Road to Safer Gambling Week: A Content Providers’ Perspective
In Part 3 of our journey to Safer Gambling Week, we catch up with the industry’s leading content providers to find out their thoughts on responsible gambling and how it impacts their market strategy going forward.
- Fraser Linkleter, CMO, Slots Temple
- Elliott Resnick, Head of First Look Games
- Achilleas Chrysafis, Head of Platform, FSB
How do responsible gambling requirements impact your business and the solutions/services you provide?
We’ve always been very focused on Responsible Gambling, and it runs through the heart of our business. We see Responsible Gambling requirements as a positive necessity, which ensures we’re offering players a safe place to play their favourite games.
Conforming to regulations also helps to instil trust with the casino operators as well as our players. By offering a compliant, safe place to play we’re increasing our appeal to players as well as building confidence with our affiliate partners.
First Look Games has been built to do the heavy lifting for studios when it comes to affiliate outreach for the purpose of game marketing and promotion. Part of the service we offer is to ensure the 800+ members of our affiliate community are the absolute best at what they do within the markets that they and our studio customers target. There’s a compliance requirement to that, not only with the community we service but in adhering to the regulation within those markets. This includes age-gates on demos, which we provide for free as the responsibility for unrestricted demos falls on the studio, even if they’ve had little to do with where the review of their game is published. This is just one example of where we provide that peace of mind.
The improvements in our Responsible Gambling toolset can be self-driven in the form of innovation, or as a result of industry requirements. We’ve always tried to ensure we remain competitive in terms of the tools we offer to monitor and manage responsible gambling to the point of developing our own management interface to manage customers that may be at risk and interact with them accordingly after reviewing their account. On the other hand, there are tools that the industry will promote, and FSB will implement as a result of the requests that will come in from our partners. As we are a global company, we are laser focussed when it comes to adhering to regulatory requirements in different jurisdictions.
What are the greatest challenges in this regard? And how do you overcome them?
The biggest challenge we come across is keeping on top of the ever-changing regulations in different jurisdictions.
With the affiliate-studio relationship being relatively new, outreach is an additional requirement on teams that are already busy. This is certainly the case for compliance teams, and many smaller studios are already outsourcing these requirements while they focus on building their content in line with the requirements in place in the markets they serve. Adding a layer of affiliate compliance and game promotion requirements across multiple markets can therefore present a challenge for studios that are already pushed to capacity. First Look Games, with its depth of experience, already understands this and that is why we work with the most reputable affiliates via our platform. This means that any game promotion done in partnership with our community of affiliates provides peace of mind for compliance and marketing teams as well as an additional and effective route for game promotion.
Probably the greatest challenge is ensuring that the output of our AI-led reports/solutions that we create highlights the correct customers that may be at risk. Sometimes false positives may be highlighted due to a change in the customers activity, but this is where we would rely on human intervention to ensure that those false positives are ruled out and then improve the output via offering feedback. It’s about constantly evolving and making our tools better.
Apart from that, the landscape seems to be constantly evolving (in terms of responsible gambling in the industry) and as a result we need to be continually training and informing advisors across the evolving regulations.
How do requirements differ in each of the markets you target? How do you ensure compliance in each?
The differing age verification requirements for each jurisdiction has meant we’ve had to partner with different data providers and build our registration processes differently. Luckily our business is able to do this and it allows us to launch in new regions with a tailored offering, for example when we launched in Canada and the US in the last couple of years.
For studios, the main concern is ensuring the accuracy of the information published by affiliates on their behalf, rather than there being detailed requirements on the game reviews that are written. At First Look Games, we have proprietary software that identifies any inaccuracies in the game review published by our affiliate community, and we proactively highlight these and encourage swift amendments to the information where it’s wrong. As I mentioned, there is also a need for game demos to be age-gated. Where this isn’t done, the responsibility is that of the studio even if the review sits on a third-party site. So again, we provide a free age-gate solution to all our partners to ensure this requirement is met. Beyond that, there’s security in our vetting process as we only work with the best and most responsible affiliates across the industry.
An enormous amount of preparatory work and due diligence is undertaken before we enter any new jurisdiction to make sure we are wholly compliant. This process includes listing all regulatory requirements in this area and then scoping the projects and tools required to meet the partners and business needs in that jurisdiction. We also make sure any partner requests are supported by the regulatory documentation to implement the solution needed. Obviously, throughout the development phases, this will also be tested and improved via each sprint with regular feedback being offered at key points of each project. It is FSB’s responsibility to provide a compliant platform to its partners and it’s something we take incredibly seriously.
