Interactive Gambling Responsibility Code - LIAB | Latvijas ...
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Interactive Gambling Responsibility Code
Contents
1. Responsibility Code: necessity and objectives ....................................................... 5
2. Subjects of the Responsibility Code ........................................................................ 5
3. Basic principles of responsible gaming .................................................................. 7
4. State requirements for promoting responsible gaming ........................................ 8
5. Responsible gaming customer protection mechanisms ....................................... 9
6. A register of self-excluded players ....................................................................... 11
7. Age limit .................................................................................................................. 12
8. Sponsorship of sporting events ............................................................................. 12
9. Further actions and revision of the Code .............................................................. 13
2Introduction
The members of the Latvian Interactive Gambling Society (LIAB) are aware that
the sustainable existence of the interactive gambling industry is only possible if
the industry and the state jointly ensure the provision of services in a responsible
manner and environment.
The interactive gambling market in Latvia is regulated by the state; the normative
acts define the licensing procedure, operators’ services, responsibility before the
state institutions, including the mechanisms of the players’ protection. Organizers
of interactive gambling already comply with the regulations regarding the players’
right to set their own betting and turnover limits (Cabinet of Ministers Regulations
No. 715, 10.1., 10.2.) Also, the interactive gambling organizers fully restrict the
admission of the self-excluded players and individuals under 18 years of age.
The interactive gambling industry is growing and developing fast, with H2 Gambling
capital1 forecasting a turnover of 88.6 million in 2019, of which EUR 54.6 million
EUR is the turnover of gambling operators licensed in Latvia. The pace of industry
development is accelerated by changing societal habits – increased use of the internet
and smart devices, as well as by expanding entertainment options – gambling and
casino customers are changing habits and using online gambling platforms for
entertainment. It is also important that the turnover of the sector is growing due to
the changes in the regulations of the Lottery and Gambling Supervision Inspection
of the Republic of Latvia (IAUI), as more and more Latvian residents prefer Latvian-
licensed interactive gambling platforms for their entertainment, thus multiplying
the number of operators and potential growth of the sector. The pace of industry
development is one of the factors that make operators think about protecting their
customers’ rights and minimizing potential gambling-related risks.
1 https://h2gc.com
3The interactive gambling industry representatives welcome the efforts made by the
industry policymakers to protect players’ interests from the potential gambling-
related risks. The Interactive Gambling Industry Liability Code is a contract binding
all members of Latvian interactive gambling community. The Code is a self-
regulatory document of the industry conforming with the regulations set by the
national authorities.
Interactive gambling is a form of entertainment and leisure for most of the consumers.
Unfortunately, the risk of addiction cannot be ruled out, so the interactive gambling
industry has a duty to set a framework for business ethics. The purpose of this code
is to strengthen consumer protection and to help ensure that gambling habits of the
players do not develop from entertainment to addiction.
41. Responsibility Code: mission and goals
The goal of the Code is to strengthen social responsibility of the gambling industry
by providing systems and customer protection mechanisms going beyond the
requirements already imposed by the legislation and industry regulations to
increase consumer protection and develop gambling as a form of entertainment
without risk of addiction. The Code is intended as a set of criteria and minimum
industry requirements. Each particular interactive gambling operator may choose
to offer its customers more responsible gaming customer protection mechanisms
and activities than required by the Code. The purpose of the Code is to supplement
existing legislation and regulations.
2. Subjects of the Responsibility Code
The contracting parties intend to support the achievement of the objectives of the
Code by involving as many interactive gambling operators as possible. Developed by
LIAB members, the Code is binding on its members and, at the same time, invites any
operator providing interactive gambling services to join and follow the Code. Game
providers who comply with the Code have the right to refer to it on their websites.
The Code focuses on interactive gambling, players’ rights protection, and reduction
of industry risks. At the same time, the content of the Code is reaching out to a wider
audience – the authors of the Code believe that friends, family and other relatives
can also support those at risk when the perception of the industry changes and
knowledge of player protection mechanisms increases.
The Code is mandatory for the LIAB members, because sustainability in the
industry can only be achieved through the principles of responsible gambling and
by preventing the players from entering the potential risks created by the industry.
