With emerging markets and countries taking a stricter approach to regulation in recent weeks, the subject of responsible marketing remains high on the agenda.
As an industry we understand the importance of being safe and responsible when engaging with end users with marketing material, but how exactly are operators and suppliers working together to ensure that best practices are maintained on a daily basis?
We asked Daniela Speranza, Head of Compliance at Betsson, Liesbeth Oost, Sustainability Manager at Aspire Global and Peter Christian Noer, Head of Country Managers at Soft2Bet, to discuss the tools and measures that are being utilised to improve the execution of responsible marketing.
Given the increased scrutiny around marketing across multiple regulated markets, do you think more can be done at platform level to support operators in their efforts to be more responsible?
Peter Christian Noer: Yes and no, we believe the responsibility falls on every operator, to ensure its marketing practices are kept in line with regulations. However, the more tools that can be provided the better. Especially in terms of targeting, so that operators can filter out under-age people easily.
It all comes down to data and what opportunities the platform provider has in place, if the system is kept secure and a trusted source of compliant traffic, then increased marketing budgets will be allocated to the platform.
Overall, it is in everyone’s interest that the platform can offer great protection, betting and data tools, although the responsibility of the allocated marketing budget should always fall on the operator.
Daniela Speranza: Yes, ideally platforms would be designed with responsible gambling considerations at their core, making it simpler for operators to achieve their objectives in this sense and comply with their ever-increasing obligations. For example, if platforms were to be tailored to cover market-specific legislation and advertising standards, I believe that it would be easier to protect the end-user, this of course being the ultimate goal of any responsible gambling requirements. The greatest thing about software is that it is plastic, and it can be moulded as we desire. This benefit must be used to our advantage as operators, always subject to the exigencies of the market competition, of course.
Furthermore, artificial intelligence and real-time alerting models can be integrated with platforms to provide efficient monitoring and analyses, enabling operators to interact proactively with players and ultimately providing end-users with the ability to make informed choices.
Liesbeth Oost: With AI and machine learning technology coming on in leaps and bounds in recent years, there’s a lot more that providers can do for operators in this space. For instance, in the world of affiliate marketing, an operator can have dozens of affiliates and the operator is responsible for ensuring each one remains compliant. When platform providers invest in developing the right solution, they have the ability to offer greater oversight on affiliates. This leaves the operator open to a lot less risk, which is a huge step forward, especially as stricter marketing rules are being enforced.
The industry has embraced a lot of different aspects of sustainability such as responsible marketing in the last two years. It’s easy to see how that is becoming more a part of the culture now, and this isn’t purely motivated by a fear of getting fined. Embracing compliance has led to better business, so it is no surprise that doing so with responsible marketing, for which Aspire is a strong advocate, has had a similar impact. It would be fantastic to see those efforts replicated in the wider industry, which could only serve to benefit operators.
What are the key differences between different jurisdictions approach to responsible marketing?
Liesbeth Oost: There are massive differences between jurisdictions. However, one steadily emerging trend is the markets that have regulated most recently seem to be the strictest. In the Netherlands, which has recently introduced its new regulatory framework, penalties on advertising violations result in non-eligibility to apply for a license.
Elsewhere, the US is very serious about each business’ role in the environment and its overall social governance. Embedding a culture of responsible gambling in a newly regulated country bodes well for the future of the market, promoting safer gaming experiences that players can enjoy.
Daniela Speranza: Whilst the intention of responsible marketing measures in different jurisdictions is more or less the same, namely, to reduce rates of gambling addiction and ramp up player protection efforts, especially for vulnerable groups such as problem gamblers and minors, there are key differences when it comes to how different jurisdictions approach it.
Certain measures in jurisdictions which do permit marketing are often similar regarding what can and cannot be included in communications regarding marketing material. For example, requiring ads to be socially responsible, not targeting minors or portraying sexual content.
