Review and analysis of sports and
race betting inducements
Nerilee Hinga, Kerry Sprostonb, Richard Bradinga and
Kate Brookb
Centre for Gambling Education & Research, Southern Cross University
ORC International
a
b
October 2015
© Copyright Victorian Responsible Gambling Foundation, October 2015
This publication is licensed under a Creative Commons Attribution 3.0 Australia licence. The licence does not apply to any images, photographs,
branding or logos.
For information on the Victorian Responsible Gambling Foundation Research Program visit responsiblegambling.vic.gov.au.
Disclaimer:
The opinions, findings and proposals contained in this report represent the views of the author and do not necessarily represent the attitudes or
opinions of the Victorian Responsible Gambling Foundation or the State of Victoria. No warranty is given as to the accuracy of the information. The
Victorian Responsible Gambling Foundation specifically excludes any liability for any error or inaccuracy in, or omissions from, this document and
any loss or damage that you or any other person may suffer.
To cite this report:
Hing N., Sproston, K., Brading, R., and Brook, K. (2015) Review and analysis of sports and race betting inducements. Victoria, Australia:
Victorian Responsible Gambling Foundation.
Conflict of interest declaration
Nerilee Hing has worked with Echo Entertainment, Sportsbet and Singapore Pools over the four years previous to the study. She has also received
funding over the past four years from the Victorian Responsible Gambling Foundation, Gambling Research Australia, the Queensland Government and
the National Association of Gambling Studies (NAGS).
Kerry Sproston has received funding from Gambling Research Australia in the past four years.
Richard Brading has worked with BetSafe Pty Ltd over the four years previous to the study.
The other author has no conflicts to declare.
Victorian Responsible Gambling Foundation
Level 6, 14-20 Blackwood Street
North Melbourne, Victoria, 3051
PO Box 2156
Royal Melbourne Hospital
Victoria, 3050
Tel +61 3 9452 2600
Fax +61 3 9452 2660
ABN: 72 253 301 291
Our vision: A Victoria free from gambling-related harm
Review and analysis of sports
and race betting inducements
Prepared by: Nerilee Hinga, Kerry Sprostonb, Richard Bradinga and Kate
Brookb
a
Centre for Gambling Education & Research, Southern Cross University
b
ORC International
October 2015
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Acknowledgements
This project was funded by the Victorian Responsible Gambling Foundation. The content is solely the
responsibility of the author(s) and does not necessarily represent the official views of the Victorian
Responsible Gambling Foundation.
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
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Table of Contents
EXECUTIVE SUMMARY ........................................................................................................... 8
CHAPTER ONE: INTRODUCTION TO THE STUDY .............................................................. 14
1.1 Introduction ....................................................................................................................................................... 14
1.2 Project requirements and research questions .................................................................................................. 14
1.3 Project definition of wagering inducements ...................................................................................................... 15
1.4 Overview of the study’s methodology ............................................................................................................... 15
1.5 Scope of the study ............................................................................................................................................ 16
1.6 Structure of this report....................................................................................................................................... 16
CHAPTER TWO: LITERATURE REVIEW .............................................................................. 17
2.1 Introduction ....................................................................................................................................................... 17
2.2 Overview of sports and race betting in Australia............................................................................................... 17
2.2.1 Wagering operators .................................................................................................................................... 17
2.2.2 Betting odds ................................................................................................................................................ 18
2.2.3 Types of bets .............................................................................................................................................. 18
2.2.4 Betting channels ......................................................................................................................................... 18
2.2.5 Wagering participation and expenditure ..................................................................................................... 19
2.3 Marketing of sports and race betting ................................................................................................................. 20
2.3.1 Media used for wagering marketing ........................................................................................................... 20
2.3.2 Investment in wagering marketing .............................................................................................................. 21
2.3.3 Sponsored advertising and promotion of wagering marketing ................................................................... 21
2.3.4 Target markets for wagering marketing ...................................................................................................... 22
2.3.5 Major messages conveyed in wagering marketing .................................................................................... 22
2.4 Marketing inducements ..................................................................................................................................... 23
2.4.1 Definition and purpose ................................................................................................................................ 23
2.4.2 Types of inducements................................................................................................................................. 24
2.4.3 Consumer responses to inducements ........................................................................................................ 24
2.4.4 Benefits of marketing inducements for sellers ............................................................................................ 26
2.5 How the gambling industry uses inducements to promote gambling ............................................................... 27
2.5.1 Types of gambling incentives offered ......................................................................................................... 27
2.5.2 How gambling incentives are obtained ....................................................................................................... 27
2.6 How the wagering industry uses inducements to promote gambling ............................................................... 28
2.6.1 Types of wagering incentives offered ......................................................................................................... 28
2.6.2 How wagering incentives are obtained ....................................................................................................... 28
2.7 Influence of marketing inducements on gambling behaviour............................................................................ 30
2.7.1 Influence of gambling inducements on gambling behaviour ...................................................................... 30
