The Institute of Public Health (IPH) recently responded to a Department for Communities consultation on developing new Gambling Codes of Practice for Northern Ireland.
The Gambling Codes of Practice are being developed for gambling operators, ie those who hold a licence, permit or certificate under the Betting, Gaming, Lotteries and Amusements (Northern Ireland) Order 1985.
In its submission the Institute highlighted that Northern Ireland has the highest prevalence of problem gambling and mental ill health across the UK and that any legislation and Codes of Practice need to be on par with existing protections across the UK.
In its response, the Institute made a series of recommendations, including the following:
• The need to enshrine aspects of the proposed Gambling Codes of Practice into legislation, including self-exclusion measures, advertising and marketing, product design, and verification measures including affordability.
• A Regulator should have the power to review, revoke and amend the Codes of Practice and put forward recommendations for measures to be included as part of criminal law. Breaches of Codes of Practice should be clearly defined alongside any punitive measures such as fines, penalties or revocation of licence.
• The Codes of Practice being developed for Northern Ireland should provide the same protections available in the rest of the UK, as set out in the Gambling Commission Licensing Conditions and Codes of Practice.
• The proposal that gambling on credit is prohibited is welcome and the Institute would call for a complete ban on the use of credit card payments.
• The proposed measures on reverse withdrawals and the inclusion of age verification measures within the Codes of Practice are welcome.
• Consideration should be given to rolling out a test purchasing scheme, as part of any new regulatory framework.
• Banning free bets, VIP schemes and incentives through legislation is strongly recommended.
• Limits should be applied to stakes, prizes, and deposits of all gambling products, not just those in land-based venues. This could include on-screen warnings and limit-setting.
• It should be a condition of licensing that land-based operators provide data on trading hours, location of premises and the number and type of gaming machines on the premises as part of good practice.
Access the full IPH consultation response here.