The Betting, Gaming & Lotteries Commission regulates all forms of gambling in Jamaica.

The last few years has seen an increase in the number of gambling operators and gambling products in Jamaica. This more competitive market has resulted in a noticeable rise in the volume and style of gambling related marketing and advertising, raising concerns about how this may be influencing society's attitudes and perceptions of gambling and the impact of this on children, youth and the more vulnerable persons in society.

The Betting, Gaming & Lotteries Commission is aware that research conducted by betting, gambling and lottery regulators in other parts of the world has shown a clear link between marketing and advertising and risks to customers, children, youth and vulnerable individuals, resulting in those regulatory authorities introducing new controls to ensure customers and better protected, and children and youth are not unduly exposed to gambling and gambling products.

As the national regulatory authority for all forms of gambling, the Betting, Gaming & Lotteries Commission has a responsibility to take heed of this and take appropriate action to evaluate if consumers in Jamaica are also exposed to a similar risk, and if so, ensure appropriate controls are put in place to protect them. The Commission also recognises, however, that the type and level of risk will vary from jurisdiction to jurisdiction, so any controls or rules around marketing and advertising need to be proportionate and relevant to the betting and gambling market in Jamaica, and to the Jamaican society.

Evidence and Stakeholder Engagement
In order to understand the risks posed by the increase in marketing and advertising of gambling and gambling products in Jamaica, alongside the information provided by RISE, the Betting, Gaming & Lotteries Commission engaged with two local agencies: Hope Caribbean Co. Ltd and Bluedot to conduct independent research into a number of areas including:

• a) Prevalence of gambling in Jamaica
• b) Links between gambling advertising and gambling
• c) Awareness and perceptions of risk

The results from these two studies have highlighted a number of concerns mirroring the experience of other jurisdictions relating to the relationship between exposure to gambling and gambling products through marketing and advertising, and the potential impact on all consumers, but especially children, youth and the vulnerable in society.

Research Findings

Demographics:

• Over 61% of respondents indicated that they had taken part in some form of gambling in the preceding 12 months.
  Over 50% of participants indicated they were under the age of 25 (31% aged 19-24; 21% between 14-18).
• When asked about their knowledge about the risks relating to gambling less than 1% claimed to be knowledge. 51% indicated that they were 'somewhat knowledgeable', with the remainder of responses indicated limited or no knowledge about the risks related to gambling.
• It was also noted that some persons used gambling as the main source of income or as an addendum to their main source. This seemed to be especially the case for those in lower income groups who may be unemployed or underemployed. Some participants shared stories of individuals using games such as Cash Pot as a job, playing to provide lunch money for children and to get funds to purchase meal items.
• For some gambling was a part of their lives at home as parents gamble or they see it in the community they reside. In some instances, family or community members may even involve children in gambling activities and this becomes a part of their lifestyle in their adult years.

Marketing & Advertising

• Almost 40% of respondents became aware of gambling as a direct result of some form of marketing or advertising (from billboards and TV to social media and merchandising); Almost 25% through a friend; and just over 15% through a family member.
• Gambling related marketing and ads were thought to be misleading or untruthful by many participants. Ads were described as persuasive and playing on an individual's desire to win money or prizes.
• The use of key phrases and fine print provided sufficient information to make them truthful.

Reasons for believing ads were misleading or untruthful included:

• The ads give people false hope
• The ads tell you what could be won but do not say what could be lost
• The low chances of winning were not highlighted