5Players. Safe and reasonable gambling environment and responsible behavior
of the operators is a prerequisite for the gaming industry to function as a secure
entertainment for the players where the customer’s interests come first. The Code’s
authors believe that maintaining such an environment is a significant contributing
factor to competitiveness against the service providers who neglect to provide
responsible gambling environment or, worse, even attempt to make profit using
questionable practices or gambling addiction.
Society: The number of people who opt for gambling entertainment in Latvia is
300,0002, which constitutes an essential part of society. Studies have shown that in
case of gambling addiction, one player can have a negative impact on 7-10 people3 ; a
large number of problem gamblers can negatively affect a significant part of society.
In this context, it is particularly important to inform the public about the potential
risks of gambling entertainment and the mechanisms of player protection available
to prevent them. The aim of LIAB is to strengthen public confidence in the industry
by providing true and transparent information about the industry operations and
presenting opportunities to protect players from the risks of problem gambling and
addiction.
Policymakers. Gambling is a legal form of business in the Republic of Latvia with
significant financial contributions to the economy and the state budget. But industry
is aware that given the risks of a gambling, the state must protect its citizens from
possible negative impact and provide assistance when it happens. Through its
expertise, knowledge and technological capabilities, the industry wants to become
a partner in players’ protection.
2 Putniņa A., Pokšāns A., Brants M. (2019) Pētījums par procesu atkarību (azartspēļu, sociālo mediju, datorspēļu atkarība) izplatību
Latvijas iedzīvotāju vidū un to ietekmējošiem riska faktoriem: Pētījuma gala ziņojums. Veselības ministrija, Rīga, 157 lpp.
3 Dowling N. A., (2014) The impact of gambling problems on families.
Australian Gambling Research Centre : Australian Institute of Family Studies, p 12
63. Basic principles of responsible gaming
Responsible gambling environment means that the players are provided with
customer protection mechanisms preventing them from developing problematic
gambling habits before and during the game. It also means that in case of fears
that gambling habits become uncontrollable or addictive, mechanisms are provided
to deal with the situation. Responsible operators take care of the players before
and during the entertainment, not just when a gamble-related problem game or
addiction occur.
Interactive gambling operators must be socially responsible and pay particular
attention to the protection of children, youngsters and socially vulnerable individuals
in order to reduce the risk of addiction.
Educating players, the public and policymakers about the potential risks4 of gambling,
self-limiting customer protection mechanisms and other tools is substantial in
preventing the potential risks.
The services provided by the interactive gambling operators and the communication
with the customers must not give the false impression that gambling can serve as a
source of income or other profit, and can be more than entertainment. Information
on operators’ websites must not:
- encourage more spending on gambling that could potentially cause
financial, social or emotional harm to customers;
- give an impression that gambling is a way of running away from personal,
professional or financial problems, or a tool to solving personal, professional
or financial problems;
- give an impression that gambling can be an alternative to employment,
financial profit or financial investment;
- contain false information about the player’s chances of winning;
4 Remote Gambling research: Interim Report on Phase I. (2016) PricewaterhouseCoopers LLP, p 15
7- contain information that correlates with the player’s self-esteem – give the
impression that self-esteem or the appreciation of the others may improve
by participating in gambling;
- target children and young people under 18;
- unjustifiably use popular personalities as an example showing successful
gambling.
4. State requirements for promoting responsible
gambling
Already now, the Gambling and Lotteries Law (AIL) and the Cabinet of Ministers’
regulations have set a number of requirements aimed at ensuring the protection of
the public interest and the rights of players, as well as reducing the potential risks
of gambling:
- a ban on gambling for persons under the age of 185;
- a ban on any loans or credits to players provided by the gambling operator6;
- prohibition of gambling advertising7;
- a ban on participating in gambling for free, as a gift, a prize or a compensation
for the purchase of goods or services8;
- player registration and identity verification procedures, as well as minimum
requirements to prevent players dependent on interactive gambling or
interactive lotteries from continuing to participate in gambling and lotteries9;
- obligation for each interactive gambling, including betting and totalizer,
operator to create a register of gamblers, with the aim to identify players,
prevent minors from participating, and prevent addicted players from
further participation in interactive gambling or interactive lotteries10;
5 Azartspēļu un izložu likuma (AIL) 41. panta pirmās daļas 6. punkts
6 AIL 41. panta trešā daļa
7 AIL 41. panta piektā daļa
8 AIL 41. panta sestā daļa
9 AIL 54. pants un AIL 80. panta pirmās daļas 1. punkts
10 AIL 54.1 panta pirmā daļa un 79.1 panta pirmā daļa
8- minimum requirements to prevent persons dependent on interactive
lotteries and interactive gambling from further participation in gambling
and the right of individuals to be denied access to a gambling or lottery
sites11;
- the restriction prohibiting players to register for a game and start a game
before setting a maximum bet per game or a bet amount for a 24 hour
period. If a player wishes to increase the maximum daily rate, the organizer
shall provide it only on the seventh day after receiving such a request. These
measures ensure that players are rush-free and reasonable as possible12.
