March 25, 2020

Amidst stories of gambling affiliates being accused of exploiting coronavirus panic in an attempt to encourage gamblers to spend more, it’s worth reminding affiliates (and operators alike) of some of those specific CAP Code (and BCAP Code) rules that might be of particular relevance in a time of ongoing pandemic.

Apart from being mindful of the general obligation not to create marketing communications that:

“portray, condone or encourage gambling behaviour that is socially irresponsible or could lead to financial, social or emotional harm”,

marketers need to be particularly careful about how certain situations and phrases used within their marketing campaigns might be viewed differently given the strange times we currently find ourselves in.

This advice goes beyond the obvious; the reported promotion of ‘Covid-free casinos’ by some affiliates has been called out as bad practice by the Responsible Affiliates in Gambling and rightly so. But at time of world-wide emergency, isolation and economic uncertainty, gambling advertising, like all advertising, must be prepared with increased sensitivity.

Remember, marketing communications must not:

• suggest that gambling can provide an escape from personal, professional or educational problems such as loneliness or depression (16.3.3 CAP Code);

• suggest that gambling can be a solution to financial concerns, an alternative to employment or a way to achieve financial security (16.3.4 CAP Code);

• portray gambling as indispensable or as taking priority in life, for example over family, friends, or professional or educational commitments (16.3.5 CAP Code); or
• portray gambling in a context of toughness or link it to resilience or recklessness (16.3.9 CAP Code).

So references or inferences to: ‘boredom’; ‘something to do whilst not at work’: ‘something to do whilst taking a break from working from home’; ‘supplemental income’; ‘lack of employment’; ‘escaping from the family’; or ‘keeping calm and carry on gambling’ are all flawed.

Similarly, any pre-existing campaigns which emphasise the social aspect of gambling (in an attempt not to fall fouls of the:

“marketing communications must not suggest that solitary gambling is preferable to social gambling” rule) (16.3.11 CAP Code);

are also likely to be insensitive to run in the current climate. Hopefully it’s unnecessary to point out that structuring any campaigns around gambling in isolation is also a blatant breach of this rule – but there it is, just in case!