Submission to the Standing Senate Committee on Transport and Communications: Bill S-269,

An Act respecting a national framework on advertising for sports betting June 5, 2024 The Centre for Addiction and Mental Health (CAMH) appreciates this opportunity to comment on Bill S-269. We are encouraged by this bill’s call for measures to restrict the number, scope, and location of sports betting ads in Canada. However, we recommend it be broadened to address the advertising of all forms of gambling, not just sports betting. Gambling-related harms While most people who gamble do not experience gambling-related problems, it is an activity that comes with significant risks.

An estimated 0.6% of Canadians meet the criteria for problem gambling, with an additional 2.7% being at-risk gamblers.1 But these statistics tell only part of the story. People can experience a range of harms to their physical and/or mental health as a result of gambling, even in the absence of a gambling disorder.2 Many people who gamble experience dysfunctional relationships and financial difficulties, so gambling-related harms can affect their families and communities as well.

And while people with a gambling disorder account for up to 40% of total gambling expenditures, up to 85% of gambling harms occur in people who do not meet the criteria for a disorder.3,4,5 People living with a gambling disorder commonly experience other physical and psychiatric problems.6 Up to 70% of people with gambling disorder have a pre-existing mental health problem.7 Anxiety and depression are common in this group, and research has consistently found elevated rates of suicide among individuals with gambling disorder.8 One study found that people with gambling disorder had 15 times the suicide mortality of the general population, with suicide being the leading cause of death in this group.9 People who gamble are not the only ones who can be impacted.

It has been estimated that for every person experiencing gambling problems, another 5 to 10 people are negatively affected, with harms to mental health and financial security especially common.5 Risk factors Research has found many factors that can place individuals at high risk of gambling-related harms. Individual characteristics may make some people more susceptible. For example, problem gambling is most common among younger males with lower levels of education.

Other groups may disproportionately experience gambling-related harms; notably, Indigenous people as well as people from lower-income households are more likely to be at risk of gambling problems than the general population.10 However, the most important predictors of problem gambling are not individual factors. Among the most important factors are: • Exposure to gambling. In general as gambling opportunities increase, gambling-related harms tend to increase; further the more an individual gambles, the more likely they are to experience harm.11,12,13

2 • Form of gambling. Forms of gambling vary greatly in terms of riskiness. Some combine features (e.g. rapid speed of play; losses disguised as wins) known to be problematic, making them especially likely to cause harm.11,12,13 In this submission we will focus on the latter. Riskier forms of gambling There are features present in some forms of gambling that are known to increase the potential for harm. There is a high level of consensus regarding the features most likely to cause harm.11,12,13 Most notably: • Speed of play (time between the gamble and the outcome).

Forms of gambling with a rapid speed of play tend to encourage more betting and longer play, and people experience more difficulty stopping.14 • Event frequency (time interval between bets). Forms of gambling with high event frequency are associated with difficulty stopping gambling and with greater monetary losses.15 • Features that encourage false cognitions or beliefs (e.g. by giving the illusion of skill or control, or disguising losses as wins).

Forms of gambling with such features tend to encourage longer play and lead people to underestimate their losses.16 Some forms of gambling combine these features in ways that make them particularly harmful. Three such forms of gambling stand out.

Electronic gambling machines (EGMs) The EGMs (often called slot machines) available in Canada are generally characterized by high speed of play, the possibility of large bets, and features encouraging false cognitions (notably stop buttons on slot machines, which give the illusion of skill; losses disguised as wins via celebratory sights and sounds; and near-miss events— all features strongly associated with harm). These features combine to facilitate rapid, immersive, continuous, and impulsive gambling.

The existence of these features is not a coincidence; EGMs are purposely designed this way.17 As a result, many EGM users have gambling problems, and it has been estimated that more than a third of EGM revenue comes from people experiencing gambling problems.3,18 For all these reasons, EGMs have been called the most harmful form of gambling.19,20 Online gambling Online gambling is a mode of access rather than a distinct form of gambling, but it warrants separate discussion due to its rising popularity.

Although recent data on online gambling in Canada are lacking, prevalence is certainly increasing.21 The global COVID-19 pandemic and associated public health restrictions, including the closure of land-based venues, contributed to rapid increases in online gambling participation.22 Online gambling participation is also known to have increased in jurisdictions that, like Ontario, have legally regulated online gambling sites.23 Online gambling is more common among people who gamble frequently and, for some, this form of gambling can significantly contribute to gambling problems.24 In fact, gambling online may be the single strongest risk

3 factor for developing a gambling disorder.24 Certain features of online environments may increase the likelihood of developing gambling problems, including: 25,26 • easy access and ability to play for long periods uninterrupted • ability to gamble alone • use of credit card and other digital payments that make spending easy • highly interactive or immersive features that facilitate losing track of time and/or money People who gamble online are more likely to have co-occurring mental health problems than those who gamble in land-based venues.27 As the popularity of online gambling increases, so do the problems.