Children, Youth and Vulnerable people

• Data provided by RISE suggests that this rise in gambling activity, which may or may not be directly related to advertising is reflected in the numbers of callers to its helpline, in particular:
• The number of callers requesting access to the Voluntary Self-Exclusion Programme has increased over the last 3 years from 15 in 2020, to 25 in 2021, to 42 in 2022, suggesting a strong link between increased levels of gambling and problem gambling.
• The highest risk age group, based on callers to their service, is 25 to 35.
• The figures from RISE also indicate some extremely concerning trends in relation to young people and children:
• In recent years up to 15% of calls relate to a child.
• There has been an increase in the number of schools island-wide requesting interventions for students involved with gambling at school; and
• Students have been observed sharing the times for lottery game draws as well as the meaning attached to numbers in particular games, and indicated that this knowledge is based upon repeated exposure to adverts and draws that are usually taking place during the time that they are allotted to watch television, including the news hour.
• Some Urban Guidance Counsellors and High School teachers believed that children were now more heavily involved in earning money through various online ventures which may or may not include gambling.
• 14.65% of respondents indicated that the source of funding for gambling came from their allowance (pocket money or lunch money); 10% from savings; 4% from pension/benefits.
• Gambling was seen as a quick way to earn money and for some this was a key driver to gamble. Urban Guidance Counsellors and High School Teachers pointed out that gambling was "not easy money but easily accessible…it's at my fingertips". Its accessibility meant it was a possible solution for many as a means of earning funds to take care of needs or to drive the desire to escape poverty.
• "Most times you at school and you walking pass, almost every class you see people a gamble… because they want money to spend" 14-18yrs Rural Males

Copies of the full reports can be found here:
Report 1
Report 2

Stakeholder Engagement.

Based upon the research findings, the Betting, Gaming & Lotteries Commission is actively considering a proposal to implement fresh regulations for the promotion and advertising of gambling and related products in Jamaica."

All stakeholders, including consumers, betting, gambling and lottery operators and members of the public are invited to share their views on these proposals

The Consultation
The Consultation looks at the introduction of new measures to:

• Ensure gambling related marketing and advertising is conducted responsibly.
• Limit the exposure of children, youth and vulnerable individuals to gambling related content.

We are proposing to introduce the new guidelines by April 1, 2024.

Background
The Island has seen significant changes in the betting and gambling landscape in recent years, with traditional forms of betting such as racing, giving way to forms of gambling that are more readily available and easier to access, such as betting, lottery and gaming machines.

Figure 1: Licensed operators 2019 v 2021

Whilst the impact of COVID and lockdown saw a significant shift in consumer habits, the continued growth of the gambling industry in Jamaica over the last few years, and in particular products which can be easily accessed through remote communication devices, has been met with a significant increase in the volume, form and format of gambling messages and content across both traditional marketing channels such as print and broadcast, and emerging technologies such as push notifications, SMS and streaming platforms. In the absence of any specific regulations governing the safe and responsible advertising and marketing of gambling products and services there is a significant risk of, young people and vulnerable people being exposed to gambling products and services resulting in gambling becoming normalised and presented as just another form of entertainment and without a clear understanding of risk.

Data provided by RISE Life suggests that this rise in gambling activity, which may or may not be directly related to advertising is reflected in the numbers of callers to its helpline, in particular:

• the number of callers requesting access to the Voluntary Self-Exclusion Programme has increased over the last 3 years from 15 in 2020, to 25 in 2021, to 42 in 2022, suggesting a strong link between increased levels of gambling and problem gambling;
• the highest risk age group, based on callers to their service is 25 to 35.

The figures from RISE Life also indicate some extremely concerning trends in relation to young people and children:

• in recent years up to 15% of calls relate to a child
• there has been an increase in the number of schools island-wide requesting interventions for students involved with gambling at school; and
• students have been observed sharing the times for lottery game draws as well as the meaning attached to numbers in particular games, and indicated that this knowledge is based upon repeated exposure to adverts and draws that are usually taking place during the time that they are allotted to watch television, including the news hour.

Research commissioned by the Betting, Gaming & Lotteries Commission in 2023 supports this with key findings suggesting that:

1. Children and youth are aware of and engaging in gambling related activity to a far greater extent and greater numbers than previously thought.
2. The majority of awareness about gambling and gambling products is as a direct result of marketing and advertising of gambling and gambling related products.
3. An overwhelming majority of respondents are not fully aware of the risks related to gambling.
4. There is a sentiment that marketing communications are misleading and do not highlight the risks related to gambling.