2.7.2 Influence of wagering inducements on betting behaviour .......................................................................... 32
2.8 Influence of wagering inducements on gambling problems .............................................................................. 33
2.8.1 Gambling problems associated with wagering ........................................................................................... 33
2.8.2 Risk factors for gambling problems associated with wagering ................................................................... 34
2.8.3 Influence of wagering marketing on gambling problems associated with wagering .................................. 35
2.8.4 Influence of gambling and wagering inducements on gambling problems................................................. 36
2.9 Chapter summary.............................................................................................................................................. 38
CHAPTER THREE: POLICY ANALYSIS ................................................................................ 40
3.1 Introduction ....................................................................................................................................................... 40
3.2 The Legal Landscape ........................................................................................................................................ 40
3.2.1 Background ................................................................................................................................................. 40
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3.2.2 The Australian betting market opens .......................................................................................................... 42
3.2.3 Reaction to the impacts of change ............................................................................................................. 43
3.2.4 Inducements, problem gambling and the courts ........................................................................................ 43
3.2.5 Government reviews in Australia ................................................................................................................ 44
3.2.6 Responses from Australian governments................................................................................................... 46
3.2.7 Codes of practice and codes of conduct .................................................................................................... 48
3.3 International Developments .............................................................................................................................. 50
3.3.1 Accessing offshore Internet wagering ........................................................................................................ 50
3.3.2 International directions................................................................................................................................ 50
3.3.3 Europe ........................................................................................................................................................ 51
3.3.4 United Kingdom .......................................................................................................................................... 52
3.3.5 Denmark ..................................................................................................................................................... 52
3.3.6 Germany ..................................................................................................................................................... 53
3.3.7 Italy ............................................................................................................................................................. 53
3.3.8 Small jurisdictions ....................................................................................................................................... 53
3.3.9 International industry and organisational initiatives .................................................................................... 54
3.4 Policy Issues ..................................................................................................................................................... 55
3.4.1 Terms and conditions of inducements ........................................................................................................ 55
3.4.2 Broadcasting and advertising ..................................................................................................................... 56
3.4.3 Complaint resolution ................................................................................................................................... 57
3.4.4 Credit .......................................................................................................................................................... 57
3.4.5 Loyalty programs ........................................................................................................................................ 57
3.4.6 Affiliates ...................................................................................................................................................... 58
3.5 Laws and self-regulatory measures .................................................................................................................. 58
3.5.1 Types of measures ..................................................................................................................................... 58
3.5.2 Commonwealth ........................................................................................................................................... 59
3.5.3 States and Territories ................................................................................................................................. 59
3.6 Identifying options ............................................................................................................................................. 60
3.6.1 Elements of laws ......................................................................................................................................... 60
3.6.2 Determining the objectives of the regulatory approach .............................................................................. 60
3.6.3 Industry view ............................................................................................................................................... 61
3.6.4 Option 1: Prohibition of all inducements ..................................................................................................... 62
3.6.5 Option 2: Prohibition of some inducements ................................................................................................ 62
3.6.6 Option 3: Restrictions on the type and terms of inducements .................................................................... 62
3.6.7 Option 4: Restrictions on the type and form of advertising ......................................................................... 63
3.6.8 Option 5: Requirements for additional features – terms and conditions, independent dispute resolution . 63
3.6.9 Option 6: Improved self-regulation ............................................................................................................. 64
3.7 Chapter summary.............................................................................................................................................. 64
CHAPTER FOUR: THE AUDIT OF INDUCEMENTS .............................................................. 65
4.1 Introduction ....................................................................................................................................................... 65
4.2 Method .............................................................................................................................................................. 65
