BY PROFESSOR PETER COLLINS.

• As Professor of Public Policy Studies at the University of Salford, UK, and Director of the Centres for the Study of Gambling at the University of Salford and the University of Cape Town
• As Executive Director, reporting to the SA Responsible Gambling Trust, of the National Responsible Gambling Programme.

I hope that the Committee will wish to receive oral evidence from the SA Responsible Gambling Trust and the National Responsible Gambling Programme and I would hope to be part of the group that makes a presentation on behalf of this internationally-recognised public/private sector partnership of government regulators and industry in South Africa. I would also be happy to present to the committee in my personal capacity as an academic who specialises in the study of the gambling industry and gambling regulation.

This submission covers the following issues:

• General Principles of Good Public Policy Regarding Gambling
• Gambling and Gambling Regulation in South Africa
• Problem Gambling
• Research Findings
• The SARGT/NRGP
• Evaluation of the Bill
• Recommendations

Whether a jurisdiction’s laws and regulations relating to gambling are good or bad depends on the purposes for which they are being adopted. This means that good gambling law will not necessarily be the same in all jurisdictions since different jurisdictions will have different objectives.

Most obviously, some sets of laws relating to gambling seek to prevent or discourage people from participating in gambling. Others make it more or less easy (or easier than it used to be) for people who wish to gamble to do so.

Gambling laws also often discriminate between different types of gambling and have different rules for e.g. lotteries, slot machines and internet gambling. Sometimes also they discriminate between different types of potential gambler, e.g. minors and adults, citizens and foreigners, the poor and the affluent.

In general, governments typically pass laws prohibiting or restricting gambling activity because they believe either or both of the following:

• That gambling is wicked and therefore government should stamp it out
• That gambling is unacceptably dangerous.

Conversely, governments typically liberalise gambling law for one of the following reasons:

• They adjudge it better to have a legal than an illegal industry
• They believe that adults ought to be allowed to decide for themselves how to spend their own time and their own money in pursuit of pleasure, provided they do not unjustifiably harm others but even though they may make choices which are foolish or of which others disapprove
• They think it a good way - because it is relatively popular or at least relatively unresented - of raising money to fund good causes, i.e. of generating tax and quasi-tax revenues for the state
• They think they may be able to use gambling to enhance foreign earnings by attracting gambling tourists or cyber-tourists, by increasing spending by existing tourists or by inducing locals to spend their money gambling in the domestic jurisdiction rather than in a foreign one.

In addition all governments seek, as part of their general duty to protect their citizens from the use of force and fraud, to:

• Ensure that gambling is crime-free by ensuring that gambling services are only provided by "fit and proper persons"
• Ensure that the gambling is honestly conducted and that players know what to expect
• Protect minors and other vulnerable persons.

More generally, it is widely accepted that good gambling law must conform to the general principles of good public policy-making, namely that the policy is:

• Only adopted after appropriate consultation
• Does not normally operate retrospectively if this will damage legitimate interests
• Is evidence-based.

Similarly, good regulation in any industry is generally recognised as needing to meet the requirements of:

• Transparency: it must be clear why the regulations are being put in place, what they are and how they will work
• Accountability: the regulators must give an account of the effects and effectiveness of the regulations
• Proportionality: the onerousness of the regulations should be proportionate to the social harm they are seeking to contain or eliminate
• Consistency: they should be consistent with other regulations imposed by government
• Targeting: they should be accurately targeted at reducing or removing specific evils.

As a rule of thumb, it is helpful for policy-makers to treat gambling, for most purposes, in the same way that liquor is treated. Both gambling and drinking are harmless forms of recreation for the majority of people who indulge in them but lead to serious problems of abuse and addiction for a small minority. Both are morally and politically controversial, in that some people believe both that indulging in these activities is wrong even when no harm ensues and that government ought to discourage or prevent everyone from gambling or drinking. Others see nothing wrong with gambling and drinking in moderation and think it wrong for governments to impose the moral convictions of some of its citizens on others who have different moral views. Finally, it is generally agreed that only adults should have the option of choosing whether to gamble or drink.

