MONOPOLY – THE RIGHT SYSTEM?

I have recently analyzed a lot of different gambling systems and their real objectives and effects. Last week, my company The Finnish Gambling Consultants published a “white paper” report on the current state of the Finnish gambling system and its alternative solutions. We have got familiar with the gambling systems in Denmark, Norway, and Sweden, which differ quite a bit from each other and from the Finnish system. It has been interesting to note that it is possible to have different solutions to achieve similar goals. So what is the right solution? In order to answer this, you need to know what states are really aiming in the area of gambling.

There have been two very interesting news from Norway about gambling business. First, the University of Bergen published an extensive study on gambling and, above all, gambling problems. According to that research, the number of gambling problems seems to have increased in Norway. The difference in research methods makes it difficult to compare the results both between different years and between different countries. Despite this, I dare say that Norway has more gambling problems than other Nordic countries. Why is this a strange result and how can it be possible?

Norway has a strict monopoly system for gambling. State-owned Norsk Tipping has the exclusive right to all other gambling products except horse betting which games are run by Rikstoto. There are some smaller companies in Norway that are licensed to run small-scale gambling, but this is not relevant in this context. The Norwegian state has imposed strict restrictions on Norsk Tipping’s operations. In Norway, it is only possible to play gambling products as an identified customer and there are strict maximum loss limits for gambling. So it seems that in Norway, the goal of the state has been to curb gambling and gambling problems, and not just to maximize the revenue from gambling.

In recent years, Norway has sought to restrict gambling for offshore gambling operators. The country has introduced a blocking of money transactions, which has made the customer’s money transactions to foreign gaming companies quite difficult. In addition, the country is making serious efforts to prevent foreign gambling companies from showing TV advertising in Norway, regardless of whether the TV channel is Norwegian or not.

Denmark and Sweden have opted for a quite different gambling system than Norway. Denmark decided to move to license-based gambling system less than 10 years ago, and Sweden followed to similar system from the beginning of 2019. In practice, only lottery and instant tickets games have remained in monopoly and other gambling verticals can be licensed. The volume of gambling has increased in both countries and players as a whole are losing more to gambling than before. Despite this, at least the number of gambling problems does not seem to have increased and the number of problems is clearly lower in both countries than in the strict monopoly country of Norway.

How can such outcome be possible? Studies show that there is a correlation between the volume of gambling and the number of gambling problems. The more you play, the more gambling problems you experience. However, studies have been conducted in situations where the actual amount of gambling has been known. This may no longer be the case in today’s digital world, where there is a large amount of gambling on offer via the internet and mobile that doesn’t show up in official gambling figures. Restricting the physical supply of games can only shift customers to the digital offerings of other operators.

It is often thought that in a monopoly system, state control is much stricter than in other systems. However, this is not self-evident. The regulator has just as good, or even better, opportunities to control gambling activities in the license model as well. An important factor is the channeling ability of the gambling system. The more the system makes gambling a legal activity in the country, the better the state control will work. At least after the change of the system, the channeling capacity of the Danish and Swedish gambling systems rose to a significantly high level and thus the operating restrictions worked better than before, with a large part of the gambling going to unregulated offshore operators.

So what should Finland learn from the experiences of the other Nordic countries? Before you can answer this, you need to know what Finland is really aiming for in the area of gambling. According to the EU, a gambling monopoly system is possible if it can improve the protection of players and prevent criminal activities related to gambling. A particularly important justification for the monopoly system has been better prevention of gambling problems. It should be borne in mind that gambling revenues are not an acceptable basis for a monopoly system.

The prevention of gambling problems has gained more weight in the Finnish gambling policy and its practical implementation in recent years. The merger of gambling operators and the centralization of gambling operations in one company, Veikkaus, from the beginning of 2017 has given the regulator better tools to control the company’s operations. Veikkaus’ operations are supervised and regulated more than the three previously monopolies were supervised. This has been reflected in lower revenues from gambling operations. Unfortunately, and somewhat surprisingly, gambling problems have not diminished. The number of problems has been at the same level for long time. About 3% of Finnish adults suffer from gambling problems. Studies show that the number of people with serious problems is growing, which is a matter of real concern.