The foregoing list of statutory requirements is not final and in no way exempts the
interactive gambling and lotteries operators from complying with other normative
regulations and requirements.
5. Responsible gaming customer protection
mechanisms
Scientific research13 into the causes of the gambling-related problems shows that
they can be different for different people. Risks can be significantly influenced by
age, gender, education, income level, availability, design and rules of games, as
well as other social, economic and personal factors. This means that customer
protection mechanisms must be as diverse as possible, as every gambler has
its own risk profile, and might need to choose specific and personalized defense
mechanisms. Recognizing the diversity of these risks and taking care of the players,
LIAB members already offer a wider range of customer protection mechanisms
than required by law and continue to work on new technological solutions to ensure
player protection.
11 Ministru kabineta 2017. gada 12. maija noteikumu Nr. 715 “Interaktīvo azartspēļu
un interaktīvo izložu spēlētāju reģistrācijas un identitātes pārbaudes kārtība” 5., 6.punkts
12 Ministru kabineta noteikumu Nr. 715 10., 11. un 13. punkts
13 Dowling N. A., Merkouris S. S., Greenwooda C. J., Oldenhofa E., Toumbouroua J. W., Youssefa G. J. (2017) Early risk and
protective factors for problem gambling: A systematic review and meta-analysis of longitudinal studies. Elsevier Ltd, pp 109–124
9Technology and its affordability ensure the possibility to adhere to the principles of
the Code. The customer protection mechanisms must be available to the players,
should be easily found on operators’ websites, and must be comprehensible and
easy to use, thus encouraging players to apply to them.
All the operators whose representatives have signed this Code are required to
provide their customers with the following Customer Protection Mechanisms none
later than June 30, 2020:
- self-assessment questionnaire;
- possibility to set spending/loss limit per day/week/month;
- an option to close the account permanently;
- information on where to go for help;
- access to the gamblers’ playing time and money transfer history, which
allows an assessment of potential game risks;
- customer service: the player can contact the operator by calling or writing
on the operator-created correspondence site (chat);
- after the registration, the new clients are informed of the opportunities
mentioned above;
- employee training: if in communication with the player, customer support
service suspects problematic gaming habits, the situation is analyzed and
ended with a decision whether to close or not the customer’s account – at
the initiative of the game operator, not the customer;
- proactive distribution of information for the players.
Customer protection mechanisms, not required by the Code, but already offered by
some LIAB members:
– an option to “freeze” the account;
– an option to close access to certain game groups (betting, casino, poker
etc.);
10– an option to set a time reminder for the games with technical settings
allowing the installation and presentation of such reminders during the
game in content controlled by operators;
– responsible game notifications (as a mandatory requirement after the
introduction of the register);
– chat content monitoring and responding to key words such as “problems”,
“addiction”, etc.
– Radar software monitoring players’ average spendings/payout changes
and game habits, and signaling the increased risk of addiction, thereby
providing a personalized approach to the customer.
6. The Registry of self-excluded players
One of the mechanisms helping the state and the operators protect the players from
potential risks is the self-excluding option available both on interactive gambling
operator platforms (account freeze, account deletion) and as state-created and
maintained self-excluded player register. There are registers in the member states
of the European Union offering the players an option of withdrawing from gambling,
ranging from a 24-hour period to an unlimited time14. Already now, players in Latvia
have an opportunity to protect themselves by writing an application to the IAUI asking
the licensed Latvian operators to restrict the applicant from gambling.
Already now, the players in Latvia have an opportunity to protect themselves by
writing an application to the IAUI and requesting to be banned by the Latvian licensed
operators.