The principal difference between gambling and drinking is that gambling to excess involves the abuse of money and this renders the poor especially vulnerable to getting into serious trouble if they gamble too much.

Under apartheid, gambling was prohibited on the grounds that it is immoral and that government had a right to impose the moral values of its supporters on all others. This prohibition was eroded in part by the development of casinos in the so-called Homelands, but far more drastically by the proliferation of illegal casinos.

These illegal casinos were easily accessible by poor people as they sprang up wherever there was a market - especially for machine gambling. Because they had lower costs than the international-style casinos with which we are now familiar they also offered cheaper (i.e. lower stakes) gambling.

The South African Government decided to legalise gambling, first and foremost, to eliminate this vast but popular illegal industry, by replacing it with one which would:

• Allow adults who enjoy gambling to do so

• Keep out crime
• Ensure that consumers are treated fairly
• Protect children and other vulnerable people

It also recognised that gambling can be a good way of raising money for projects which are in the public interest. These projects were typically not easily funded by ordinary taxation, but nevertheless promoted the redistributive objective of advantaging the least advantaged.

In all of this the new democratic government was largely successful. Illegal casinos have virtually disappeared. The industry is managed by accountable, publicly-traded companies, whose managers and employees have to meet internationally recognised probity requirements. The games are closely regulated to ensure fairness. Minors are prevented from gambling. Provincial gambling boards and the Lottery Board require operators to address problem gambling issues as a condition of licence.

In addition, the Lottery has been successful in raising money for good causes and casinos have contributed significantly to the funding of tourism-enhancing infrastructure as well as to provincial treasuries.

The principal weakness of the regulatory environment is that there are too many regulatory bodies with nine provincial boards, a National Gambling Board, a National Lottery Board, civil servants and a minister in each provincial government, as well as in the DTI. This is not only wasteful of money which could better be spent on, say, health and education, but it also leads to confusion, conflicts of interests, litigation and unnecessary duplication of work. All this, however, is a legacy of South Africa’s historic compromise at Kempton Park on the issue of whether the country should be governed as a federal or a unitary state, and the consequent concurrent responsibility between provincial and national governments for the regulation of gambling.

The other area where South African gambling law is deficient is that of "remote" gambling, i.e. gambling which takes place via the internet, cell phones or interactive television. The result is that there is a small unregulated internet gambling industry supplied to South Africa from abroad. This, however, is likely to become a bigger problem in the future as the relevant technologies become more accessible and user-friendly.

These considerations suggest that the 1996 Act needs amendment to streamline the administration of gambling regulation and to take account of new technologies. Overall, however, the legal and regulatory environment in South Africa is largely satisfactory and conforms with international best practice. It is consequently not clear why a whole new Gambling Act has been thought necessary.

The history of the eleven drafts of the bill suggests that the reasons for proposing a new act of parliament, rather than amendments to the present act, have been based on considerations of administrative convenience rather than on conviction that the country needs a new gambling policy. Be that as it may, discussion of the new bill is now certain to focus not on whether the existing regulatory environment is largely satisfactory in terms of what it set out to achieve, but on whether there is now too much gambling in South Africa and, if so, what should be done about it.

In fact, in both parliament and the press there has been substantial public disquiet expressed about how much South Africans now gamble. This focuses on the entirely proper concern which both the public and politicians have about excessive or problem gambling.

It is also true that in virtually all jurisdictions where there has been a liberalisation of gambling laws – usually, as in South Africa, to accommodate people’s rights to choose how to spend their own time and money, to raise revenues for the state and to keep out an illegal industry - there is a backlash against gambling some two or three years after the implementation of the new laws as stories begin to appear in the media and anecdotally of families being ruined by the massive gambling losses incurred by one family member. Awareness of a few sensational cases of lives ruined through compulsive gambling typically combines with a realisation that gambling is a popular pastime amongst the poor to generate a sense that "perhaps we have gone too far and should rein gambling in."

Inevitably, this reopens the whole debate about whether gambling should have been legalised in the first place. From the point of view of addressing problem gambling realistically and effectively, this may be unfortunate because both those with an economic interest in commercial gambling, and those who are in principle opposed to gambling on moral, religious or personal grounds, tend to distort the facts about problem gambling to support their case.