The operations of the monopoly company Veikkaus are thus controlled more and more, which reduces gambling through the company and thereby the state’s profit. According to research, a large part, almost all, of Veikkaus’ declining gambling is directed at other gambling companies. This way, overall gambling and gambling problems are not reduced. The regulator currently has little possibility to take action against offshore gambling companies. So something needs to be done and soon. Otherwise, the pace of development will only continue, and Finland will soon end up in the same situation as Denmark and Sweden years ago.

If the prevention and reduction of gambling problems is the primary goal, then Finland must be able to tighten control over all gambling activities, not just Veikkaus. This can happen in both a monopoly system and license-based models. The goal is to bring gambling under regulation in one way or another and then impose strict restrictions on gambling. According to results from Norway, it is not sure that monopoly would be automatically better from gambling problem point of view than license-based system.

If the goal of gambling activities is also to continue to generate revenue for the state but at the same time prevent gambling problems, the alternatives are more difficult to implement. Continuing in a completely monopoly system in this case is legally difficult to implement, at least in the way where customers would be satisfied. It seems to be obvious that license-based system would generate more money for the state than monopoly system.

I think it is particularly important that Finland now carefully considers the future of its gambling system and makes a comprehensive and neutral analysis of the matter before making a final decision! In our own report, we have described and calculated the effects of different gambling systems on gambling problems, government revenue levels, and customer experiences. We are happy to help you get a good and safe gambling system in Finland that is also good from customer point of view!

THE IMPORTANCE OF FACTS

I have a problem, big personal problem! I’m a person who likes to make decisions based on facts. I haven’t understood how someone can trust on decision-making process where they haven’t used correct information. But now, someone could say finally, I have realized that it is not always clear what the facts are. “The truth” could be different for me than for the other person.

It has been obvious that there are almost always lack of information and we have to make decisions without all facts. We are living in the middle of chaos and we should accept that. But I still believe that right information will help you to make better decisions and that’s why you should try to collect as much facts as possible.

My company made quite big report for one of our customers. We needed there lots of information about different countries and market developments. As always, I made a list of statistics and other information which we should have before writing the final report. It sounded as a quite simple process to collect that kind of background package and the idea was to make analysis based on that information. It wasn’t so difficult to collect information, but we made one mistake which caused me personal crisis. We were curious to hear two different stories about the same situation. Both of those stories were believable ones and they were based on facts. How it could be possible that two bodies were using different facts when they were talking about the same situation?

The outcome of our work would be quite different if we would believe on the other story but not on the other one. That’s why we decided to have the third opinion from the independent research company. We got there the third version of “the truth”. Which one of those three stories is the right one? We don’t know but it was easy to choose the facts from the research company because they probably don’t have reason to have wrong data by purpose. But those two other bodies are working in that area and they should have more information than the foreign research company has, so did we make right decision?

Of course I have known that companies are using data which is supporting their own business goals. Here in Finland we are even used to say “lie, whopper, statistics” which describes that it’s possible to “prove” with statistics whatever you want. My problem is that I don’t understand why we are doing that? I believe that the world would be better place and companies would make better business if we would have the real data available. Sharing the information would help everybody and then it would be up to companies and persons how they would use that information.

I describe two cases from the gambling world where the correct information would help almost everybody. The first case is the prevention of gambling problems. The gambling industry has all data of their customers’ gambling behavior. If ministries or other authorities who are taking care of gambling problems would have that data and if they could link that to other information they have about same persons, they would have much better tools for fighting against gambling problems.

Someone might say that gambling companies are not willing to share all information about their customers because they are afraid of loosing too much revenue by doing that. They have risk of loosing customers who are playing much, probably too much. From short term business point of view they are the most profitable customers, but is that the case in long-term? If gambling business would manage to reduce gambling problems, the reputation of whole industry would increase and in long-term it might mean better business for all gambling companies. If regulators would have better information and tools, they could set more personalized limits and let normal customers continue gambling without so tight restrictions.

The other case is the discussion of market shares and the size of gambling business in specific countries. I take Finland as an example although I believe that it is not the worst example at all. Does anyone know what is the size of whole gambling business in Finland and how big market shares different gambling companies have here? No, although all data is there but companies are not willing to share it. Just the total numbers from monopoly operator Veikkaus are available and everything else is based on estimations or even guesses.

