It is long past time I posted an update on this issue and I will offer an apology for this being very late. There have been a number of other issues that have pulled my attention away from this matter over the last couple of months, but the blunt truth is that I have been putting this off as I consider our efforts on this front an unmitigated failure.
Cutting to the chase, the situation is that of the programs we contacted about this issue the majority either offered no response or what we feel is an inadequate response. Large swathes of the industry are taking the position that as long as the identified affiliate stops engaging in these marketing strategies, everything is a-o-k.
We have heard a lot of self-serving platitudes about redemption and rehabilitating wayward affiliates by showing them the right way to go about marketing. These could be laudable positions if it were not for two factors:
i) The site in question is a big player in the industry. The motivation behind wanting to rehabilitate this site, when no-one has questioned trying to rehabilitate any of the other smaller partners, is highly dubious.
ii) These affiliates engaged a clearly thought through strategy to target and exploit vulnerable persons. Malicious intent is not best dealt with via “rehabilitation”, nor would we ordinarily choose to give someone identified intentionally exploiting vulnerability access to the same vulnerable people again after “correcting their error”.
If a teacher is identified having an inappropriate relationship with a pupil, they do not get to teach again.
If a doctor is found touching patients in an inappropriate fashion, they are not allowed to practice further.
If a care worker if found to be financially exploiting the people they are employed to help they don’t get access to vulnerable people again.
But the attitude of this industry is that when a business partner is identified actively targeting gambling addicts, as long as they stop the identified actions there is no further reason for concern. In fact, they are to be considered a valued partner.
As long as the affiliate stops engaging in these practices, why should there be any further repercussions?
This is the question that has been asked again and again by those programs that would like to continue working with this affiliate. Their practices are compliant now so what is the problem?
The problem is one of cause and effect. By simply requiring the affiliate to stop ‘doing the bad thing’, it sets a precedent. That precedent is that you can do the bad thing and as long as you stop when you are caught there are no negative consequences for you. Drunk driving? No problem – when the police flag you over simply stop driving and wait till you sober up and everything is ok. Embezzling money from your employer? I am sure when they find out they will be happy for you to keep your job (and the money you took) as long as you stop. Cheating on your wife? Again there should be no negative consequences for you as long as you stop when she finds out.
In effect, this position makes the statement that every affiliate can now take a shot at this or a similar marketing strategy, cash in for a time, and simply stop when the problem practice is identified. All under the guise of shepherding wayward affiliates back to a position of compliance.
Open season has been declared on gambling addicts.
Money Talks
Sadly this issue has come to a head at the same time as other more fundamental problems with ThePOGG’s business structure have become apparent. Over the last couple of years we have invested a very significant amount of our revenue in the development of BetBlocker. This is money that was diverted from other activities that ensure that the business continues to receive traffic from various sources, but primarily search engines. The lack of investment in ThePOGG has resulted in a drop in search engine rankings, and consequently traffic, that started to become apparent in June of this year.
The relevance of weaker rankings to this conversation is one of influence. With weaker rankings for important search terms, operators are less inclined to worry what we have to say. My personal opinion on this is that it has directly impacted our ability to influence operators with regard to this matter. We have less clout than we did a few years ago. Ironically, as a group that has taken direct action to help problem gamblers we are now finding a by-product of our efforts is a weakened ability to affect change.
And that leaves us at an impasse. The simple truth is that if we look at the array of programs still listed on this site – remembering to take into account regional variations – the sheer number of programs precludes us from being able to take any meaningful action. And this does not take into account the ongoing monitoring involved in the game of whack-a-mole that has occurred in the last few months with programs that say they have terminated their relationship with the affiliate but keep appearing back in the listings.
To my mind, the response to this issue should have been clear and self-evident to every operator in the business – if you find one of your partners exploiting gambling addicts in this manner, you stop working with them. No ifs, no buts, this was not a ‘mistake’ – you terminate the relationship and put as much distance as you can between these activities and your brand. That however counted on the industry seeing past their wallets to make decisions based on principals - a clear misjudgement on my part.
Had the industry taken a strong and consistent stance on this issue word would quickly have spread within the industry and this would have been a non-issue. The offending parties would quickly have found themselves without respectable partners to work with.
Rather than finding a cooperative industry that saw the inherent dangers of allowing this practice to go unchallenged what we actually got back from many programs was disinterest or, more concerningly, active resistance to anything that would result in a loss of revenue.
If players were ever to question whether the online gambling industry was genuinely interested in protecting problem gamblers this issue provides solid grounds for contesting that the bottom line will trump any faux social concern for large swathes of the industry.
The above said it should still be noted that the programs previously mentioned did take action on this issue, showing that the apparent apathy for this issue was not by any means universal. These programs should be applauded for having the courage to stick by moral principles, demonstrating that for some Responsible Gambling means more than empty promises.
Setting things right
Another interesting interaction during this pantomime of denials of responsibility has purportedly been with the affiliate in question. One of the operators in question did look to engage a type of mediation between ourselves and the affiliate.
I need to be clear at this juncture that we never interacted with the affiliate directly, so everything said about this is what we were told was said. We cannot speak to the veracity of the communications between the operator and the affiliate.
The operator spoke to the affiliate who they report claims that they “did not make a cent out of the article in question, as it did not rank high and for that reason never got organic traffic”. Alongside this we were told that they offered to make a donation of £1.5k to a UK based Responsible Gambling charity to redress this issue. This is certainly an interesting claim and offer combo and if it could be verified via data may have influenced our position on this issue.
Sadly it was not to be.
The claim of zero organic traffic was not one that the affiliate were prepared to back-up with Google Analytics data. It also fails to take into account traffic landing on this page from other sources. Saying that the only manner in which vulnerable persons could have been damaged by this content is via organic search traffic ignores the high traffic nature of the site in general and the fact that this page is a page that was prominently linked up in the main menu of their site. Traffic landing anywhere on the site from any source was never more than one click away from the offending content.
And the offer of a donation was not unqualified either. The donation was to be made on the basis that we remove mention of this affiliate from our previous article on this issue (effectively expunging history for the affiliate) and inform those programs that had terminated their relationships with this affiliate that the affiliate had “taken the responsible actions to be a compliant guide going forward.”
So we have an argument that fail basic scrutiny, that even were we to accept it as reasonable could not be qualified as accurate with any data, and an offer of a charitable donation that requires us to take actions to restore beneficial financial relationships for the affiliate that would likely be worth more than the donation. Given the quantifiers placed throughout this offer it is hard to view it as anything less than cynical.
All of the above said about the conditions on the donation I do need to be clear that we would have happily agreed to this arrangement if the data could have been verified. If minimal UK traffic could be shown to ever have landed on that page then the likelihood of harm to vulnerable players would have likewise been minimal.
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All in all this is one of the saddest episodes I’ve seen in the gambling industry and I think it will be far from the last of this nature given the lack of any actual consequences for the culprits.
Some days it is very hard to muster any positivity about this industry.
TP
