1 TRCM STANDING COMMITTEE BILL S-269,

AN ACT RESPECTING A NATIONAL FRAMEWORK ON ADVERTISING FOR SPORTS BETTING Written Remarks by Dr Raffaello Rossi, University of Bristol 5th June 2024 In addition to my opening statement, I would like to take this opportunity to highlight one distinct issue of gambling marketing that I have researched in-depth. I believe it requires urgent attention by legislators—namely, the increasing use of social media gambling marketing. This is already happening in many places around the world, including the UK, US, Germany, and Canada.

The proliferation of gambling advertising on social media have recently attract criticism with comparisons to the wild west. A key concern is that regulations are just not keeping up with industry developments and that children may be the ones most exposed to harm. Indeed, the influential WHO-UNICEF-Lancet Commission argued that “new technologies are exacerbating and creating new threats to children that are not well understood.

Gambling is a potentially large and unaddressed public health challenge for children.” The combination of novel social media gambling marketing, and ethical and practical challenges in research with children, has resulted in a lack of empirical data to inform policy makers. We are lacking even basic metrics such as children's exposure to gambling ads or, indeed, whether ads deliberately target children. The Appeal of Gambling Adverts to Children In a study we conducted with the London-based think tank Demos, we found, for example, that on UK Twitter alone, around 1m gambling ads are posted each year.

What is more, though, we uncovered that 73% of the 613,986 followers were under 24 years old, with 5% being under 16. When looking at the ages of the 455,958 users that engaged with these gambling ads (i.e., replying to or sharing the ad), we found that 68% were under 24 years. These findings are reflected in self-reported exposure data, which suggest that 72.4% of 18– 24-year-olds, and 45% of 11-17-year-olds see social media gambling ads at least once per week.

With these high numbers of engagement, followership and exposure, we wondered whether gambling ads – potentially inadvertently – target those young demographics. We conducted an online experiment with over 650 participants aged 11-78 and found that all forms of gambling advertising investigated triggered more positive emotions in children and young persons, than in adults. The bar chart below shows how social media gambling ads triggered positive emotions in youth, but (strong) negative emotions in adults.

2 The issue of content marketing Most advertising on social media relies on individuals to share content within their networks to make it successful for the brand . Conventional gambling advertising (ads that include a clear call to action and are focused around gambling) has been found to trigger negative emotions in many consumers, and does not lead to high engagement figures (e.g. liking or sharing the post).

Content marketing on the other hand, has been found to trigger mainly positive emotions (especially in children and young persons), and leads to much higher engagement numbers (i.e. user “liking” or “sharing” the post). Content marketing make up between 40% and 50% of all the gambling marketing on social media in the UK and Ontario – putting it at the heart of gambling accounts social media efforts. Content marketing is about “developing stories that inform and entertain and compel customers to act — without ac tually telling them to”.

This could be posting competitions, memes, funny pictures of cats, how-to content, or fascinating infographics — anything goes as long as it makes the user feel good and gets them to share the ad. Although gambling content marketing uses a variety of different techniques, they tend to have something in common: they seem very inconspicuous, innocent and harmless despite being advertising for a highly addictive product. Below four recent examples from Canada.

4 These seemingly harmless ads may function as a bait — luring users into engaging with the account without actually knowing that it is a gambling account. Beyond this insider-driven humour, news, emojis or memes are very unlikely to trigger feelings of “be careful — this is a gambling ad”. Our research found that gambling content marketing was almost four times more appealing to 11–24-year-olds than to older adults. What is more, 11 out of 12 gambling content marketing ads were found to trigger positive emotions in children and young persons, while only 7 out of 12 triggered them in adults.

Creating these positive emotions toward gambling ads and brands is not only likely to further normalize gambling as a harmless activity but may entice children and young persons to start following gambling accounts. We have meanwhile replicated this study with 60 children aged 11-17, yielding nearly identical results that highlight the validity of our work. Regulatory Failures Although gambling content marketing has been found repeatedly to be of strong appeal to children—an advertising code that exists in the UK, US, and Ontario—to date, none of these jurisdictions have intervened effectively.

This is despite our recent study, which highlights that gambling content marketing is not “obviously identifiable as such”—the first rule of most marketing regulations (both in the UK and as set by the Canadian Ad Standards). Content marketing, however, has no clear link to the product or service and is, therefore, potentially not obviously recognizable as a persuasive attempt. Previous arguments have centred around the fact that social media ads are clearly recognisable since they are posted by a “brand’s account.” However, this argument is seriously flawed.

Not only are many brands new, unknown, or very small, but also many businesses operate as individuals, such as politicians, lawyers, or tradespeople, making it next to impossible to differentiate between a private post and a commercial one. In our research with over 650 participants, we found that only 44% of content marketing ads related to gambling were correctly identified as “advertising” by 11–24-year-olds. Additionally, only 65.3% of adults were able to classify it correctly (see figure below).

5 We reported these findings earlier this year in our report with CBC News. We noted: ‘Alarmingly, 48% of the ads were deemed not clearly identifiable as advertising, thereby violating the Canadian Ad Standards Code 2 (Ad Standards, 2024). This code explicitly states that “No advertisement shall be presented in a format or style that conceals the fact that it is an advertisement.”’ To date, we have not heard back from the Ad Standards nor the AGCO regarding their assessment of the issue.

Recommendations In light of our previous work, we have been making the following recommendations to policy makers across different jurisdictions: 1. Compulsive Marketing Database To ensure that both researchers and policy makers are able to track trends in volume and content of gambling marketing, we recommend that new legislation includes a licensing condition for gambling brands to report on their advertising efforts. This is especially important for online marketing, where ads tend to be highly targeted and non-permanent. 2.

Ban Gambling Content Marketing Introduce legislation that comprehensively regulates gambling messages during sporting events. This legislation should include all forms of messaging during matches. This includes gambling marketing on pitchside hoardings, player shirts, and all other visible surfaces within the stadium. It should also encompass radio broadcasts and social media marketing during matches.

6 3. Legislation on Gambling Marketing during Sporting Events Introduce legislation that comprehensively regulates gambling messages during sporting events. This legislation should include all forms of messaging during matches. This includes gambling marketing on pitchside hoardings, player shirts, and all other visible surfaces within the stadium. It should also encompass radio broadcasts and social media marketing during matches. 4. Online-specific advertising regulations Our research has shown that social media presents additional opportunities for advertisers that are well beyond the scope and consideration of traditional advertising regulations. These include

(1) Encouraging engagement with and sharing of content that exposes an ever-increasing number of children to gambling.

(2) Immediate links to accessible betting on a mobile phone.

(3) Exposure to gambling opportunities at night.

(4) An incredibly high volume of gambling ads that serves to normalize the activity. Therefore, we believe that new, online-specific regulations should be developed in cooperation with social media platforms, technology experts, and academics to ensure effective regulations that utilize cutting-edge technological possibilities. 5. Include Children and Young Persons Directly Gambling advertising appealing to children is a serious issue. However, regulators rarely ask children and young persons what actually appeals to them.

We strongly recommend that regulators include children and young persons when evaluating complaints and also when creating new guidance meant to protect them. 6. Extend Advertising Protections to include 18-24-year-olds Many regulators use the terms “children” for anyone aged 0-15 and “young persons” for anyone aged 16 and 17. However, 18-24-year-olds find gambling adverts more appealing than other age groups. In line with recent neurodevelopmental findings, we recommend an extended definition of “young persons” to include 18-24-year-olds to ensure their protection.