Veikkaus used to publish their own analysis about the size of total gambling business and their own market share of that in Finland. Offshore companies were saying that Veikkaus was underestimating the offshore gambling business in Finland. At the same time gambling problem researches were saying that Veikkaus was overestimating that offshore gambling. That led to the situation where Veikkaus is nowadays using the independent estimation from H2GC, but the similar discussion is still going on around that issue. Offshore companies say that offshore business is bigger than H2GC is estimating and authorities say vice versa. It is easy to understand what the reasons for that are. Both bodies are trying to improve their own interests.

It would be important to have the real data from the offshore companies to make correct decisions about the gambling law and regulation. Now the authorities have to make decisions based on incomplete information and there is the risk that they will make wrong decisions. I would like to develop the system where we would have all important facts available for decision making. That would make gambling business better for the customers for sure and probably it would be better for the companies too.

RESPONSIBLE GAMING HAS IMPACT ON THE REPUTATION OF GAMBLING INDUSTRY

I have worked almost 30 years in gambling business and most of that time in lottery world where I was told to use word “gaming” instead of “gambling” when I was talking about our business. I’m not native English-speaking person so I don’t recognize all details in that language, but I believe that it wasn’t only about detail issue but rather about reputation of business. Lottery people have always thought that lottery is much softer and not so dangerous business than casino business is. Sports and Horse Betting are somewhere between those two areas. To me they all are gambling business and it doesn’t matter how soft or hard versions they are. I use gaming when I’m talking about casual and social games like for example Candy Crush Saga.

It is true that lottery games have caused much less, or almost at all, gambling problems than other gambling verticals. That’s one of the main reasons why lottery has had much better brand in the society than other games groups have had. The other reason has been “benefits for the society and good causes” ideology which has been the model all over the lottery world. It’s still very common that states have monopoly for lottery games and profit from those games is going to good causes. In other games groups that hasn’t been the case or if it has it’s not anymore. The gambling world has changed and is going to change.

Responsible gaming has always been important part of gambling business, but its role has increased rapidly during last few years. Especially in Europe responsible gaming has big role in political level discussion and I’m sure that other continents will follow soon or later. It’s important to understand what responsible gaming is about. To be honest I’m not expert on that area, but I have my own view about responsible gaming and I’ll try to explain how it should work.

Problem gambling and responsible gaming are not exactly the same issue but of course those two things are linked together. There are about 3 % of adults who have had gambling problems here in Finland. About 40 % of that group are serious problem gamblers which means that there are 50 – 60 000 people who really suffer. At least in Finland the most of gambling problems are caused by casino games and especially by slot machines. That’s why the former lottery company and horse betting company haven’t thought so much about gambling problems. Of course Horse and Sports Betting are reasons for some of those gambling problems but not at all at the same level than casino games. All game verticals have become quicker and harder and they are not anymore so different than they used to be before. Responsible gaming should be in the agenda of all gambling companies.

Gambling professionals seem to be worried what will happen to the reputation of our industry. There is more and more public discussion about that and unfortunately that discussion sounded to be rather negative one. It looks like gambling will follow the way which has happened in tobacco industry already many years ago. Smoking was very common when I was young adult, but nowadays it’s not acceptable at all. I think that gambling and smoking are not the same. Smoking is unhealthy for everybody, but gambling is not so dangerous for 80 – 95 % of people. Gambling is more like alcohol than tobacco when I think about problems caused by those things. It’s sure that gambling companies should do more in responsible gaming area, but there is no reason to ban whole gambling, because it causes problems for some of customers. We should concentrate on finding effective solutions to prevent those problems!

The problems won’t be solved if just some companies would change their rules, business models or whatever is needed to change. I think that whole industry should take responsible gaming really seriously, because it will affect on the reputation of industry. If there are companies which don’t care about the welfare of their customer, we can’t solve these problems, because problem gamblers would have companies where to move from the responsible companies. How we could solve that?

States, regulators and social welfare bodies, should decide and describe guidelines and the most important features for gambling companies which should operate according to those rules. I would describe that like “box” where companies should stay inside, but there they could run their business quite freely. If there would be any company which is not following those rules, that company should be punished very heavily and finally prevent whole operations of that kind of company. That model would work if whole industry would agree on that and there would be good cooperation between the industry and regulators.