Does responsible gambling present any opportunities for you and the operators you work with?
Absolutely! As regulation increases operators will choose their affiliate partners with increasing care and will only work with the partners they can trust to behave responsibly. By ensuring we comply to all regulations we have been able to establish strong relationships with both operators and game studios. Our UKGC licence puts us in a unique position to promote new games and operator offers.
Good regulation should always create opportunity. A solid framework within which to operate should prevent harm and retain the entertainment value for players, while giving the end-to-end supply chain clear guidance on how to correctly develop and market content and offerings. Acquisition and retention are critical for operators, but fines can do untold damage to a business (and especially to its reputation). The clearer and more common-sensical the framework is, the easier it is for those working within it to meet its requirements.
Studios generally do less B2C outreach and therefore have less requirements to adhere to, but the quality of that outreach is important. First Look provides a way for studios to assist in the promotion of their own content to a B2C audience with compliance already factored in; we remove the additional work this would otherwise require while adhering to necessary requirements across all markets.
Ultimately, offering a responsible gambling service is something we take incredibly seriously and want to champion. It’s incumbent on the industry to embrace it and that responsibility lies on our shoulders too.
With regard to the operational side of things, there are some improvements that are global and others that are specific to one jurisdiction. As we are expanding into North America and Europe, we see that some of the functionality already implemented for our UK / European partners can be utilised or adjusted slightly to meet the demands of these other markets. However, in some cases brand new tools and features are built specifically to meet the exact requirements set out by the partner or jurisdiction in question. An example would be the log in pop-up presented to one of our European partners that highlights customers’ recent spend to serve as a reminder of the activity the customer has had. This is also an opportunity to highlight responsible gambling tools available on site.
How can we strike the right balance between protecting a small number of vulnerable players while not over-burdening the vast majority that gamble responsibly?
This will always be a challenge within our industry. There is, however, a lot of data available to review a player’s potential vulnerability before needing to request a lot of information directly from a player. Ultimately though the most important point is to protect that small number of vulnerable players, in all situations.
That’s the crux of regulation, and it’s not easy to achieve the perfect balance. The fragmentation of the regulatory framework has proven that very few regulating bodies have hit the optimal equilibrium the first time of asking and, in some cases, explains why requirements can change frequently. But this creates additional issues as well, including financial burdens on studios and operators with already busy development and compliance teams. No one wants to cause harm, but excessively restrictive rules also risk driving players to sites that don’t adhere to any regulation, which, again, is not something that benefits the player or the casinos doing everything right.
Most regulators look to consult with those that truly understand the motives of players that are likely to do themselves harm and try to weigh this equally with insight from those that have a good understanding of how to retain the entertainment value for the masses. Acting based on a one-sided consultation without the macro view on long-term impact is unlikely to result in strong and effective regulation that genuinely protects those that are really at risk.
I think it’s about adopting a forensic player by player approach led by human intervention and technology. As per the previous examples offered, we can only rely on technology up to a certain extent to highlight problem gambling. For example, we may have a customer who wins a large sum of money on a sportsbook bet and then increases their weekly spend by 50%. This may be a trigger to flag a customer for review but doesn’t necessarily mean we would need to take restrictive measures. This could be because this 50% increase is well within the customer’s budget for personal use (as a percentage of their discretionary income) and as they have just won a large sum of money. Having said that, we would still need to ensure that this pattern of behaviour is monitored in terms of future spend so that this does not become a gambling problem. If the gambling industry educates members of staff to recognise signs of problem gambling and keep them up to date with industry standards, the battle to ensure vulnerable customers are protected will be a lot easier to manage, and indeed offer insights on how not to overburden the vast majority of responsible gambling customers. This approach in tandem with AI-led technology that monitors player pattern is the ideal blend in tackling Responsible Gambling in a non-intrusive way.
It’s great to see that responsible gaming issue are just as important to the content providers as the rest of the gaming industry. Their biggest challenge is with creating games that are suitable for multiple jurisdictions, that’s where the real challenge and strain on resources can arise from. However, with advancements in tech and industry experience, this is being managed effectively. We look forward to seeing the new and exciting developments this sector of the industry has to offer.