The Betting and Gaming Council (BGC) has published its inaugural Game Design Code of Conduct (Code).
The Code is significant because it has been introduced at a time of heightened political and regulatory scrutiny. It represents a significant and ongoing commitment from BGC members, who comprise more than 90% of the UK industry, to integrate Safer Gambling principles into game design and to invest in research to improve understanding of responsible game design for the benefit of consumers.
This announcement addresses the Gambling Commission's challenge to the industry from October 2019 to produce an industry code for product design, and is a consequence of the work undertaken by the industry working group for game and product design established in January 2020.
The Code addresses concerns expressed by the Commission in response to the industry working group's initial draft code for responsible game design, which the Commission opined in their June 2020 progress report "represent[s] some initial tangible actions which are likely to move the debate on at least partially."
The industry working group's initial draft code commitments were limited to the Phase 1 standards described below, however the Code now includes further measures (referred to as Phase 2 measures) to be achieved by the end of January 2021 and longer term commitments covering access to safer gambling information during gameplay and mandatory player interactions every 60 minutes, by a future date yet to be determined. The BGC has also identified and is committed to exploring a number of key areas of concern (with projects starting during 2020) via the BGC Innovation and Testing Lab (see 'Living Document' below).
The Code has been published in advance of the Commission providing the responses to its own consultation on changes to the design of online slots, which closed on 3 September 2020. The industry is also keen to stay ahead of the curve in anticipation of the Gambling Act review, with responsible game design featuring in the House of Lords Select Committee's report 'Gambling Harm— Time for Action' (with the discussion beginning at paragraph 162).
What does the Code provide?
The commitments in the inaugural Code will be brought into effect in two phases, with the following Phase 1 standards representing measures that BGC members committed to adopt by 30 September 2020:
- Minimum game cycle speed of 2.5 seconds;
- Removal of turbo play (a feature that enable players to speed up the cycle of games);
- Removal of "slam stops" (which are features that enable players to end the base game before it would naturally conclude and may encourage intensive play); and
- Removal of multi-slot play (where players can place multiple stakes on multiple slots games simultaneously).
The following Phase 2 measures represent additional commitments which will be implemented by BGC members for new games by 31 January 2021; aimed at improving the transparency of games for players, as well as increasing friction between gaming sessions for players to stop, think and reflect between sessions so that they can make informed choices:
- Wins that are below the staked amount will be presented differently from wins that are equal to or greater than the staked amount; specifically for the former, the win line should be displayed for a period long enough for the player to understand the result of the bet (in accordance with RTS 7E), and a brief sound may be used to make the player aware of the result, and for the latter, it should be presented in a differentiating manner, e.g. a celebratory manner with corresponding animations and sounds; and
- Regarding bonus game notifications, bonus games that are separate from the base game cannot be automatically triggered without a positive action by the customer to interact with the bonus game, e.g. by requiring players to click a button to acknowledge that a bonus game has been won and can be entered.
The BGC has also made future commitments to give players access to additional safer gambling information during gameplay (e.g. a display will include a link to such information), and for mandatory player interaction every 60 minutes or at the conclusion of a game cycle.
The BGC has created a dedicated committee to review and adapt the Code on an ongoing basis. Moreover, the Code includes a commitments to a research-based approach to game development, with a view to identifying and mitigating potential risks, as well as to collaboration with academics, researchers, regulators and consumers (including those with experience of gambling-related harm) to identify risk and best practice.
The BGC Innovation and Testing Lab will also be used to inform the development of Code provisions in the future, with the following being identified within the Code as key areas for initial development:
- Game labelling (to improve players' understanding of slots games, including the creation of a consistent safer gambling icon to access game information and help pages);
- Increased staking (to gain a greater understanding of the prevalence of staking up behaviour and the circumstances in which this takes place, and how safer gambling messages can be incorporated to enhance player safety);
- Auto-play (to understand how auto-play impacts the speed of play, limit setting and player control, and whether restrictions are required if there is evidence between auto-play and players exhibiting markers of harm); and
- Display of net position and elapsed time (to consider the benefits of providing this information to players for individual slot sessions, or for their gambling activity as a whole).
Research into these areas will commence during 2020. In line with BGC's aim to promote a research-based approach to game development, the projects will be independently scrutinised, and BGC intends to be transparent in its reporting of BGC Innovation and Testing Lab's findings, methodology and data.
The BGC's members will have worked hard to adopt the measures outlined in Phase 1, and will be working towards implementing the Phase 2 measures over the coming months. The industry must also keep an eye out for the responses to the Commission's consultation on changes to the design of online slots, which will be published imminently, as well as developments in the Gambling Act review when that begins.
Although the Code is adopted only by BGC members, the BGC suggests that it might in the future recommend adoption of the standards as part of the Remote Technical Standards, in which case it would apply to all British licensed operators.
The BGC has shown leadership at a time when the industry must be seen to take significant steps to mitigate gambling-related harms. Critics may argue it should have come earlier, but the Code clearly demonstrates how seriously the BGC's membership takes the challenge of safer gambling, and of securing a more sustainable future for the industry.
It seems likely that the Commission's consultation will go further, however, including with the proposal to permanently prohibit reverse withdrawals (which have been banned until further notice pursuant to amendments made to the Commission's guidance on customer interactions in response to the COVID-19 outbreak), and the House of Lords Select Committee's recommendation to impose online stake limits as part of the Gambling Act review (discussed from paragraph 176 of the 'Gambling Harm-Time for Action' report) will put the industry on high alert.