Manitoba Liquor & Lotteries conducted research to develop consistent social responsibility standards for alcohol and gambling advertising following the merger of various liquor and gambling regulatory bodies in the province. The research involved reviewing literature on associations between advertising and problematic consumption, and analyzing existing advertising codes. Twenty-five themes were identified for gambling advertising and policies were implemented to apply the evidence-based standards through a new advertising assessment process. Steps were outlined to audit and improve the process over time through training, tracking, and review.

3. Ms. Judith Glynn and Mr. Richard Lennon
Principal, Strategic Science
Manager of Social Responsibility Research, Manitoba Liquor & Lotteries

4. Judith Glynn & Richard Lennon
February 4, 2015 – Vancouver, BC

5. Introduction
 Context / Background
 Research Challenge/Opportunity
 Methodology
 Results
 Policy Outcome
 Questions

6. Context / Background
 Reorganization of liquor and gambling operation and
regulation
o Merger of gambling operator (MLC) with liquor operator
(MLCC) to form Manitoba Liquor & Lotteries
o Regulatory functions of MLCC merged with gambling
regulator (MGCC) to form Liquor and Gaming Authority
(LGA) of Manitoba
o Announced in 2012; came into effect April 1, 2014

7. Research Challenge/Opportunity
 Liquor, lotteries differed in approach to assessing
advertising
o Liquor – according to requirements in the Act
o Lotteries – through established processes, review by Social
Responsibility and Corporate Communications
 Need to adopt consistent and comprehensive policies
 Opportunity
o inform standards through research, review of practices
o Compare standards on gambling and liquor

8. Methodology
 Review literature for associations between advertising and:
o in problematic consumption
o Known risk factors, e.g., imply influence of skill to win,
gambling as means of escape, solve financial problems
 Analyze advertising codes (national or state/province) for
social responsibility (SR) themes:
o Jurisdictions with progressive SR practices and socio-
cultural similarities
o Canada, New Zealand, United Kingdom, & Australia
o 8 alcohol & 10 gambling codes

9. Methodology: Alcohol advertising codes
Canada • Manitoba’s Liquor Control Act
• Canadian Radio-television Telecommunications Commission’s (CRTC’s)
Code for Broadcast Advertising of Alcoholic Beverages
• Advertising Standards Canada’s Canadian Code of Advertising Standards
Australia • Alcohol Beverages Advertising (and Packaging) Code
New
Zealand
• Code for Advertising and Promotion of Alcohol
United
Kingdom
• Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing
• Code of Broadcast Advertising
• Code of Practice on the Naming, Packaging and Promotion of Alcoholic
Drinks (Portman Group)

10. Methodology: Gambling advertising codes
Canada • BC’s Gaming Policy and Enforcement Branch’s Advertising and Marketing
Standards for the Gambling Industry
• Nova Scotia Gaming Corporation’s Code of Advertising Standards
• Manitoba Lotteries’ Responsible Gaming Standards
• Television Bureau of Canada’s Gambling Advertising Guidelines
• Advertising Standards Canada’s Canadian Code of Advertising Standards
Australi
a
• Queensland Responsible Gaming Code of Practice
• South Australia State Lotteries’ Advertising Code of Practice
New
Zealand
• Advertising Standards Authority’s Code for Advertising Gaming and
Gambling
United
Kingdom
• Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing
• Code of Broadcast Advertising

11. Stages: Social responsibility themes
1. Develop themes: 27 for alcohol, 25 for gambling
2. Assess codes for presence, breadth, depth of
scope and language
3. Identify best language for each theme/code
o Measureable and enforceable
o Language clarity for regulators and the organizations
they regulate
4. Draft integrated code for alcohol and gambling

