inclusion of a statutory levy within the Gambling White Paper is a commitment
that is very precious and comes with great responsibility, both
for the commissioner/s who will distribute the funds and for the organisations
who access the funds to provide their services. The United Kingdom’s eco-system
to reduce gambling harms is, in the main, world-class. I hope the significant
uplift in funding arising from the statutory levy is a fundamental catalyst for
innovation as to how funds are distributed by the commissioner/s with the approach
of supporting organisations with core sustainable funding first, then
innovation funding second.
This paper shares some of my own learning and observations on funding for services and research, having worked predominantly in the third sector for over thirty years, of which ten years have been spent in the gaming space. The third sector is incredibly special, bursting with talent, entrepreneurship and a real sense of purpose. It is also a sector which has to demonstrate the Public Benefit test at the point an organisation is incorporated and has to also evidence value for money and social impact. These qualities alone I would hope mean the third sector will continue to play its part in reducing gambling harms in the United Kingdom, alongside the NHS and other agencies in a coordinated, positive and solutions focus manner; free of any vested interests or showboating.
I have no doubt that all the organisations on the current Gambling Commission RET list will be able to find commonality, understanding, and unity and contribute purposeful insight to the upcoming consultations. Building upon the experience of these organisations of what works will no doubt accelerate a new collectively owned national strategy to reduce gambling harms and that is why we should recognise, support and celebrate our world-class eco-system. The current Gambling Commission RET list already draws on sharing global expertise, insight and services and is a real asset from the previous national strategy.
Looking at the current transition period that we are now in, organisations that are part of the National Gambling Support Network (NGSN) and therefore funded by GambleAware, principally for treatment have a structure to contribute as a collective voice to the various consultations and stakeholders. Those organisations who are not part of the NGSN, I sense do need a collective voice and strong leadership to define and establish the areas of commonality to also present to various consultations and stakeholders. I am particularly thinking of research, prevention and start-up organisations here. Having a broad church of collective voices is more important now than ever.
This paper aims to share two specific foundations on which a statutory levy may be initially organised and funding distributed. It has been written through the lens of (i) delivering social impact in a timely manner, ensuring value for money and transparency with a two-step approach to the production of any new strategy and (ii) what organisations might need who are currently in this space (i.e. those on the Gambling Commissions RET List) to contribute to the development of this strategy during the first year.
Outcome one: An initial one-year enabling plan by bringing the support ecosystem together.
Outcome two:A comprehensive three-year strategy to reduce gambling harms in the United Kingdom
It takes time to develop a good, insightful strategy but equally, the task also creates a wonderful opportunity to bring the sector together. To my knowledge, the rich and diverse range of organisations which are currently on the Gambling Commissions RET list haven’t come together as a whole to look at strategy and coordination, might this be a useful starting point.
I suspect any strategy would take approximately twelve months to create and so might an initial one-year enabling plan provide a useful framework to build a level of consensus among everybody in the current support eco-system (i.e. particularly bringing together the NGSN and non-NGSN organisations), develop shared understanding and trust among organisations and finally share insight into what will be a full collectively owned national strategy to reduce gambling harms in the United Kingdom.
In addition to the above particularly non-NGSN organisations might benefit from a transition plan and the leadership to establish themselves as a collective and credible voice. Funding for these organisations remains a challenge and expecting operators to step in with funding solves an immediate funding challenge, but some non-NGSN organisations need more than an immediate sticking plaster which funding provides.
Developing a collectively own, fully costed national strategy to reduce gambling harms and one where progress can be measured in a straightforward manner will require some intensive work to be undertaken if it is to be delivered in a timely manner. Writing the actual strategy is in many ways the easy part; putting a budget to it, making it easily measurable and collating the evidence will be the trickier challenge. Organisations contributing need to be compensated for their time and if we are to develop this as an inclusive process, there should be a level of parity among all organisations on the Gambling Commission RET list to enable this to happen.
Therefore a programme of quarterly in-person consultations and strategy days might be developed to enable organisations to come together for all the advantages above. There are currently thirty organisations only on the Gambling Commission RET list and so this will be an ideal size for such work to be completed. There are some noticeable organisations in our sector that are not on the Gambling Commission RET list and they should also be invited to ensure an inclusive process and as a way to build trust.
