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.
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
14. Example 1: Isleta Casino Ad
SR Themes: “Appeal to financially vulnerable: Solve financial problems /
Replacement for employment / way to pay routine expenses”
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
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
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
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
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
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
"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
"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
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.
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.
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.
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.
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
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
Across codes: within gambling codes and across alcohol codes, where work (research and regulatory) is much more mature
Alcohol lacks emphasis on problem drinker
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.
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.
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.
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.
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.
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.
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.