Jolyon Maugham’s Good Law Project is on a mission to force the Charity Commission to investigate GambleAware. GambleAware is a charity funded by the gambling industry that runs the National Gambling Treatment Service and, via GamCare, the National Gambling Helpline.

The Good Law Project has decided that GambleAware is untrustworthy and is covertly pursuing a pro-gambling agenda. It has put up a video featuring Will Prochaska to explain why.

Even if you’re underage and spending your weekly income on gambling, you’re advised by GambleAware to simply limit your gambling.

Expert on gambling reform, Will Prochaska (@cagauk), tells us why the regulator must investigate the gambling industry-funded charity: pic.twitter.com/nkD99LtxVv

— Good Law Project (@GoodLawProject) March 9, 2024

This tweet and the accompanying video are deeply misleading. For a start, Will Prochaska is not an expert on gambling. He was a management consultant before getting the gig of CEO at the pressure group Gambling With Lives. He has since become the “leader” of the Coalition Against Gambling Ads, one of several pressure groups funded by the casino entrepreneur turned philanthropist Derek Webb. He may or may not have strong feelings about gambling, but being paid to campaign against something doesn’t make you an expert.

That much is clear from what he says in the video:

The scale and depth of gambling harm in the UK is often overlooked but it’s become extremely serious in the past few years.

There is no evidence for this. The rate of problem gambling is 0.3-0.4 per cent, which is as low as it’s ever been.

You have almost 1.4 million people who are addicted to gambling.

As the Gambling Commission has explained ad nauseum, problem gambling does not imply addiction. Instead it indicates that a person suffers “negative consequences as a result of their gambling and possible loss of control”. As the Commission says, “we do not recognise the terminology ‘addiction rate’ and do not have any official statistics on ‘addiction rates’.”

The figure of 1.4 million is miles out. As the Gambling Commission has explained — in a direct response to previous claims from Will Prochaska — the evidence shows that problem gambling affects “between 250,000 and 460,000” people in the UK. The 1.4 million figure comes from an online survey by YouGov (commissioned by GambleAware) which is such an outlier that no serious person takes it seriously (I have discussed the problems with using online surveys to track problem gambling before).

The industry’s business model is based on addiction. Online, 86% of profits come from just 5% of the customers.

This is a reference to the Patterns of Play research from NatCen published in 2021 — which, incidentally, was also funded by those fiends at GambleAware. The research looked at revenue, not profit, and studied online accounts, not people. The latter point is particularly important since people often have multiple accounts, some of which they use more than others and some of which are rarely used at all.

The NatCen study found that 5 per cent of accounts with the highest spending losses contributed 86 per cent of gross gambling yield (which is essentially revenue before overheads). This is a slightly extreme version of the Pareto Principle, but it does not imply that the top 5 per cent of spenders are “addicts”. Only 0.45 per cent of the accounts spent more than £5,000 across the year and 96.8 per cent of accounts spent less than £2,000 (the distribution is shown below).

As the Gambling Commission explained to Prochaska in 2023, “The Patterns of Play research does not show any evidence that the industry is ‘dependent on harm’.” It is strange that this purported expert continues to make claims that the regulator has told him are not true.

After this little introduction, Prochaska gets to the killer argument that supposedly shows that GambleAware is a mouthpiece for the gambling industry and should lose its charitable status:

If you go on the GambleAware’s website and you fill out their affordability tool and you say that you’re extremely harmed and you gamble away all of your income each week — even if you put down that you’re underage — it will not tell you to stop gambling. It will tell you to limit your gambling to a safer level.

I have tried this myself (for research purposes, I should add) and it is true that the automated GambleAware response is not “STOP GAMBLING”. If only it were that easy to cure problem gambling! Does the Good Law Project really think that would work?! Do they not think that the individual might have considered that already, but has been unable to stop?

What GambleAware says instead is “you appear to be experiencing significant harm from gambling” and advises the person to call the free problem gambling helpline. On reflection, that might be more helpful. We must at least consider the possibility that a charity with 20 years experience running treatment services knows more about how to handle problem gamblers than a management consultant who wants to ban gambling adverts and a fox-clubbing lawyer who enjoys publicity.

Prochaska’s feeble example is the only evidence the Good Law Project offers for its witch hunt against GambleAware, so what is going on? I think there are two reasons why this charity is suddenly under attack.

The first is that gambling research is being taken over by “public health” academics who are endlessly cosplaying the 1990s tobacco wars. Anything involving “the industry” inspires a dark mood of paranoia, as I said last year:

GambleAware runs the National Gambling Helpline which helps thousands of people every year. If the industry didn’t fund it, the Lancet would be writing furious editorials asking why not. It has lobbied for tighter advertising restrictions and a mandatory levy on gambling companies, neither of which the industry wants. The only way you could consider it to be a sinister front group pushing an industry-friendly agenda would be if you knew nothing about it and considered anything short of prohibition to be industry-friendly.

The second reason for the attacks on GambleAware is, I think, a bit more cynical. A levy on gambling companies is imminent and is expected to raise at least £50 million a year. The money will be earmarked for “research, prevention and treatment” and there are a lot of potential recipients who will be fighting like rats in a sack to get their hands on it. The House of Lords called for a gambling levy in June 2020 and the government consulted on the matter later that year. Since then, problem gambling NGOs have been sprouting up all over the place. Among the organisations that have already received grants from the Gambling Commission are Gambling Harm UK (founded in 2020), Deal Me Out CIC (founded in 2020), the Epic Restart Foundation (founded in 2021), GamFam (founded in 2022) and the Academic Forum for the Study of Gambling (founded in 2022).

GambleAware, founded in 2002, is the daddy of them all and has an income of nearly £50 million a year

Having been founded in 2018, Gambling with Lives is a relative veteran and has received £600,000 from the Gambling Commission so far. It is likely to be in the running for further grants when the levy takes effect, alongside such recently formed organisations as The Big Step (founded in 2019), Clean Up Gambling, the Coalition Against Gambling Ads, Bet Know More, Action Against Gambling Harms (all founded in 2020), Tackling Gambling Stigma (founded in 2021) and GamLEARN (founded in 2022).

GambleAware, founded in 2002, is the daddy of them all and has an income of nearly £50 million a year, virtually all of which comes from the gambling industry. These donations will cease when the statutory levy is introduced. The levy will effectively nationalise industry donations, with decisions about how the money is spent made by bureaucrats rather than businesses. When the donations dry up, GambleAware will have to bid for the pot of money marked “prevention”. With 20 years experience of running educational campaigns and helping problem gamblers, it will be the favourite to get the contract, unless its name is sullied in the meantime. If GambleAware becomes politically toxic, there are plenty of pressure groups ready to accept the money who will argue that the most effective form of “prevention” is tobacco-style regulation.

The Good Law Project may be unaware of this dynamic but with tens of millions of pounds up for grabs, the stakes are high and competition is fierce. The statutory levy will create a massive slush fund and a new generation of hardline activists will stop at nothing to get a piece of the pie.