Although many aspects of problem gambling are disputed in the academic literature, the following propositions are widely accepted and not controversial:

• Like alcoholism and alcohol abuse, gambling addiction and problem gambling are conditions which cause serious damage to the lives of those who are afflicted by them, to their relatives and dependants, and often to their communities
• These conditions are also particularly tragic because of the great difficulty which problem drinkers and gamblers experience in trying to control their behaviour even when they realise that it is causing serious harm to themselves and those they care about
• Drinking and gambling for most people are harmless pleasures: in this respect, they are unlike smoking cigarettes and taking drugs which are rarely harmless
• The poor are especially vulnerable to excessive gambling, especially when poverty is combined with relative under-education which leads to a lack of understanding about how gambling works and a proneness to superstitious and other false beliefs in this area
• The evidence from around the world, as well as in South Africa, is that prohibiting or severely restricting legal access to alcohol and gambling does not solve the problems of addiction and abuse: it merely drives them underground.

It also seems to me to be beyond reasonable doubt that if an illegal gambling industry were to re-emerge in South Africa, the South African public would not tolerate the diversion of law enforcement resources – police, courts, prisons – from more serious crimes on the scale that would be necessary to deal with gambling offences.

Finally, it seems clear that good policy about problem gambling should be informed by the best available empirical data.

The National Responsible Gambling Programme has a research programme designed to gather data in South Africa about gambling behaviour generally, the incidence of problem gambling, and the characteristics of those vulnerable to becoming problem gamblers. It also monitors and contributes to international research on strategies for preventing and treating problem gambling. The research is designed to facilitate the work of legislators and regulators, on the one hand, and of educators and treatment professionals, on the other.

In 2000-1 a survey was conducted by Roots Research of 5 800 adult South Africans with some access to commercial gambling products, i.e. at least to a lottery outlet. We excluded minors and those living in remote rural areas. Our sample was thus representative of about 12m South Africans.

The survey covered many aspects of gambling behaviour, including rates of participation and reported expenditure on different types of gambling. In analysing this data we divided respondents into 4 categories: those who never gamble, those who gamble occasionally, i.e. less than once a month, those who gamble regularly (once a month or more) but only on the lottery and those who gamble regularly on some other activity such as slots, horses or scratch-cards, whether or not they also play the lottery.

We repeated this survey during 2002-3 and have now analysed most of the relevant data. We will shortly be publishing the results of this second national survey.

In the first survey, we stressed the methodological difficulties of using the 20-question survey method to calculate the proportion of the population who can be classified as problem gamblers. These include, in particular, the relative arbitrariness of the cut-off point, and the danger that respondents will lie about their gambling. However, the survey method is what has been used internationally for some years. It thus, at least, enables us to make some approximate international comparisons. It also enables us to compare our results for South Africa in 2003 with those we found for 2001.

Amongst our principal findings are these:

4.1 Participation

Of the 5816 respondents in the 2003 survey the participation profile was as follows:

• 76.3% had played the lottery;
• 31.1% " slots;
• 23.7% " scratch-cards;
• 10.5% " newspaper jackpots;
• 10.5% " horses and
• 10% " had participated in the remaining gambling activities, namely Fafi, Bingo, Dice, Roulette, Cards and Sport betting.

In respect to these activities amongst the 5 800 survey respondents in 2001:

• 69.5% had played the lottery;
• 28.9% " slots;
• 20.8% " scratch-cards;
• 12.8% " newspaper jackpots;
• 10% " had gambled on the remaining activities listed.

Of the 5 816 surveyed in the 2003 survey:

• 20.1% never gamble
• 4.3.% gamble occasionally, i.e. less than once a month
• 41.4% gamble regularly i.e. once a month or more, but only on the lottery; and
• 34.3% gamble regularly (once a month or more) on some activity other than the lottery whether or not they also gamble on the lottery.

These compare with the following statistics for the 5 800 surveyed in the 2001 sample:

• 25.6% never gamble;
• 2.2.% gamble occasionally, i.e. less than once a month;
• 34.6% only gamble regularly on the lottery, i.e. once a month or more; and
• 37.5% gamble regularly (once a month or more) on some activity other than the lottery whether or not they also gamble on the lottery.