4.3 Inducement types .............................................................................................................................................. 67
4.3.1 Sign up offer ............................................................................................................................................... 68
4.3.2 Refer a friend offer ...................................................................................................................................... 69
4.3.3 Happy hour (or similar) offer ....................................................................................................................... 69
4.3.4 Mobile betting offer ..................................................................................................................................... 71
4.3.5 Multi bet offer .............................................................................................................................................. 71
4.3.6 Refund/stake back offer .............................................................................................................................. 72
4.3.7 Match (or partially match) your stake/deposit (with bonus bets) ................................................................ 72
4.3.8 Winnings paid even if you don’t win ........................................................................................................... 73
4.3.9 Bonus or better odds .................................................................................................................................. 73
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4.3.10 Bonus or better winnings .......................................................................................................................... 74
4.3.11 Competitions (where payout is in bonus bets) ......................................................................................... 74
4.3.12 Reduced commission ............................................................................................................................... 75
4.3.13 Free bets (selected punters) ..................................................................................................................... 75
4.3.14 Other free bets (e.g. predict the outcome of a match).............................................................................. 76
4.3.15 Cash rebate (no play through required).................................................................................................... 76
4.3.16 Click to call bonus ..................................................................................................................................... 77
4.4 Summary statistics ............................................................................................................................................ 78
4.4.1 Number of inducements, by brand ............................................................................................................. 78
4.4.2 Inducement types ....................................................................................................................................... 79
4.4.3 Incentive provided ....................................................................................................................................... 82
4.4.4 Monetary value of incentives ...................................................................................................................... 85
4.4.5 Sporting or racing ....................................................................................................................................... 86
4.5 Terms and conditions associated with inducements ........................................................................................ 88
4.5.1 Overview ..................................................................................................................................................... 88
4.5.2 Play through restrictions ............................................................................................................................. 90
4.5.3 Jurisdictional restrictions............................................................................................................................. 92
4.5.4 Restrictions on betting medium .................................................................................................................. 93
4.6 Responsible gambling messaging .................................................................................................................... 95
4.7 Chapter summary.............................................................................................................................................. 98
CHAPTER FIVE: DISCUSSION ............................................................................................ 100
5.1 Introduction ..................................................................................................................................................... 100
5.2 Main characteristics of inducements ............................................................................................................... 100
5.2.1 Prominence of inducements ..................................................................................................................... 100
5.2.2 Most inducements change frequently, but some are perennial ................................................................ 100
5.2.3 All inducements are price promotions ...................................................................................................... 101
5.2.4 Wide range of inducements and incentives .............................................................................................. 101
5.2.5 Many inducements are for complex bet types and combined contingencies ........................................... 102
5.2.6 Most common types of inducements ........................................................................................................ 103
5.2.7 Inducements used by new entrants .......................................................................................................... 103
5.2.8 Differences between onshore and offshore inducements ........................................................................ 103
5.2.9 Sports betting inducements vs race betting inducements ........................................................................ 104
5.2.10 Complex terms and conditions ............................................................................................................... 104
5.2.11 Minimal embedded responsible gambling messages ............................................................................. 105
5.3 Considerations for harm minimisation ............................................................................................................. 106
5.3.1 Wagering inducements and the commencement of betting ..................................................................... 106
5.3.2 Wagering inducements and the continuation of betting ........................................................................... 107
5.3.3 Wagering inducements and the intensification of betting ......................................................................... 108
5.3.4 Wagering inducements and problem gambling ........................................................................................ 109
5.4 Considerations for consumer protection ......................................................................................................... 110
5.4.1 Complex terms and conditions ................................................................................................................. 111
5.4.2 Minimal provision of responsible gambling messages ............................................................................. 111
