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Ms. Judith Glynn and Mr. Richard Lennon
Principal, Strategic Science
Manager of Social Responsibility Research, Manitoba Liquor & Lotteries
Judith Glynn & Richard Lennon
February 4, 2015 – Vancouver, BC
Introduction
 Context / Background
 Research Challenge/Opportunity
 Methodology
 Results
 Policy Outcome
 Questions
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
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
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
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)
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
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
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
Example 1: Isleta Casino Ad
Example 1: Isleta Casino Ad
SR Themes: “Appeal to financially vulnerable: Solve financial problems /
Replacement for employment / way to pay routine expenses”
Example 2: Betfair ad
Example 2: Betfair ad
SR Themes: “Underage: Youth appeal; Feature youth underage”
Example 3: Ladbrokes ad
Example 3: Ladbrokes ad
SR Themes:
“Informed
consent: Not
imply influence
of skill to win”
Example 4: Pistorius ad
Example 4: Pistorius ad
SR Themes:
“Irresponsible or
criminal behaviour”
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
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
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!
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
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)
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
Advertising assessment tool
Will this advertising … ?
• No
• Yes / Unsure
If Yes / Unsure, then
situation analysis
required
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
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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Judith Glynn and Richard Lennon: Integration of Responsible Advertising Standards for Gambling and Alcohol

  • 1.
  • 2.
  • 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”
  • 16. Example 2: Betfair ad SR Themes: “Underage: Youth appeal; Feature youth underage”
  • 18. Example 3: Ladbrokes ad SR Themes: “Informed consent: Not imply influence of skill to win”
  • 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!
  • 30. To provide session feedback: • Open New Horizons app • Select Agenda tile • Select this session • Select Take Survey at bottom of screen If you are unable to download app, please raise your hand for a paper version

