Dr. Helen McAvoy:

The Institute of Public Health is an all-island organisation which is jointly funded by the Departments of Health in Ireland and Northern Ireland. As individuals, and on behalf of the institute, we declare no conflict of interest in respect of the gambling industry. I have a quick note on our view on the purpose of the Bill. As Mr. Grant highlighted, there is no Government strategy to reduce gambling-related harms. There is neither a roadmap for action across Government Departments nor any specified goals or targets. This makes this Bill therefore a critical tool for change.

The programme for Government committed to bring forward legislation that protects public safety and well-being. The measures in the Bill, in our view, must reduce the exposure of the overall population to gambling-related harms, reduce the incidence of problem gambling among children and adults and protect vulnerable people, most notably children, people with mental ill-health and those with problem gambling or who are experiencing multiple addictions.

We know that around one in four 15- and 16-year-olds in Ireland have gambled for money in the past 12 months. This is therefore not a minority activity among children and young people. Of those, approximately 5.7% are experiencing problem gambling. It is our view that regulation in Ireland must focus on making gambling much less appealing and far less accessible for children, as well as less harmful for those who gamble.

In terms of adults, we know that for every person who is experiencing problem gambling, another six people are adversely affected. There is a spectrum of gambling disorders that goes well beyond problem gambling. We also know that problem gambling and mental ill-health are strongly related, albeit in complex ways. For this reason, we would see regulation that reduces gambling-related harms through appropriate regulation having a protective role in relation to mental health, health inequalities and the reduction of poverty.

Our core recommendations are around pace and priority. Reform of gambling regulation is certainly overdue. It is important to public health, health inequalities and mental health. Pace and priority are now vital.

In terms of heads 10 and 17, we recommend that provision be made to include public health expert representation on the membership of the authority and advisory committee. In order to maintain public trust and adherence to the goals of public safety and well-being, conflict of interest will have to be very carefully managed.

We recommend some amendments to heads 49, 86 and 92 to better protect vulnerable groups. These refer to limits applied to all gambling products, stakes, prizes and deposits, including those online, as well as to a scheme of escalating fines and a threshold that, if exceeded, triggers the revocation of a licence. Breach of self-exclusion measures should incur an automatic loss of licence.

In relation to the protection of children, we have a particular concern around the role that advertising, marketing and sponsorship are playing in enhancing the appeal of gambling to children and young people and setting them on a path to progressing to at-risk gambling and into problem gambling. We recommend that extensive regulation of marketing be included in the Bill.