible Gambling (IGRG) of an updated ‘Industry Code’ for socially responsible advertising, while the UKGC also strengthened its stance on the marketing of promotional offers, such as free bets and bonuses.
This came as part of its Licence conditions and codes of practice (LCCP), for which it will now consider further proposed amendments. Under the LCCP’s existing Social Responsibility Code (1.1.12), licensees can terminate the contract of a third party – for example an affiliates – if the third party breaches the relevant advertising code.
“We committed in our business plan to develop the new strategy and continue to be committed to driving and encouraging progress within our remit,” read the UKGC consultation statement.
“However, we are only one of the bodies with a role to play, and will work together with Government, public health, the charitable sector and gambling businesses in order to make real progress to reduce gambling harms.”
It has been estimated by OFCOM that there are 1.8 billion incidents whereby commercial gambling ‘impacts’ children aged four to fifteen.
Even though the “effect of advertising on participation in gambling and on the prevalence of problem gambling is difficult to establish”, affiliate partnerships have often been scapegoated.
For example, Ladbrokes Coral was probed for a partnership with stars of reality show Geordie Shore, which was deemed to have promoted products to audiences under the age of 18.
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