Of the 5 816 surveyed in the 2003 survey the following gaming profiles were revealed:

• 72.3% play the lottery regularly (mostly once a week);
• 14.1% play slots regularly;
• 15.0% play scratch-cards regularly;
• 5.7% bet on horses regularly;
• 5.6% play fafi regularly;
• 3.3% do newspaper jackpots regularly;
• 2.2% bet regularly on sports;
• 2.0% play dice regularly;
• 1.4% play table games regularly;

These compare with the following statistics for the 5 800 surveyed in the 2001 sample

• 67.6% play the lottery regularly (mostly once a week);
• 19.2% play slots regularly;
• 12.0% play scratch-cards regularly;
• 9.5% do newspaper jackpots regularly;
• 7.8% bet on horses regularly;
• 4.9% play table games regularly;
• 4.5% play fafi regularly;
• 2.8% bet regularly on sports; and
• 1.7% play dice regularly.

The total gambling picture can be summarised as follows:

Taken together what these numbers show is that:

• Gambling overall has grown: the number of people who never gamble was 25.6% and is now 20.1%;
• The principal gambling activities in South Africa are the lottery; slots; scratch-cards; and the horses, in that order;

• Growth has come principally from the lottery: the number of people who play the lottery regularly was 67.6% and is now 72.3%;
• The number of people who play slots has grown somewhat overall (28.9% to 31.1%) but the number who play slots regularly has declined (19.2% to 14.1%);
• Scratch-cards are up both in overall and regular participation (20.8% to 23.7% overall, and 12% to 15% regular);
• All other gambling activities have declined in the face of the new competition.

The following table shows the reported amount spent on the lottery, slots and horses by disposable income group:

The reported spend by regular players on each activity by income group is as follows:

• All income groups tend to play the lottery including the poorest. Fairly poor people tend to play the horses and more affluent people tend to play slots;
• Conversely when poor people play the slots and horses, they spend a very high proportion of their income doing so, whereas they spend only modestly on the lottery.

These findings accord with what common sense would predict. The lottery is a much more accessible product to poor people both in terms of geography and price, whereas playing slots is an expensive pastime: it is difficult to purchase an average of an hour’s playing time for less than R100. Additionally, casinos have other barriers to entry by charging for entrance.

• In 2001, 221 out of 5800 respondents answered 7 or more of the 20 GA questions affirmatively. In 2003 the number was 270 out of 5816. These numbers constitute 3.8% and 4.6% respectively of the sample, 1.1% and 1.3% of the population as a whole and 5.3% and 6.1% of regular gamblers;

• There are probably now 550 000 people who gamble too much to the point where it is causing serious problems and who would benefit from education and/or counselling;

• In 2001, there were 35 problem gamblers who only play the lottery. In 2003 there were 87;

• In 2001, there were 186 problem gamblers who played something other than the lottery regularly whether or not they also played the lottery. In 2003 this number was 187;

• Of problem gamblers in 2001, 84% played something other than the lottery. 16% played the lottery only. In 2003 67.5% of problem gamblers regularly play something other than the lottery, 32.5% only play the lottery;

• Of the 270 problem gamblers in 2003:

• 21 members of the group revealed expenditure on roulette, the average monthly spend being R782
• 123 members of the group revealed expenditure on slots, the average monthly spend being R644
• 251 members of the group revealed expenditure on the lottery, the average monthly spend being R80.

The conclusions to be drawn from this are that South African numbers for problem gambling remain at levels comparable to those which are found in overseas jurisdictions, viz between 3% and 7% of regular gamblers. Such small increase as there has been is attributable to the lottery, although the lottery remains the safest form of gambling for the overwhelming majority of people, including poor people.

The majority of people, including the majority of poor people, gamble sensibly. It is also worth mentioning that the numbers are very similar for alcohol consumption in South Africa although the consequences of alcohol abuse are more damaging in respect of reckless driving and public and domestic violence. In neither case, of course, should the fact that problems of excessive and addictive gambling and drinking are comparatively small, be used as a reason for not doing as much as reasonably can be done to prevent these problem from arising, or providing help to those who develop such problems.