It is expected that beginning January 1, 2020, Latvia will have a single united register
of self-excluded players maintained by IAUI and obligatory for all gambling operators
licensed in Latvia. After the publication of a single register of self-excluded players
on LIAB members’ sites, the previously received self-excluding applications will
remain valid. All self-excluding accounts will be closed by 2021. After 2021, a specific
account may be opened upon application. In addition, the barring will be removed
only on the seventh day after the application was submitted.
14 Blake M., Pue J., Mollidor C. (2019) Measuring gambling-related harms among children and young
people: A Framework for Action. Ipsos MORI Social Research Institute, London, p. 36
117. Age limitations
All LIAB members comply with the defined age limitations ensuring that children
and youngsters are denied access to interactive gambling. The studies15 show that
age limitations excluding children and adolescents from entering gambling and
lottery are very important in reducing the potential risks of gambling addiction when
they become adults. The risks to which children and youngsters are exposed by
allowing them to participate in gambling and lotteries are divided into the following
categories:
- financial: understanding of family comfort level, financial well-being;
attitude and understanding of money and earning money;
- child and adolescent development risks: education, social and emotional
development;
- relationship risks: understanding relationships with friends and family,
behavior within the relationships;
- health risks: physical, mental, psychological and emotional well-being16.
8. Sports events sponsorship
Responsible gaming principles and Responsibility Code information are essential
for interactive gamblers, the public, and the policy makers. It is important that the
principles contained in the Code are followed and applied by the highest possible
number of participating organizations. It is the responsibility of LIAB members,
upon entering cooperation with sports organizations, to inform them about the Code
and to invite to become acquainted with the content of it.
15 Dowling N. A., Merkouris S. S., Greenwooda C. J., Oldenhofa E., Toumbouroua J. W., Youssefa G. J.
(2017) Early risk and protective factors for problem gambling: A systematic review and meta-analysis of
longitudinal studies. Elsevier Ltd, pp 109–124
16 Blake M., Pue J., Mollidor C. (2019) Measuring gambling-related harms among children and young
people: A Framework for Action. Ipsos MORI Social Research Institute, London, p. 13
129. Further actions and revision of the Code
In the future, LIAB sees the Code as a changing and developing document promoting
a responsible game culture and reducing gambling addiction using such principles
and tools as:
– human-centered, individual approach; in cases of suspected gamble-related
problems, contacting the player, explaining the potential consequences and
the importance of responsible gambling, providing information on where to
address for support;
– machine learning, or algorithms, that monitor player behavior, automatically
detect changes in game habits and react when a gambling problem is
detected.
The authors of the Code intend to establish the LIAB Ethics Commission as soon
as possible, in order to investigate complaints regarding the violations of the Code
involving the contracting parties, as well as develop on additions to the Code. The
LIAB will invite the Ministry of Finance and the Lottery and Gambling Supervision
Inspection to nominate their representatives to serve on the Ethics Commission.
The Code is to be reviewed and updated at least once a year. In dialogue with the
legislators and the state regulatory authorities, the contracting parties shall carry
out the evaluation of compliance with the requirements of the Code and coordination
of updated versions of the Code. Each Contracting Party is free to set additional or
alternative requirements for its gaming offerings and to inform the other Contracting
Parties accordingly.
13The Responsibility Code enters into force in 7th of October 2019.
Signed by:
Streiķis Rihards, Pafbet Latvija, Head of Marketing
Ukass Armands, Betsafe Latvija, Chair of the Board
Ustinovs Georgijs, Optibet, Member of the Board,
Enlabs group Financial Director
Trēgers Jānis, 11.lv, Chair of the Board
Zuzāns Jānis, Alfor, Chair of the Board
14About LIAB
Latvian Interactive Gambling Society is a non-governmental organization uniting
representatives of the Latvian interactive gambling industry in order to provide a
unified industry opinion to the public administration sector, maintain constructive
communication with the legislature in the development of regulatory frameworks,
and represent the interests of its members.
The goals of LIAB are:
- introduce standards promoting a fair and socially responsible environment
for the interactive gambling industry;
- in cooperation with public administrations and the legislature, improve
the regulatory framework for the interactive gambling sector, aiming to
reduce illegal sector and promote equal competition for all the members;
- to contribute to the fight against illegal interactive gambling thus
reducing the black-market economy and protecting Latvian citizens from
aggressive and irresponsible commercial practices.
Members of LIAB: Betsafe, Optibet, Pafbet, Viensviens.lv, Alfor.
info@liab.lv, www.liab.lv
15October 2019
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