12. Results
Alcohol - Focus on
underage
consumption
Gambling – focus on at risk and
problem gambler, and underage
• Youth appeal
• Age of models
• Placement (time of day
and audience
composition)
 Informed consent
 Social pressure
 Appeal to financially vulnerable
 Cultural stereotyping/ vulnerabilities
 Youth
 At-risk/problem gamblers
 Responsible gambling messaging
 Alcohol
 Placement
 Sponsorship

13. Example 1: Isleta Casino Ad

14. Example 1: Isleta Casino Ad
SR Themes: “Appeal to financially vulnerable: Solve financial problems /
Replacement for employment / way to pay routine expenses”

15. Example 2: Betfair ad

16. Example 2: Betfair ad
SR Themes: “Underage: Youth appeal; Feature youth underage”

17. Example 3: Ladbrokes ad

18. Example 3: Ladbrokes ad
SR Themes:
“Informed
consent: Not
imply influence
of skill to win”

19. Example 4: Pistorius ad

20. Example 4: Pistorius ad
SR Themes:
“Irresponsible or
criminal behaviour”

21. Implications
 Address pure social marketing campaigns by industry
 New theme for Alcohol codes
o solitary consumption
 Gambling – began with 39 themes from literature and
across all codes, combined and refined to 25
o First set of themes for gambling
o Research needed to test and further refine
 Integrated code
o Common risk factors
o Risk factors specific to alcohol or gambling

22. Policy Outcome
 Minimum regulatory standards – advertising must:
o Be consistent with Canadian Advertising Standards
o Include a social responsibility message
 Decision to hold ourselves to higher standard – why?
o Social responsibility goal of minimizing harm
o Mitigate potential risks to public image
o Crown corporation – expectation to uphold community
values, lead by example

23. Policy Outcome
1. Decision to implement evidence-based standards
2. Additional input on public image / social values elements
o Manitoba Women’s Advisory Council regarding
depiction of women in advertising
3. Apply standards via advertising assessment process
o Ensure standards upheld consistently
o Input from other jurisdictions on their assessment
processes very helpful – thank you!

24. Advertising assessment scope
 Process ensures standards applied for any advertising
generated by operator, with operator logo, or appearing at
operator sites
 Examples: marketing, casino/event centre promotion, ads/
thematics in Liquor Marts, CSR, SR or community support,
eGaming

25. Advertising assessment process
 Each functional area assesses advertising
o Previously, all signed off by Corporate Communications
o Disseminates standards throughout organization - sense of
ownership
 Reviewed, approved by authorized manager once ad fully developed
 Escalation process to Communications/SR
o if concern raised or of lack of clarity about adherence to standard;
or
o if advertising on television, through previously-unused channel, or
if distributed outside corporation’s point of sale
 Situation analysis required by manager – what is risk and rationale for
proceeding (pre-set questionnaire)

26. Process auditing and evaluation
 Pilot process and review
o Full review to occur several months after implementation
 Secure, central log/database to track all assessments
o Ongoing audit of advertisement, assessments and assessment
results
o Inter-rater reliability – do assessments differ by individual?
o Changes to process and/or training as required
 Tracking and re-assessment based on complaints received
 Annual reporting to executive level for each department
o ads, assessments, escalations and complaints
 Process reviewed in full every two years

27. Advertising assessment tool
Will this advertising … ?
• No
• Yes / Unsure
If Yes / Unsure, then
situation analysis
required

28. Next steps
 Employee training March 2015, roll-out April 2015
 Review of process, finalization later in 2015
 Product assessment tool to assess and respond to risks
related to all new and acquired products
o Apply to both alcohol products including shelf talkers
and games/game platforms
o GAM-GaRD is one example of such a tool
o Will be developed in 2015; rolled out in 2015 or 2016

29. Questions
Judith Glynn
Principal
Strategic Science
226-821-3167
judith@strategicscience.ca
www.strategicscience.ca
Richard Lennon
Manager, Social Responsibility Research
Manitoba Liquor & Lotteries
204-957-2500 ext. 2457
richard.lennon@mbll.ca
www.mbll.ca
Thank you!

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