Reporting in terms of oversight to the SA Advisory Council on Responsible Gambling (SAACREG), and with supervision from the SA Responsible Gambling Trust (SARGT), the National Responsible Gambling Programme was developed with the goal of ensuring that everything that reasonably can be done is done in order to minimise the incidence of, and harm caused by problem gambling. It aims to do this by:

• Conducting research which will:

• maximise our understanding of gambling behaviour and problem gambling in South Africa
• monitoring the effectiveness of the programme’s treatment and prevention activities
• accessing international research into the development of strategies and practices for regulating gambling, educating the public and providing support services so as to minimise the harm cause by excessive gambling

• Educating gamblers and potential gamblers so that they understand:

• how gambling works
• that for some people gambling can ruin their lives
• how to recognise the signs of problem gambling
• where to get help

• Offering counselling and treatment through:

• A free telephone 24/7 helpline
• A free six-session customised programme of out-patient treatment
• Subsidised in-patient treatment where appropriate.

To be published next week is the latest Annual Report of the National Responsible Gambling Programme for 2002, and this will be circulated to the Portfolio Committee. Our quarterly reports are regularly distributed to a wide variety of stakeholders in government and elsewhere.

Naturally, we acknowledge that we have not yet achieved all the goals we have set ourselves in each of these areas, despite good progress to date. What should be highlighted is that this is a public-private sector partnership of the type that was developed first in New Zealand. The South African version of this model has been widely recognised internationally as offering a highly effective way for governments to address problem gambling issues because it ensures co-operation between the industry and government, the most cost-effective use of resources and the delivery of high quality prevention and treatment services to those who need them.

What is particularly important about the programme is that, though funded by industry and supervised jointly by industry and regulators through the National Responsible Gambling Trust, it is ultimately answerable to Government and the Minister for Trade and Industry through the South African Advisory Council on Responsible Gambling (SAACREG).

I offer comments in point form. I would naturally be happy to elaborate on them in oral evidence.

• The focus on problem gambling in the new bill is greatly to be welcomed. However, the specific recommendations run the risk that they will merely inconvenience non-problem gamblers while doing nothing to prevent problem gamblers from continuing to gamble to excess.

This applies, for example, to the closing of casinos which is likely to operate like mandatory closing hours for liquor outlets. People will simply gamble at illegal outlets or at home via the internet, as people find drink elsewhere too.

I confine my discussion of the bill to its attempts to address problem gambling issues. My views on other aspects of the bill are set out in my appended submission to DTI in response to being invited to comment on the tenth draft. This covers the issues of:

• Concurrent jurisdiction
• Internet
• Numbers of casinos
• LPMs

I repeat my general view expressed in my submission to DTI that problem gambling should not be addressed in detail by an Act of Parliament, and should rather be made a regulatory responsibility of the Minister. The bill should contain a general statement of the sort: "It shall be the responsibility of the Minister to ensure that appropriate steps are taken to minimise the incidence of, and harm caused by excessive gambling."

In general, there are two ways of addressing problem gambling issues. The first derives from the fact that problem gambling is in part the result of poor control over impulses and consequently consists in trying to minimise exposure to the temptation to gamble on impulse. The second derives from the fact that much problem gambling is a product of various kinds of ignorance including false beliefs about how gambling works, superstition, and lack of money management and other life skills. Broadly, for full-blown gambling addicts or compulsive gamblers, the central problem is an impulse control disorder, a recognised medical condition. For the much larger number of excessive or problem gamblers, the central problem is various kinds of ignorance.

Strategies for minimising the tendency to gamble impulsively are of two main kinds: those which focus on the location of commercial gambling opportunities and those which focus on regulating how games may be played. In general, the theory is that the more decisions players have to take before they gamble the less likely they are to gamble impulsively. This is why from a problem gambling point of view casinos out of town are preferred to urban casinos and urban casinos are preferred to "convenience" gambling, sometimes also called "ambient gambling," which are exceptionally easy to access and/or located at sites where customers go primarily to transact non-gambling business. Similarly, betting at tracks is safer in relation to impulse gambling than betting at high street bookmakers’ shops.