To ensure these meetings have structure and purpose, a one-year enabling or transition plan should be created. This should set out the process and deliverables to create a new national strategy within a twelve-month period. A new strategy is fundamental, otherwise, we risk not grasping the opportunities afforded by the precious statutory levy for absolute coordination, reporting progress, value for money and evaluation.
Initial funding distribution and training
Outcome one: Initial core funding to be granted to organisations on the Gambling Commission RET list
Outcome two: Leaders with Lived-Experience to be offered training to degree or masters level.
There are to my mind two challenges with the current funding arrangements for those on the Gambling Commissions RET list; one is how funding is currently collected and distributed to organisations in the support sector; the second is around core funding more generally for the wider third sector. It should be noted that being on the Gambling Commission RET list doesn’t explicitly guarantee funding, however, it is a RET list of two halves and does the statutory levy again present an opportunity to innovate and in many ways recognise the contribution made by all organisations on the Gambling Commissions RET list and their contribution to our sector.
With the period of upcoming remote consultations (and potential in person consultations), we do have the means to compensate organisations for contributing by funding a percentage of their core costs as a one-off in this period of transition. This would be a huge enabler, particularly for smaller and non-HGSN funded organisations to give their insight and expertise (as appose to these organisations consistently living month-by-month where income may be the number one priority). There is plenty of funding in the eco-system to support such an approach. There would be many ways to consider this distribution of this one-off funding, one way might be:
Organisations with a turnover under £500k in 2021/2022: Review the last set of filed accounts with Companies House or the Charity Commission and make a core funding allocation equivalent 50% of their most recent turnover filing. For example, Organisation A turned over £185,000 in their latest accounts. Make a core contribution of £92,500
Organisations with a turnover greater than £501K 2021/2022: Review the last set of filed accounts with Companies House or the Charity Commission and make a core funding allocation equivalent to 25% of their most recent turnover filing. Only work which contributes to the UK’s national strategy to reduce gambling harms would be included. For example, Organisation B turned over £2,300,000 in their latest accounts. Make a core contribution of £575,000.
Start-up organisations: A couple of organisations on the Gambling Commission RET list would not have filed their first-year accounts. These would be looked at on a case-by-case basics with a view to offering a contribution, of no greater than 50% of income as per their latest bank statements or similar.
Again to ensure inclusivity, this core funding would apply to all organisations on the Gambling Commissions RET list.
In addition to this core funding, as a sector, we have encouraged people with the lived-experience of gambling harms to step forward and contribute. Some have chosen to contribute by establishing organisations, which have since been added to the Gambling Commissions RET List. For many of these organisations accessing funding is incredibly difficult due to a range of factors. I also sense that many of these people are first-time Chief Executives, so while they may have passion and energy in abundance, that unfortunately isn’t enough to develop and lead a successful organisation in most cases. Therefore distributing an element of core funding as shown above, with the expectation of external training, might enable organisations, particularly those led by leaders with lived-experience to (i) contribute to all consultations, while their service delivery continues via a core funding contribution (ii) offer all leaders with lived experience who lead organisations the opportunity to study for a Level 6 (degree) or Level 7 (Masters) Apprenticeship in Senior Leadership. This training could be fully funded via an apprenticeship levy transfer.
There is no doubt the statutory levy will bring a host of new organisations into this space and the procurement and tendering for services in the future will be incredibly competitive. Both of these are strong positives for a new national strategy to reduce gambling harms and absolutely should be encouraged. However in this transition period finding a way to recognise, celebrate and support the current eco-system and train the lived-experience leaders of the future would be another welcome gesture and a positive bringing to the end the current arrangements. It also gives leaders with lived experience the best chance to succeed in a new and highly competitive statutory funding environment. I am grateful to Mark Conway and others who have contributed their insight to this paper and we hope this provides a starting point for a conversation.
Lee WillowsMay 2023
About the author:Lee Willows is a social entrepreneur having spent thirty-two years in the Third Sector leading the work of national charities. He is the founder of Young Gamers & Gambling Education Trust and ESG Gaming where he is using his lived experience of gambling harms to deliver social impact. Lee also works for Virgin StartUp, where he coaches and mentors entrepreneurs supported by Virgin and is currently undertaking an MBA, reading Senior Leadership in safer gaming and web3.