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Ms. Judith Glynn and Mr. Richard Lennon
Principal, Strategic Science
Manager of Social Responsibility Research, Manitoba Liquor & Lotteries
Judith Glynn & Richard Lennon
February 4, 2015 – Vancouver, BC
Introduction Context / Background
Research Challenge/Opportunity
Methodology
Results
Policy Outcome
Questions
Context / Background
Reorganization of liquor and gambling operation and regulation
o Merger of gambling operator (MLC) with liquor operator (MLCC) to form Manitoba Liquor & Lotteries
o Regulatory functions of MLCC merged with gambling regulator (MGCC) to form Liquor and Gaming Authority (LGA) of Manitoba
o Announced in 2012; came into effect April 1, 2014
Research Challenge/Opportunity Liquor, lotteries differed in approach to assessing
advertising
o Liquor – according to requirements in the Act
o Lotteries – through established processes, review by Social
Responsibility and Corporate Communications
Need to adopt consistent and comprehensive policies
Opportunity
o inform standards through research, review of practices
o Compare standards on gambling and liquor
Methodology Review literature for associations between advertising and:
o in problematic consumption
o Known risk factors, e.g., imply influence of skill to win, gambling as means of escape, solve financial problems
Analyze advertising codes (national or state/province) for social responsibility (SR) themes:
o Jurisdictions with progressive SR practices and socio-cultural similarities
o Canada, New Zealand, United Kingdom, & Australia
o 8 alcohol & 10 gambling codes
Methodology: Alcohol advertising codes
Canada • Manitoba’s Liquor Control Act
• Canadian Radio-television Telecommunications Commission’s (CRTC’s) Code for Broadcast Advertising of Alcoholic Beverages
• Advertising Standards Canada’s Canadian Code of Advertising Standards
Australia • Alcohol Beverages Advertising (and Packaging) Code
New Zealand
• Code for Advertising and Promotion of Alcohol
United Kingdom
• Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing
• Code of Broadcast Advertising
• Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks (Portman Group)
Methodology: Gambling advertising codes
Canada • BC’s Gaming Policy and Enforcement Branch’s Advertising and Marketing Standards for the Gambling Industry
• Nova Scotia Gaming Corporation’s Code of Advertising Standards
• Manitoba Lotteries’ Responsible Gaming Standards
• Television Bureau of Canada’s Gambling Advertising Guidelines
• Advertising Standards Canada’s Canadian Code of Advertising Standards
Australia
• Queensland Responsible Gaming Code of Practice
• South Australia State Lotteries’ Advertising Code of Practice
New Zealand
• Advertising Standards Authority’s Code for Advertising Gaming and Gambling
United Kingdom
• Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing
• Code of Broadcast Advertising
Stages: Social responsibility themes
1. Develop themes: 27 for alcohol, 25 for gambling
2. Assess codes for presence, breadth, depth of scope and language
3. Identify best language for each theme/code
o Measureable and enforceable
o Language clarity for regulators and the organizations they regulate
4. Draft integrated code for alcohol and gambling
ResultsAlcohol - Focus on underage consumption
Gambling – focus on at risk and problem gambler, and underage
• Youth appeal
• Age of models
• Placement (time of day and audience composition)
Informed consent
Social pressure
Appeal to financially vulnerable
Cultural stereotyping/ vulnerabilities
Youth
At-risk/problem gamblers
Responsible gambling messaging
Alcohol
Placement
Sponsorship
Example 1: Isleta Casino Ad
Example 1: Isleta Casino Ad
SR Themes: “Appeal to financially vulnerable: Solve financial problems / Replacement for employment / way to pay routine expenses”
Example 2: Betfair ad
Example 2: Betfair ad
SR Themes: “Underage: Youth appeal; Feature youth underage”
Example 3: Ladbrokes ad
Example 3: Ladbrokes ad
SR Themes: “Informed consent: Not imply influence of skill to win”
Example 4: Pistorius ad
Example 4: Pistorius ad
SR Themes: “Irresponsible or criminal behaviour”
Implications Address pure social marketing campaigns by industry
New theme for Alcohol codeso solitary consumption
Gambling – began with 39 themes from literature and across all codes, combined and refined to 25 o First set of themes for gambling
o Research needed to test and further refine
Integrated codeo Common risk factors
o Risk factors specific to alcohol or gambling
Policy Outcome Minimum regulatory standards – advertising must:
o Be consistent with Canadian Advertising Standards
o Include a social responsibility message
Decision to hold ourselves to higher standard – why?
o Social responsibility goal of minimizing harm
o Mitigate potential risks to public image
o Crown corporation – expectation to uphold community values, lead by example
Policy Outcome1. Decision to implement evidence-based standards
2. Additional input on public image / social values elements
o Manitoba Women’s Advisory Council regarding
depiction of women in advertising
3. Apply standards via advertising assessment process
o Ensure standards upheld consistently
o Input from other jurisdictions on their assessment
processes very helpful – thank you!
Advertising assessment scope Process ensures standards applied for any advertising
generated by operator, with operator logo, or appearing at
operator sites
Examples: marketing, casino/event centre promotion, ads/
thematics in Liquor Marts, CSR, SR or community support,
eGaming
Advertising assessment process Each functional area assesses advertising
o Previously, all signed off by Corporate Communications
o Disseminates standards throughout organization - sense of ownership
Reviewed, approved by authorized manager once ad fully developed
Escalation process to Communications/SR
o if concern raised or of lack of clarity about adherence to standard; or
o if advertising on television, through previously-unused channel, or if distributed outside corporation’s point of sale
Situation analysis required by manager – what is risk and rationale for proceeding (pre-set questionnaire)
Process auditing and evaluation Pilot process and review
o Full review to occur several months after implementation
Secure, central log/database to track all assessments
o Ongoing audit of advertisement, assessments and assessment
results
o Inter-rater reliability – do assessments differ by individual?
o Changes to process and/or training as required
Tracking and re-assessment based on complaints received
Annual reporting to executive level for each department
o ads, assessments, escalations and complaints
Process reviewed in full every two years
Advertising assessment toolWill this advertising … ?
• No
• Yes / Unsure
If Yes / Unsure, then
situation analysis
required
Next steps Employee training March 2015, roll-out April 2015
Review of process, finalization later in 2015
Product assessment tool to assess and respond to risks
related to all new and acquired products
o Apply to both alcohol products including shelf talkers
and games/game platforms
o GAM-GaRD is one example of such a tool
o Will be developed in 2015; rolled out in 2015 or 2016
Questions
Judith GlynnPrincipalStrategic Science
Richard LennonManager, Social Responsibility ResearchManitoba Liquor & Lotteries
204-957-2500 ext. [email protected]
Thank you!
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