IN-DEPTH 12 December 2017
ActiveWin: "Tread carefully when advertising abroad"
Bernadette Kelly, Commercial Director at ActiveWin Media, explains why operators should cautiously analyse the advertisements they choose to release across international territories
By Gambling Insider
As land-based gambling continues to experience explosive growth in emerging markets, the global restrictions on online betting remain complicated. Each country has its own set of rules for digital marketing, and operators can quickly find themselves running afoul of governing bodies abroad.
However, international gambling regulations are not the only concern for advertisers. In the UK, the Gambling Commission continues to flex its muscles regarding what it considers responsible advertising for online marketing. Sarah Harrison, Chief Executive of the UKGC, announced an increased pressure for operators to conduct more audits to ensure compliance.
Given that digital marketing spend will surpass that of television for the first time in 2017, the scrutiny for online compliance should be more intense than ever before.
There is a huge number of measures you must observe to stay compliant with the Committee of Advertising Practice (CAP), and its broadcasting equivalent, BCAP. Here is a quick summary of the chief compliance points for online operators of all sizes to consider.
AGE ISN’T JUST A NUMBER
Underage gambling is a serious concern. Websites which advertise gambling are required by law to clearly display the 18+ logo, and advise that gambling underage is an offence. However, the age restrictions don’t just apply to displaying your 18+ logo.
As a rule, images must not depict a character or a real person who is, or looks to be, under 25. If your sportsbook banner features a professional footballer, for example, you must check his age. Written content is subject to the same sanctions, so no childish language or slang that would appeal to kids and teens. Legit.
DON’T PROMISE WHAT YOU CAN’T DELIVER
No TV advert, banner, or piece of content can imply that gambling will enhance any physical attribute, or that it will have a ‘life-changing’ effect on players. A good example of this is the series of ‘life ads’ produced by Ladbrokes, which featured a set of characters with nicknames to represent what kind of bettor they were. There were 98 complaints, and the ASA deemed the ads non-compliant since they portrayed an irresponsible attitude to gambling. The ads have since been removed by Ladbrokes.
Just as you can’t imply enhanced attractiveness through gambling, you can’t encourage players to see it as an
escape from their real-world problems.
Online gambling should never be portrayed as a ‘solution’ to either, money worries, loneliness or depression.Peer pressure is another factor here. Even using words as innocent as ‘join in’ can be an inflammatory statement if combined with other factors which imply the dreaded FOMO (fear of missing out) or not being part of the crowd.
SEX CAN’T BE SOLD
We’ve all heard the phrase ‘sex sells’ and it’s been part of the advertising landscape for decades. Busty blondes and shredded shirtless men have hawked everything from perfume to cola with great success. However, as gambling is a high-risk and potentially addictive pastime, it cannot be linked with any other similarly controversial ‘activities’ such as sex, violence or links to alcohol.
Around the world, there are beliefs and superstitions that can leave people vulnerable to suggestion. For the Chinese, the number 8 is deemed to bring great fortune. Therefore, be careful not to draw any links between betting on the 8th day of the 8th month for example, or betting more on that day. Celtic culture references are also rife in gambling, thanks to Ireland’s mythical ‘lucky’ four-leaf clover. Tread carefully.
Players should never feel trapped or harassed. If they don’t want your newsletter or SMS messages, there must be a simple procedure to opt out. Similarly, if they no longer wish to be a member of a frequent player club, they should be able to easily do so. Monitor your social media channels closely for complaints from players about spam or the inability to reach your customer support team. This is a big red flag that there is a problem with your existing opt
T&CS ALWAYS APPLY
Terms and conditions must be no more than one click away. They should be clear and concise, with no room for misinterpretation. Ensure your compliance team frequently updates your terms across all platforms.
Like most things in the digital sphere, online gaming is dynamic, and is in a state of constant change. It is part of what makes it such an exciting industry. Learning the rules, and living by them, allows operators to reap the rewards of their hard work and investment.
This is by no means an exhaustive list, and the goalposts move all the time. However, it’s a good place to begin for a better understanding of the do’s and don’ts of compliance. Not sure if your advert is crossing the line with compliance? Our advice to you would be when in doubt, leave it out - or risk a hefty fine.