In 2017 online bingo and gambling operators were contacted by regulators and urged to remove adverts that included images that could appeal to children. The regulators included The Gambling Commission, the Advertising Standards Authority and the Committee of Advertising Practice. The fallout of this action was that eventually online gambling sites had to clean up their act and remove images, adverts and even site designs that could be deemed cartoon-ish or child appealing. Visit any bingo brand or slots site today and most are identikit sites with little or no personality. We ourselves as affiliates had to remove the Loquax Duck from our logo to satisfy the requests of some business partners “just in case” the duck appealed to younger visitors. However whilst gambling operators play by the rules because they are at risk of losing their licences if they don’t, competition sites don’t have to because as we know they’re not regulated. But we think some are potentially breaking ASA/CAP codes, risking copyright infringement and making a mockery of their “it’s not gambling” position. All those withstanding they’re also not being responsible. Responsible play doesn’t just mean taking care of the players who spend money with you, it’s thinking about keeping everyone safe!
What Does The CAP Code Say?
The BCAP Code states that “17.4.5 Advertisements for gambling must not … be likely to be of particular appeal to under-18s, especially by reflecting or being associated with youth culture”. The guidelines published by CAP explain items that may have “particular appeal” include licensed characters, especially those that target U18s, animated characters, themes and imagery, sports and celebrities, humour and youth culture. The guide also covers something called game tiles. These are the various logos that you might see on a bingo or slots site to highlight a particular game. Before 2017 these included cartoon figures and popular superheroes from the likes of DC and Marvel. The guide explains that these tiles should “avoid using names incorporating specific characters familiar to children, as well as more general tropes, themes and imagery from stories or other media directed at children”. More about guidance with respect to gambling and protecting under 18s can be found on ASA. But as competition sites (or raffle sites or pay to enter sites) aren’t gambling? They aren’t licensed by The UKGC so surely there’s no problem? In this blog we’re going to highlight some isses with respect to competition sites that are currently running and then let you decide.
“But It’s Not Gambling”
There’s a huge question mark over whether pay to enter prize draw sites are gambling or not. On this blog post we’ve written a lot about raffle sites and it’s hard to argue that they’re not gambling. People are spending money – and in some cases a lot of money – for the chance to win prizes. You can say that’s the same as ITV Competitions and similar and to a point it is. It’s just that The UKGC rules are just out of date and need a radical overhaul. But for now competition sites aren’t not gambling sites. The good news is that some do have responsible play messaging despite them also explaining that “online competitions and/or prize draws are not considered gambling”. It’s not gambling but they do like gambling images.
The image above (screenshot 11/3) is taken from a competition site with 23K followers on Facebook and boasts of paying out over £6million in prizes. We don’t know about you but the first two images remind us of things you might see on a slots brand whilst the third one clearly indicates a slot machine. It’s not gambling but they’re using gambling images to encourage play. But they’re not the only ones!
Another site (screenshot 11/3) shows a roulette wheel promoting one competition with “£100,000 March Mega Spins” and another with a Rewards Grabber that has a £100,000 prize fund. But remember it’s not gambling.
In this example we’re showing a competitions site that uses well known gambling phrases to advertise their competitions. As well as High Card and Cherry Wilds you’ll also find Roulette Riches, Lucky Threes, Casino Cash Hunt, Stack Your Chips, Cherries Gone Wild and Lucky Dice!
And just for the record here’s another site (screenshot 11/3) with a Spin To Win car promotion and and a Prize Every Time competition. The car competition perhaps isn’t that slot orientated by there’s no denying the gambling imagery shown for the other. Interestingly all four sites shown above have no reference to responsible play on their sites.
Child Friendly Images
Some sites do have responsible play messaging on their pages and that’s good to see. In fairness there is a growing movement for improvements across the pay to enter sector. The fallout from Jackson Jackpot (including latching on to their demise by naming competitions after them as in image 1) is that people do want it to be more transparent. However noble all that is there’s still room for improvement.
The central image is not a great look for a competition site that’s loitering in the grey area of online gambling. Obviously there’s potential copyright issues but this is absolutely child appealing imagery as outlined by ASA/CAP. Next to that you have a Loot Crate competition which hints at Loot Boxes and interestingly these have been studied for problem gambling (Spicer et al).
Now whilst the “above “it’s not gambling” examples are the only issues on the individual sites, the one featured in this section has up to 20 images/competitions that raise a question mark or two. In the above there’s reference to odds, cartoon or fairy tale images and a reference to a popular slot (Book Of Dead). What we haven’t shown are other images that include images from Disney’s Cars and The Gruffalo.
Here’s another example (as above all screenshots taken 11/3). The graphics here look quite cool but they are potentially child appealing. Ice Age Instants could for example reference the movie franchise.
In the old days you could play on various Marvel themed slots including Iron Man and Spider-man. However when Disney took over the company they didn’t want their brands associated with gambling. Therefore the games were removed from gambling operator’s rosters. Again copyright issues aside, this competition site’s use of Marvel and Iron Man will fall under the appealing to children category.
Is There Any Good News?
The good news is that a lot of sites that we visited don’t have the kind of images shown above. They simply rely on showing the prizes you can win and not resorting to using cartoons, copyright images or heading down the gambling route. The bad news is that if you do a Google Image search for say “competition win slots” you’ll find multiple examples of platforms that have run competitions with titles such as Instant Win Slots, Jackpot Slots, Cash Casino Multiplier, Lucky Slots and many many more. Whilst pay to enter prize draws may not fall under UKGC jurisdiction this is unrefutable evidence that the sector is tapping into the gambling psyche of customers but without having to worry about responsible play issues or safeguarding their players. That needs to change! Players, platform developers and other siteowners need to call this stuff out too. There’s no need to use cartoons or copyright images to promote your competitions and if “it’s not gambling” then why use gambling imagery? It’s just not a good look and inflicts damage across the whole sector. Now we’ve not named any site in the above and hopefully removed all logos. The aim here is not to name and shame but to encourage all siteowners to do better. It may not stop The UKGC eventually getting involved but it might help put the sector in a better light if it’s actually being responsible.