At Betsson, we believe that advertising is vital for channelisation. Associations like the European Gaming & Betting Association’s (EGBA) are aiming to set long-term standards for gambling advertising content in Europe. Betsson is a member of EGBA and follows its Code of Conduct on Responsible Advertising for Online Gambling with a firm commitment on responsible gambling.
Peter Christian Noer: I wouldn’t say that there are many differences. Overall, they are quite similar with each jurisdiction having a unique trait. For example, some regulators will want a license number included in banners whereas others don’t mind.
The main rules to follow are quite consistent, such as not targeting minors, following good marketing practices, indicating terms associated with offers, offering full terms and including references to responsible gambling helplines or services.
Perhaps one of the biggest differences between jurisdictions is how many disclaimers need to be included. However, in my opinion, this doesn’t serve much of a purpose. In certain jurisdictions, regulators differentiate the number of disclaimers based on the market channel, as some allow for more to be included. However, this allows these regulators to bloat the requirements. I personally fail to see the point of including several disclaimer sentences in marketing messages, no one reads them, and, in any case, they are available online.
What sort of solutions does your company provide in supporting operators with their responsible marketing efforts?
Peter Christian Noer: As an operator ourselves, we mostly rely on the tools provided by partners at our disposal. In general, we maintain a strong level of communication with our provides and external partners.
We also normally work with partners that have operated within the industry before, since they have experience with special regulatory, technical and business requirements. More importantly they’ll also understand that our iGaming industry probably has more restrictions than others.
Since players’ trust is crucial in all markets, it’s also important that we as an operator market ourselves in a responsible and balanced manner. We also ensure that we stay within the guidelines and not go outside of them. Facing courts for marketing violations not only hurts the operator but the industry as a whole. We must acknowledge that we are an easy target and that we should all work collectively to improve the presentation of our offers so that they are clear and fair, otherwise future marketing restrictions will continue.
Daniela Speranza: Betsson understands the importance of identifying early signs of potential gambling-related harm and with this in mind, constantly invests in technology to develop automation and tools to help identify end-users at risk, such as late-night gamblers, chasing losses, heavy spenders, frequent depositors and limits being changed frequently. Our in-house built RG Prediction Tool with the help of various other reports, alerts and escalation processes is in use by a dedicated safer gambling team that is collating all data, analysing, and using the outcomes for interactions and interventions.
Betsson also ensures that marketing and advertising efforts are conducted in a socially responsible manner. Marketing and advertising communications are not aimed at, nor appeal to, underage persons (i.e., any age below the legal age for gambling in any jurisdiction where the communication is targeted) and carry appropriate warnings about underage gambling. By way of example, no logos or names of gambling products or services are found on products intended to be used or worn by underage persons. Advertising is not shown on any websites that children may frequent; YouTube and social media content are age-gated; celebrities or prolific persons are not used in marketing if they are under the age of 25, and persons that are shown, are shown to be gambling responsibly, for example no links to alcohol and gambling together.
The Compliance team is well integrated with the marketing teams and provides guidelines and training so that marketing is responsible and meets the various regulatory standards of moderation. Furthermore, the Compliance team oversees these functions to ensure that published marketing material follows internal guidelines and policies.
Liesbeth Oost: A huge challenge for most operators is how they monitor their affiliate partners to ensure they are always compliant. Overseeing every aspect of how multiple affiliates are performing is a massive task that cannot be done without the support of technology. To help with this, Aspire has partnered with Rightlander, which offers a range of solutions for affiliate compliance monitoring. Through its technology, we can identify affiliates bidding on client brand names, hijacking traffic and using their own tracking codes to intercept traffic.
Significant strides have been made in the world of machine learning and AI, which means that advanced platforms can actively optimise campaigns to a much greater extent and reduce the need for judgement calls on employees’ part. Most importantly for this issue, these tools can monitor a huge number of sites and flag any that may not be compliant in that market in an efficient manner.
Although our operating partners take care of their own marketing and relationships with affiliates, we are equipped to assist them in their operations and provide them with a service that ensures affiliates are not misrepresenting their brand.
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