The proposals in this consultation relate to the introduction of new measures designed to ensure that all marketing and advertising of gambling and gambling related products in Jamaica: 

• adhere to a common standard of social responsibility
• clearly communicate the risks related to gambling
• are not misleading
• protect children, youth or vulnerable people from being overly exposed to gambling related content.

New Guidelines for Marketing and Advertising of Gambling and Gambling related products in Jamaica

This Consultation covers 4 key issues:

1. Adhering to a common standard of Social Responsibility
2. Communicating the risks related to gambling
3. Marketing & advertising is not misleading
4. Protects children, youth or vulnerable people from being overly exposed to gambling related content

Summary of Issue 1 - Adhering to a common standard of Social Responsibility

• Whilst Jamaica has laws and regulations covering advertising and marketing at a national level, these are generic and do not include any rules specific to gambling. This allows operators to apply their own interpretation as to what they consider to be acceptable or socially responsible. The Betting Gaming & Lotteries Commission would like to introduce a common standard to ensure that all forms of marketing and advertising across all and any channel adhere to a minimum common standard of social responsibility.

Summary of Issue 2 - Communicating the risks related to gambling

• The research shows that there is a significant lack of awareness about the risks and harm that can be caused by gambling. The Betting, Gaming & Lotteries Commission would like to introduce new rules that will require that all gambling, marketing and advertising content is clearly communicated. ,

Summary of Issue 3 - Marketing & Advertising is not misleading

• The research indicates that there is a perception that certain advertising and marketing practices lack transparency or intentionally deceive consumers. This deception can manifest in various ways, such as misrepresenting the actual odds of winning a prize or concealing the terms and conditions associated with a bonus or promotion. The BLGC would like to introduce new rules to guard against content that could be intentionally or accidentally misleading.

Summary of issue 4 - Protect children, youth or vulnerable people from being overly exposed to gambling related content

• The research shows that the main driver for awareness around gambling and gambling products is marketing and advertising, (TV, press, billboards, merchandising, social media), all of which are easily accessible to children, youth and vulnerable groups. The Consultation invites stakeholders to share their views together with supporting evidence on proposed changes designed to limit exposure to gambling and gambling product content to these groups.

Adhering to a Common Standard of Social Responsibility
Whilst Jamaica has laws and regulations covering advertising and marketing at a national level, these are generic and do not include any rules specific to gambling. This allows operators to apply their own interpretation as to what they consider to be acceptable or socially responsible. The Betting, Gaming & Lotteries Commission would like to introduce a common standard to ensure that all forms of marketing and advertising across all and any channel adheres to a minimum common standard of social responsibility.

The Betting, Gaming & Lotteries Commission proposes to introduce rules to ensure that any content used to promote gambling and gambling products or services, across any delivery channel (e.g. TV, press, radio, social media, blogs, billboards, perimeter fencing, hoardings, or any other channel or means that is accessible to the public) should adhere to a common standard. The new rules would be in additional to existing national laws, regulations and standards on advertising and marketing and focus on how language and imagery used in the promotion of gambling and gambling products should not give customers a distorted or misleading impression of impact of engaging in gambling.

Examples might include not suggesting that gambling could make an individual more attractive to the opposite sex, improve their financial circumstances, or use imagery that could portray gambling as cool or sexy, or be attractive or engaging to children, youth of vulnerable people.

This Consultation provides stakeholders with the opportunity to comment on, and inform, the specifics of those proposals. We remain open to direct engagement during this period. We will review consultation responses alongside any other additional evidence that is obtained prior to the conclusion of this consultation and provide an update as part of our consultation response.

Responding to this Consultation

• You can choose to respond to any or all questions; we will consider all responses.
• We will publish the names of individuals or the organisations they are responding on behalf of on our website as part of the published responses to this consultation.
• The consultation will close on December 1, 2023.
• Responses received after this date will not be considered.

You may respond to the consultation using the online e-Survey:

Betting Gaming & Lotteries Commission Consultation
78cef Hagley Park Rd
Kingston 10

If you have any questions or queries about the Consultation, please contact:
Wendy Robertson
Email: [email protected]; or [email protected] Cell: 876-552-9977

Please provide your responses by completing the online e-Survey here.