Editor's Notes

  1. Direct and indirect Literature: Broad reviews of evidence and theory on effect of advertising on consumption generally and on at-risk groups. For alcohol focus is on underage but not problem drinkers; for gambling focus is on at-risk and problem gamblers, and to lesser extent underage. Plus, examination of specific risk factors that may be influenced by advertising. For example in gambling, research on: Cognitive errors and need to provide clear odds/prize information trigger/craving/relapse of problem gamblers and upon seeing/hearing an advertisement Co-morbid connection between alcohol and gambling
  2. NOTE: CRTC has code for alcohol but not for gambling, provinces are left to develop own Generally less national leadership on regulation, more state of province level, or self-regulation as opposed to co-regulation
  3. Informed consent: Odds of winning, Size and number of prizes/typical not best prize, Not imply influence of skill to win, Social pressure: Verbal/peer pressure, Success (personal, social, sexual, sporting, business), Toughness/resilience/recklessness Appeal to financially vulnerable: solve financial problems / Replacement for employment/way to pay routine expenses, Cultural stereotyping/cultural vulnerabilities Underage: Youth appeal, Feature youth underage, Rite of passage At-risk/problem gamblers: Not target SE’s, Inducements/promotions that can exacerbate PG, Not imply intrinsic luck, Gambling as means of escape, Indispensable/taking priority, Solitary gambling, Irresponsible or criminal behaviour, Playing beyond one’s means Responsible gambling messaging Alcohol (association with) Placement: Timing, Audience composition Sponsorship: Sports, Minors
  4. "So, the holidays have passed, and those credit card bills just keep piling up, and there seems to be no relief in sight. How will you pay those huge bills?" a narrator asks in a 30-second Isleta Casino & Resort television ad "Well— Isleta Casino Resort comes to your rescue!”. One image showed a smiling woman with an outstretched hand receiving dollar bills. Recovering gambling addict said in a letter to the casino that an ad pitch like Isleta's is "deadly" for addicts trying to keep their problem in check. Ad aired for several weeks
  5. "So, the holidays have passed, and those credit card bills just keep piling up, and there seems to be no relief in sight. How will you pay those huge bills?" a narrator asks in a 30-second Isleta Casino & Resort television ad "Well— Isleta Casino Resort comes to your rescue!”. One image showed a smiling woman with an outstretched hand receiving dollar bills. Recovering gambling addict said in a letter to the casino that an ad pitch like Isleta's is "deadly" for addicts trying to keep their problem in check. Ad aired for several weeks
  6. ad featuring poker pro Annette Obrestad has been banned by the UK's Advertising Standards Authority. A complaint was filed with the ASA claiming the ad was irresponsible because it might encourage children and young people to gamble. The ASA also challenged the ad as contrary to a Committee of Advertising Practice code which states no one under 25 can appear in a gambling ad in the UK.
  7. ad featuring poker pro Annette Obrestad has been banned by the UK's Advertising Standards Authority. A complaint was filed with the ASA claiming the ad was irresponsible because it might encourage children and young people to gamble. The ASA also challenged the ad as contrary to a Committee of Advertising Practice code which states no one under 25 can appear in a gambling ad in the UK.
  8. Stating that the ads breached the guidelines of responsible gambling and condoned an irresponsible attitude towards online gambling motivated the decision of the ASA. This was due to fact that the ads stated: “ONCE IS LUCK – TWICE IS TALENT” and “WHEN YOU WIN IT’S SKILL – WHEN YOU LOSE IT’S BAD LUCK”. The ASA found that these taglines instigated irresponsible gambling and gave gamblers a false idea of the risk that is involved in gambling.
  9. Stating that the ads breached the guidelines of responsible gambling and condoned an irresponsible attitude towards online gambling motivated the decision of the ASA. This was due to fact that the ads stated: “ONCE IS LUCK – TWICE IS TALENT” and “WHEN YOU WIN IT’S SKILL – WHEN YOU LOSE IT’S BAD LUCK”. The ASA found that these taglines instigated irresponsible gambling and gave gamblers a false idea of the risk that is involved in gambling.
  10. Paddy Power decided to offer odds on the Oscar Pistorius murder trial and placed them into the ‘novelty betting’ section of their site Ad banned for trivializing the issues surrounding a murder trial, the death of a woman and disability 5,525 complaints, record in the UK, rare step of demanding ad be removed pending investigation
  11. Paddy Power decided to offer odds on the Oscar Pistorius murder trial and placed them into the ‘novelty betting’ section of their site Ad banned for trivializing the issues surrounding a murder trial, the death of a woman and disability 5,525 complaints, record in the UK, rare step of demanding ad be removed pending investigation
  12. Across codes: within gambling codes and across alcohol codes, where work (research and regulatory) is much more mature Alcohol lacks emphasis on problem drinker
  13. Advertising assessment process is rolling out to departments in February. A review will be undertaken in July 2015 with improvement implemented then as needed. Implementation online is planned for August 2015.
  14. Advertising assessment process is rolling out to departments in February. A review will be undertaken in July 2015 with improvement implemented then as needed. Implementation online is planned for August 2015.
  15. Note: Does not apply to partners, stakeholders. First Nation casinos, lottery retailers, VLT siteholders and liquor vendors follow the Canadian Code of Advertising Standards as per LGA requirements.
  16. Note: Does not apply to partners, stakeholders. First Nation casinos, lottery retailers, VLT siteholders and liquor vendors follow the Canadian Code of Advertising Standards as per LGA requirements.
  17. Note: Does not apply to partners, stakeholders. First Nation casinos, lottery retailers, VLT siteholders and liquor vendors follow the Canadian Code of Advertising Standards as per LGA requirements.
  18. Note: Does not apply to partners, stakeholders. First Nation casinos, lottery retailers, VLT siteholders and liquor vendors follow the Canadian Code of Advertising Standards as per LGA requirements.
  19. Note: Does not apply to partners, stakeholders. First Nation casinos, lottery retailers, VLT siteholders and liquor vendors follow the Canadian Code of Advertising Standards as per LGA requirements.