22Oct

Betting and Gaming Council Announces Game Design Code of Conduct

22nd October 2020 Jessica Wilson 339

On 25 September 2020, the Betting and Gaming Council (“BGC”) announced the new Game Design Code of Conduct (the “Code”). The Code is a product of the industry’s Safer Products Working Group which was formed in January 2020 and tasked with pursuing the opportunity to reduce gambling harm through game and product design.

Compliance with the Code is to be undertaken by BGC members, including where operators use non-BGC game suppliers.

The Code applies to online slot products and is intended to be a “living document, evolving as the research base and understanding around game design continues to develop”. The Code sets out 14 principles to show a commitment to “transparency, player education, innovation and research with the overarching aim of enhancing player safety” which can be categorised into the following areas:

Game Characteristics:	Working with academics, regulators, consumers, individuals with lived experience of gambling related harm and other technical experts to identify and agree on features that are correlated to greater player risk.
Informed Player Choice:	Empowering customers to play more safely through the provision of clearer information on product and game rules, including mathematical properties such as risk, the chances of winning and optimal strategies.
Enhancing Control Innovation:	Improvements in safer gambling tools that help players both monitor and control their gambling, including spend, loss, win and time-based measures.
Governance and Continuous Improvements:	Process for reviewing and updating any Code of Conduct, in addition to transparency, disclosure and independent evaluation.

The Code is divided into two phases:

Phase 1

This phase introduces four standards of game design. The requirements are in line with the Gambling Commission’s recent consultation on online slots game design which aims to make these standards applicable to the whole industry. The Code of Conduct requires BGC members to have the measures in place by 30 September 2020, making BGC members “amongst the first to commit to these standards”.

The four standards are as follows:

1. Minimum game cycle speed of 2.5 seconds

A game cycle starts when a player has paid for an initial wager and depresses the ‘start’ or ‘spin’ button or takes equivalent action to initiate the game and ends when all money or money’s worth staked or won during the game has been either lost or delivered to, or made available for collection by the player and the start button or equivalent becomes available to initiate the next game. Where auto play or auto start is permitted then a game cycle is measured from the point at which the game is initiated by the system (equivalent to the player depressing the start button) to the point at which it is able to automatically start the next game.

2. Removal of turbo play

Turbo play or equivalent features will be not be allowed. Such features enable the player to speed-up the base game cycle speed of the game.

3. Removal of base game slam stops

Slam stops or equivalent features will not be allowed within the base game. This is the ability for the customer to interact with the base game to end it before it has naturally concluded e.g., by hitting or pressing a button whether online or on a physical machine. This includes promotional free wagers paid for by the operator.

4. Removal of multi-slot play within a single gaming client

Functionality that allow players to place multiple, separate stakes on multiple slots games within a single gaming client will not be allowed.

Phase 2

Phase 2 requires BGC members to implement additional measures for new games by 31 January 2021 to “enhance transparency and add friction for players”.

1. Wins below the stake size

Total wins below the stake will be informative and will be differentiated from wins that are equal to or greater than the stake. Specifically:

The win amount will be displayed
- The win line is displayed long enough for player to understand the impact of the bet (in line with existing RTS 7E)
- A brief sound can be used to make the player aware of the result (the return of funds to wallet)

In contrast, total wins equal to or greater than the stake may be celebratory and allow the following elements:

The win amount can be displayed in a differentiating manner e.g., the win display could be in a text size that is greater and could utilise dynamic win animations, for example coin showers
- The win line can be displayed with additional animation permitted
- Celebratory sound effects can be used.

2. Bonus game notifications

Bonus games outside the base game will not be automatically triggered without a customer intervention, e.g., clicking a button to acknowledge that a bonus game has been won and can now be entered. In addition, after the end of a bonus game, the player will receive a notification informing them the bonus game has finished before re-entering the base game. If Auto-play is used during the bonus game, it will automatically stop before re-entering the base game. In the exceptional case that a bonus game is not triggered before the platform would normally time out, the operator has the right to clear down the game with any winnings being added to the player’s balance.

The implementation timeframe of the following two measures will be agreed in the coming months:

1. Access to safer gambling information

While a player is playing a game, the display will include a link to safer gambling information that will be available to view within a prominent place on the gaming client. This will display a safer gambling icon and messaging and contain links to the customer account pages of the operator, with quick links to all limit setting functionality (e.g., deposit, loss, time, timeouts, and self-exclusion).

2. Mandatory player interaction

A mandatory player interaction will be initiated every 60 minutes or at the conclusion of the subsequent game cycle. This will require the customer to acknowledge the message.

The BGC has stated that it may recommend to the Gambling Commission that the Phase 2 measures are adopted as part of the Gambling Commission Remote Technical Standards.

Innovation and Testing Lab

The BGC have created a work programme for the BGC Innovation and Testing Lab to use an evidence-based approach to development of the Code and to inform future changes. The BGC intends to be “transparent in the reporting of findings, methodology and data”.