Obviously decisions about location need to be taken at the point where particular forms of gambling are being authorised for the first time. It might, for example, have been better if South Africa had started with a small number of resort casinos only. The question would then have been: "Would that be sufficient to eliminate the illegal industry?" Similarly, it would now be better, as Professor Graham Barr and I have argued in a consultancy report to the Northern Cape Gambling and Racing Board, rather than having lots of LPMs in bars and shebeens, to have a small number of 40-machine venues in locations remote from existing casinos, and where they could be easily regulated and required to generate some benefits for local communities, for example through contributions to local community trusts.

As to other attempts to address the issues of impulsiveness, in Australia in particular some experiments have been carried out requiring various types of intervention in the way games are played, e.g. by requiring machines to inform players at regular intervals how long they have been playing for and how much they have lost. However, when research on this was conducted by Prof Alex Blacszynski under the auspices of the prestigious Australian Institute for Gambling Research now located at the Australian National University, it was found that these interventions had virtually no effect on problem gamblers and simply annoyed everyone. This is hardly surprising if one imagines what would be the effect on alcoholism of requiring barmen to give the equivalent information to their customers every half hour or so.

It is my belief that most of the interventions proposed in the new bill between the tenth draft and the eleventh and "Final" drafts in response to a submission by six members of Gamblers’ Anonymous in Gauteng, but not otherwise discussed, are of this type and will have similarly nugatory effects on problem gamblers. These include compulsory closing of casinos for six hours and effectively requiring customers to gamble with cash only. In general, these measures, though undoubtedly well-intentioned, are likely to inconvenience the majority of non-problem gamblers while having no benign effect on problem gamblers who will simply circumvent them by gambling at illegal venues including via the internet. In the same way, closing hours for pubs and bottle stores are not an effective way of combating alcoholism.

The other danger of adopting proposals of this kind is that they may give regulators, legislators and the general public the illusion that they are effectively addressing problem gambling issues when in fact the measures are purely symbolic. In my view, it would be better to rely on ensuring the availability of high quality treatment for compulsive gamblers who suffer from an impulse control disorder, and expanding the availability of various types of education about gambling to combat the problems of ignorance, especially amongst the poor. Such strategies have the advantage that they target actual and potential problem gamblers while not penalising the large majority of non-problem gamblers in ways which may reasonably be judged unfair, or at least disproportionate.

It is worth noting in this respect that the Government of New South Wales in July this year instituted a study to be carried out by the independent Pricing and Regulatory Authority into all the strategies employed to reduce the harm caused by problem gambling, including such measures as clocks in gaming areas, limits on credit and cheque cashing, warning signs, six- hour shutdown of machines, and restrictions on promotions. The government has set up this inquiry precisely because of concern from those who deliver support services to problem gamblers, and their families, as well prevention services, that these measures may be ineffective.

This is another reason for taking all specific problem gambling proposals of this detailed sort out of the legislation and making provision for them to be considered by regulatory authorities at the discretion of the Minister. Some of the proposals in the bill might not work and others which are not in the bill might prove effective such as the pre-setting of player limits as pioneered by Crown Casino in Melbourne. At all events, it will be unwise for the South African Government to commit to specific measures of the sort envisaged until the outcomes of the kind of research being conducted in Australia and North America into precisely these issues is known which will be within the next year.

A final issue which is usually raised in relation to problem gambling and the goal of protecting the vulnerable relates to children. Since age limits are set for participation in various gambling activities preventing minors from playing is a purely matter of enforcement. However, there are other issues which relate to the exposure of children to gambling. Some of these concern advertising and the importance of having rules which prohibit the advertising of gambling services so as to target or otherwise attract children. Other concerns relate to the presence of children at gambling venues, particularly casinos.

This is a more difficult issue. In general, casinos are regulated in two ways internationally: so as to forbid children from being present in any part of casinos as in most of Europe and so as to require or at least permit casinos to form part of integrated entertainment complexes which cater for families and children as in most of the rest of the English-speaking world. The main argument for banning children from casino premises is that this will prevent them from acquiring an unhealthy desire to gamble. The main argument for requiring casinos to be family friendly is that it is unhealthy to try to conceal adult activities like drinking, gambling and sex from children: rather they should learn how to approach all these activities responsibly.