In 2022, the same year Ontario opened a legal online gambling market, online gambling displaced EGMs as the main reason for calls to the Ontario Problem Gambling Helpline. In 2021, just 21% of callers to the Helpline were experiencing problems with online gambling; that share increased to 48% in 2022 and 63% in 2023.28 In-play sports betting In-play sports betting (also known as proposition betting) involves making a bet on a component of a sports event while that event is in progress.

Examples include betting during a baseball game whether the next pitch will be a ball or a strike, or placing a new bet on the outcome of the game after it has begun, based on active and shifting lines or spreads. This betting format has only been legally available for a short time so little is known about its uptake, but in jurisdictions where legal sports betting has been available for longer, in-play betting is an increasingly popular form of gambling. 29 As with EGMs, in-play betting facilitates rapid, immersive, and impulsive gambling.

Research has found that people engaging in in-play sports betting are three times more likely to have a gambling disorder than other people who bet on sports online, and their gambling problems are more severe.29,30 The role of advertising The purpose of advertising is to drive consumption, and gambling is no exception. There is a causal relationship between exposure to gambling advertising and a more positive image of gambling, as well as intentions to gamble and actual gambling activity.31 Children and youth, as well as those already experiencing gambling problems, are especially susceptible to these effects.

Unlike other substances / activities known to carry risk and regulated by the government— specifically alcohol, cannabis, and tobacco— there are no federal regulations or codes regulating the advertising, marketing, and promotion of gambling. Concerns have been expressed over both the volume and content of gambling advertising in Ontario— especially sports betting.32,33 While Ontario has some advertising standards in place, they compare unfavourably to other jurisdictions, being much more permissive and less protective of youth.

For example, the United Kingdom and Ireland have ‘whistle-to-whistle’ gambling advertising bans: during a sports broadcast, gambling ads and promotion cannot be shown from five minutes before a match begins until five minutes after it ends.34 It is also worth noting that several European countries have banned— or are in the process of banning— virtually all gambling ads, including on social media.35

4 Ontario’s rules to protect minors from exposure to gambling advertising are also comparatively weak. Using the UK as an example again,

whereas Ontario does not allow gambling ads in programming “directed primarily to minors,” the UK stipulates that ads must not appear in programming where minors make up more than 25% of the audience. 36,37 Gambling ads in Ontario also feature messaging and themes that are forbidden for other substances / activities known to carry risk.

For example, many of the sports betting ads appearing since 2022 seem designed to reach non-gamblers and encourage them to take up gambling, and some ads strongly imply that personal success can be achieved or enhanced by betting on sports.38,39 Ads with such themes would be prohibited under the Canadian Radio-television and Telecommunications Commission’s Code for Broadcast Advertising of Alcoholic Beverages (CRTC Code).40,41 Beyond advertising, the promotion of gambling takes other forms.

Many Canadian media entities have established partnerships with sports betting companies, leading to gambling content being embedded in sports broadcasts and apps. As a result of all these developments, Ontarians are more exposed to gambling promotion than ever. Given that such exposure is associated with increased gambling activity, which in turn leads to a greater likelihood of problems, Ontario’s current approach to advertising rules can be expected to cause harm.

CAMH recommendations In March 2024, CAMH released the Gambling Policy Framework , a document that makes evidence-informed recommendations for a public health approach to gambling. The Framework makes the following recommendations on advertising. • The federal government should develop and implement national rules governing gambling advertising and promotion, either through legislation (like with cannabis and tobacco) or regulation (like alcohol).

These rules should, at a minimum, include the following principles: o Sponsorships by celebrities, influencers, sports figures, etc., for gambling should be fully prohibited. This includes the promotion of “responsible gambling.” o There should be a whistle-to-whistle gambling promotion ban for sporting event broadcasts.

Gambling content of any kind would not be allowed from five minutes before a match begins until five minutes after it ends. o Youth protections should be strengthened.  Gambling advertising should be judged on whether it appeals strongly to youth, regardless of its appeal to adults.  Gambling advertising should not appear in media and venues where minors can be expected to account for more than 25% of the audience. o The following standards, borrowed from the CRTC Code,40 should be applied to gambling advertising.

Commercial messages for gambling should not:  attempt to influence non-gamblers of any age to gamble

5  imply directly or indirectly that social acceptance, social status, personal success, or business or athletic achievement may be acquired, enhanced or reinforced through gambling  imply directly or indirectly that gambling is essential to the enjoyment of an activity or an event  refer to the feeling or effect caused by gambling In conclusion, advertising for sports betting should be addressed, and we are encouraged by the introduction of Bill S-269. However, we urge the Committee to consider broadening its focus to address advertising of all forms of gambling.

For more information, please contact: Jean-François Crépault Senior Policy Analyst, CAMH 416 535-8501 x32127 JeanFrancois.Crepault@camh.ca The Centre for Addiction and Mental Health (CAMH) is Canada's largest mental health and addiction teaching hospital and one of the world's leading research centres in this field. CAMH is committed to playing a leading role in transforming society’s understanding of mental illness and substance use and building a better health care system. To help achieve these goals, CAMH communicates evidence-informed policy advice to stakeholders and policymakers. 1 Williams, R.

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