The Innovation and Testing lab will be focussing on the following projects:

Game labelling – work on creating a consistent safer gambling icon and a common game labelling scheme for key features such as volatility and persistence
Increased staking – work to assess the prevalence of increased staking in slots sessions, whether this behaviours correlates to a risk of harm and how safer gambling messaging can be incorporated to enhance player safety
Auto-play – work on the relationship between auto-play and staking behaviour and whether any risk mitigation is required
Display of net position and elapsed time – work on providing players with quick access to information on their net spend and time elapsed

BGC’s Game Design Code of Conduct has introduced significant changes to the design and functionality of online slots games. The industry should expect to see more changes due to ongoing work in the industry and the awaited Gambling Commission response to its consultation on online slots which closed on 3 September 2020. See our blog on 10 July 2020 for further details. BGC members, and those supplying BGC members, are reminded of the Phase 1 measures were implemented on 30 September 2020.

10Jul

Gambling Commission Consultation on Online Slots Game Design and Reverse Withdrawals

10th July 2020 Bahar Alaeddini 376

On 9 July 2020, the Gambling Commission announced a consultation on online slots game design and reverse withdrawals. The former follows the work of the Safer Product Working Group, which we wrote about in our blog on 2 April 2020, and the draft Betting and Gaming Council industry code, which is due to be published in September 2020.

In April 2020, the industry and Safer Product Working Group agreed to:

A minimum spin speed of 2.5 seconds on all slots.
Removal of game features which may encourage intensive play such as slam stops and turbo buttons.
Removal of split-screen slots which have been associated with potential loss of control.
A more detailed work plan which will include in-game messaging and the creation of a Betting and Gaming Council Testing Lab to investigate other game features.
Publication of the final industry code in September 2020.

Reason for the consultation

In its introduction to the consultation, the Gambling Commission explains:

“Our interest in online slots is because it is the largest online gambling product by Gross Gambling Yield (GGY) – played by relatively few but with a high average spend. Structurally it has a number of features which can combine to significantly increase intensity of play. This means it poses a relatively high risk, reflected in its associated problem and moderate-risk gambling rates.”

Slots are the largest online gambling product in Great Britain by GGY. 1.2% of adults participate in online slots and GGY from online slots has grown by approximately 50% since November 2014. The Gambling Commission believes “this implies a sharp increase in average spend per consumer”.

In a section titled Why are we consulting the Gambling Commission explains the industry proposals are insufficient and the “consultation goes further to keep slots players safe in a number of other additional areas”. It goes on to add that “the strength in the proposals will come from effective compliance by operators… the industry can expect what has described as “relentless escalation” to continue when see consumers not being protected from harm.”

The Gambling Commission is particularly concerned about the accelerating intensity of slot games which aim to increase the time and spend of players. The stated aim of the consultation is to make play of online slots safer by adopting an industry-wide and consistent approach, not just an industry code for Betting and Gaming Council members, and going further by implementing additional measures above the draft industry code.

It acknowledges these are not the only ways to improve player protection and invites views on other aspects of game design to consider for future changes. It refers to its interim Experts by Experience Group, which has suggested stake levels and different product labels to help customers understand potential risk better. The Gambling Commission’s Digital Advisory Panel highlighted the need for friction to reduce the likelihood of players placing impulsive bets.

New controls aimed at reducing potential harm of online slots

The consultation proposes to amend the Remote gambling and software technical standards (RTS) as follows:

Insert a high-level definition of slots: “casino games of a reel-based type (includes games that have non-traditional reels)”.
Add a new requirement RTS 14C: “The gambling system must prevent multiple slots games from being played by a single account at the same time.”
Add a new requirement RTS 14D: “It must be a minimum of 2.5 seconds from the time a game is started until a player can commence the next game cycle. It must always be necessary to release and then depress the ‘start button’ or take equivalent action to commence a game cycle.”
Add a new requirement RTS 14E: “The gambling system must not permit a customer to reduce the time until the result is presented.”
Add a new requirement RTS 8C: “The gambling system must require a customer to commit to each game cycle individually. Providing autoplay for slots is not permitted.”
Add a new requirement RTS 14F: “The gambling system must not celebrate a return which is less than or equal to the total amount staked.”
Add a new requirement RTS 2E: “All gaming sessions must clearly display the net position, in the currency of their account or product (e.g. pounds sterling, dollar, Euro) since the session started.”

Testing

Licensees must satisfy themselves that they are offering compliant games. Where they are not sure, any existing game will require third party retesting.

All new games published after the implementation date for these new requirements will need to be tested otherwise, they will need to be removed until retesting has been completed.

Although slots are casino games (and therefore not separately licensed), the Gambling Commission plans to stipulate testing reports to declare whether the game is identified as slots.

Reverse withdrawals

On 14 May 2020 we wrote about the Gambling Commission’s new “additional formal guidance” for online operators in response to “evidence that shows some gamblers may be at greater risk of harm during lockdown”. This included a prohibition on offering reverse withdrawals until further notice.

At the time, we questioned the reliability of the data used by the Gambling Commission because it showed a decrease in reverse withdrawals. It was clear to us that this measure was not based on the data published by the Gambling Commission, and we questioned whether it was necessary and proportionate. The Gambling Commission, supported by research, already considered reverse withdrawals to be a flag for potential gambling harms; however, action to tackle this through an industry consultation would have been more appropriate than a strict measure introduced under the guise of guidance. The Gambling Commission has now issued the consultation to make the change permanent, but without the evidence to support it.

This consultation will make it a permanent prohibition by adding a new requirement RTS 14B: “Consumers must not be given the option to cancel their withdrawal request.” Operators will be required to make this withdrawal process as “frictionless as possible”.

Respond to the consultation

The consultation closes on 3 September 2020.