I do not myself believe that allowing children to witness adults gambling has any significant impact in either encouraging them to, or discouraging them from, becoming problem gamblers. At all events, South Africa clearly adopted the second approach in the licensing of casinos by Provinces and it is difficult to see how this can be undone. An argument which I believe is a particularly strong one in the South African context is that if casinos do not have facilities for supervising and providing entertainment for children, there is a substantial risk that some parents will leave their children inadequately supervised and unoccupied at home or elsewhere.

Recommendations.

My recommendations relate mainly to strengthening the kind of work of the NRGP carries out, particularly in the area of education.

Along with other addiction treatment services around the world, and in South Africa, we in the NRGP experience considerable difficulty in getting poor people to make use of our help-line and treatment services, even though these are free. For this reason in particular we would like to strengthen our education programmes and expand them to include the provision of problem gambling education and resources to social workers, community leaders such as ministers and others in communities who exercise influence and authority such as senior citizens. I believe the following problems should be addressed, though through the regulatory, rather than the legislative process:

• Getting the message across about responsible gambling more effectively and especially via television
• Ensuring that understanding gambling issues is part of the life skills education nationally of teenagers along with sex and drugs education
• Providing problem gambling education to senior citizens both as an at risk group and as a group of people who have authority, respect and influence within communities
• Providing problem gambling education and training to social workers, health professionals and community leaders
• Providing training to industry personnel to internationally approved standards which will secure certification by the Government’s South African Qualifications Authority (SAQA).

In respect of funding and overseeing these activities as well as of continuing to fund and oversee the activities which are currently carried out by the NRGP, I recommend that:

• South Africa follow the model which the UK Parliament is about to write into its new Gambling Act. This acknowledges the desirability of having the industry fund education, training and research in order to minimise the harm caused by problem gambling on a voluntary basis, and recommends what it thinks would be an appropriate amount. However, the Minister reserves the power to impose a levy should the industry fail to raise adequate funds for addressing problem gambling issues on a voluntary basis

• The NRGP continue to be supervised by the South African Responsible Gambling Trust (SARGT) reporting through the South African Advisory Council on Responsible Gambling (SAACREG) to the Minister. However. I believe that the senior official responsible for gambling in the DTI or their nominee be ex officio a member of both the SARGT and of SAACREG.

Although I believe the main thrust in addressing problem gambling should be educational and preventative, there are some other measures which I believe it may be worth exploring in legislation. In particular, there may be merit in the idea that players should be required to show identification similar to a driver’s licence before entering gambling premises. Although this idea may be expected to encounter some resistance from the industry, a simple procedure, overseen by the NGB, whereby South Africans acquired a gambler’s identification card when they first enter a gambling venue would have the following advantages:

• It would ensure that minors could not enter any gambling premises
• It would solve the problem of how to police exclusion whether self-exclusion or exclusion by the courts
• The licence could be withdrawn by regulators if this was deemed appropriate in the case chronically reckless gamblers
• All first time gamblers could be supplied with appropriate NRGP and other literature informing them of how gambling works, what are the signs of excessive gambling and where help can be found.

No doubt the industry would object to this, and there may be genuine worries of a civil liberties sort. However, I believe it is worth exploring.

In addition, I believe that some of what is currently working less than satisfactorily has to do more with ensuring effective compliance than with the need for new regulations. In particular, I believe the following need to be better enforced:

• Easy availability of problem gambling collateral in all gambling venues
• Appropriate signage in venues about the dangers of excessive gambling

Given this, it might be appropriate in casinos at least to require the establishment of a responsible gambling office on the premises staffed by a person suitably qualified to:

• intervene with customers clearly identifiable as problem gamblers
• advise regulators on responsible gambling compliance issues
• offer on-the-spot counselling to customers who want it.

Finally, I believe it is regrettable that the National Lottery regulators have neither permitted the National Lottery company to participate in the work of the NRGP, nor encouraged them to develop a programme of their own, nor published research of their own, nor even required Uthingo to deliver on their bid commitments in respect of social responsibility.