What would be the best way to prevent gambling problems? I believe in personalization where gambling companies could utilize also other data sources than their own customer data. Unfortunately, it’s not legal to combine for example company’s customer data and data of the customers who have got help for gambling problems. In principle GDPR is good thing, but in gambling problem area it prevents to solve even bigger problems than customer’s privacy. One solution could be state level data center which could have “black box” where regulator could combine information about gambling problems, income/tax level and gambling data. The result of that kind of information would be personal level gambling limits and/or bans for gambling which should be mandatory for all license companies.

I believe more in personal limits than general level limits. I’m not sure if customers could really make right decisions by themselves when it’s about gambling limits. Regulators and social authorities & experts together with gambling companies should help customers to set them the best possible limits. Those limits could be separate in different gambling verticals (lottery, casino etc.). Gambling companies have and will have tools like AI and machine learning which could help them to make better work in responsible gaming area. I hope that gambling industry could find out the way to prevent gambling problems in more effective way than it’s the case now and at the same time we could continue to run our business without causing any useless disruption for those customers who could play our games without any problems!

RESPONSIBILITY – OPPORTUNITY OR THREAT?

Responsibility is ”the theme of the day” in gambling business. My colleague Sami Siltanen wrote about that in his blog www.patakuningas.com (in Finnish) last week. I decided to continue with the same theme but from slightly different perspective. You might think that everything has been said about responsible gaming and it’s impossible to find out any new views. That’s probably the case but it’s so important issue that I should try!

Gambling is so dangerous that states have decided to control that business heavily. Some of customers have big problems to control their own gambling. It’s very similar case than in alcohol consumption. If player can’t control his/her gambling the result could be extremely fatal. Society and gambling companies should do their best to prevent those cases.

EC Court of Justice has stated that the member states have possibility in gambling business to limit the free movement of products and services which is against the main principles of EC. That limitation would be possible if that would help member state to prevent problems related to gambling. That kind of problems could be criminal actions and also gambling problems.

What society could do to prevent gambling problems? Countries like Finland who have monopoly system in gambling business have an idea that monopoly at itself will reduce gambling and that would further reduce gambling problems. There are own gambling laws and rules in all countries and those laws will help states to control also gambling problems in principle level. Authorities have also some tools and they try to do their best to control gambling operations in practical level too. One big challenge is that digitalization has already break the state lines in practical level and it is more difficult to control all gambling.

I would say that there are two kind of problem gamblers. According to surveys there seem to be about 1 % of adults who have serious gambling problem – it’s like disease and their really need treatment for that. That 1 % level is surprisingly same in different countries although gambling legislations are quite different ones. According to surveys there are about 40 000 people who have serious gambling problems in Finland. Totally there are approximately 3 % of adults who suffer somehow from gambling issues. Those serious gambling addicts are included in that 3 %. So, there are totally about 130 000 Finns who have some kind of gambling problems and 1/3 of them have big problems. These numbers have been at the same level already years. There has been surprisingly less change in those numbers although the volume of gambling has increased.

What gambling company could or should do? I listened to the Swedish gambling problem researcher Thomas Nilsson already 25 years ago and I still remember what he said. According to Nilsson there are not so much what gambling company could do to prevent problems of those addicted players. They will find out new way to gamble anyhow and the society should take care of treatment of those people. Gambling companies should concentrate on the group of customers who have some problems and try to prevent them to move to more serious group. There are some tools like gambling limits and marketing pans which companies could use. Companies have nowadays more tools than they had before because there are more data available and that help companies to analyze their customers. From prevention point of view, it would be good to combine information from health care and gambling because then companies could even blog out all gambling addicted consumers. I understand why this is illegal from privacy and information security point of view and won’t happen…

Quite many gambling companies have started to talk about how responsible firms they are. Almost all companies have limits for gambling and they justify those limits with problem gambling reasons. In many cases that’s not the real reason at all! According to researches there seem to be just light correlation between gambling volume (euros) and problem gambling. If company would real like to reduce gambling problems responsibility should set up guidelines for whole business operations. Companies shouldn’t ask are we willing to select our business goals or responsibility! Gambling companies should decide frames for their business operations based on responsible values. Company should operate inside those frames. It should be clear to all employees what company could do and what not. There are for example product development tools which help to analyze how dangerous new game would be and it shouldn’t be allowed to introduce too addicted games. In short term it would be tough to notice that company will lose some customers to more irresponsible operators but in long term more responsible companies will finally win. I believe that responsibility will be one of the most important competitive edge in gambling business. The reason for that is that customers will trust on responsible companies more than the other ones!