5.4.3 Exposure of minors to promotions for wagering inducements ................................................................. 111
5.5 Limitations of the study ................................................................................................................................... 112
5.6 Conclusion....................................................................................................................................................... 112
REFERENCES ...................................................................................................................... 114
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List of Tables
Table 4.1 Brands included in the inducements audit, onshore/offshore operators................................ 65
Table 4.2 Total inducements by brand, by count.................................................................................. 78
Table 4.3 Inducements by type ............................................................................................................ 79
Table 4.4 Average maximum monetary value, by brand ...................................................................... 85
Table 4.5 Average maximum monetary value, by onshore vs offshore ................................................ 86
Table 4.6 Average maximum monetary value, by type of inducement ................................................. 86
Table 4.7 Type of activity, by whether onshore or offshore .................................................................. 86
Table 4.8 Type of activity, by brand ..................................................................................................... 87
Table 4.9 Type of inducement, by activity ............................................................................................ 88
Table 4.10 Overview of restrictions, by whether onshore or offshore ................................................... 90
Table 4.11 Average play through requirements, by brand.................................................................... 91
Table 4.12 Average play through requirements, by type of inducement ............................................... 92
Table 4.13 Jurisdictional restrictions, by brand .................................................................................... 92
Table 4.14 Jurisdictional restrictions, by type of inducement ............................................................... 93
Table 4.15 Restrictions on medium, by whether onshore or offshore (% of inducements with a medium
restriction)............................................................................................................................................ 93
Table 4.16 Has a restriction on medium, by brand (% of brand’s inducements) ................................... 94
Table 4.17 Restrictions on medium, by brand (% of inducements with a medium restriction)............... 94
Table 4.18 Has a restriction on medium, by inducement type (% of type’s inducements) .................... 95
Table 4.19 Restrictions on medium, by type of inducement (% of inducements with a medium
restriction)............................................................................................................................................ 95
Table 4.20 Responsible gambling messaging, by whether onshore or offshore ................................... 97
Table 4.21 Responsible gambling messaging, by brand ...................................................................... 98
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List of Figures
Figure 4.1 Example sign up offer ......................................................................................................... 68
Figure 4.2 Example refer a friend offer ................................................................................................ 69
Figure 4.3 Example happy hour offer ................................................................................................... 69
Figure 4.4 Example mobile betting offer .............................................................................................. 71
Figure 4.5 Example multi bet offer ....................................................................................................... 71
Figure 4.6 Example refund/stake back offer......................................................................................... 72
Figure 4.7 Example match your stake/deposit offer ............................................................................. 72
Figure 4.8 Example winnings paid even if you don’t win offer .............................................................. 73
Figure 4.9 Example bonus or better odds offer .................................................................................... 73
Figure 4.10 Example bonus or better winnings offer ............................................................................ 74
Figure 4.11 Example competition ........................................................................................................ 74
Figure 4.12 Example reduced commission offer .................................................................................. 75
Figure 4.13 Example free bets offer ..................................................................................................... 75
Figure 4.14 Example other free bets offer ............................................................................................ 76
Figure 4.15 Example cash rebate offer ................................................................................................ 76
Figure 4.16 Example click to call bonus offer ....................................................................................... 77
Figure 4.17 Inducements by brand ...................................................................................................... 79
Figure 4.18 Inducements by type ......................................................................................................... 80
Figure 4.19 Inducement types by onshore/offshore ............................................................................. 80
Figure 4.20 Top two inducement types by brand - onshore ................................................................. 81
Figure 4.21 Top two inducement types by brand - offshore ................................................................. 82
Figure 4.22 Incentive types .................................................................................................................. 83
Figure 4.23 Incentive types by onshore/offshore ................................................................................. 83
Figure 4.24 Top two incentive types by brand - onshore ...................................................................... 84
Figure 4.25 Top two incentive types by brand - offshore ...................................................................... 84
Figure 4.26 Example of a responsible gambling message embedded within the inducement (not
hyperlinked) ......................................................................................................................................... 96
Figure 4.27 Example of a responsible gambling message when scrolled to the bottom of the
promotions page (contains hyperlink) .................................................................................................. 96
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Executive summary
Introduction
This study was commissioned by the Victorian Responsible Gambling Foundation to inform its
response to the use of inducements by the wagering industry. The project requirements were to:

Review the literature on inducements to gamble.

Analyse the current legal status of inducements to gamble in Australian jurisdictions, and in
relevant overseas jurisdictions.

Document the ways the gambling industry uses inducements to encourage take up of
gambling, continued gambling or intensification of gambling.

Establish processes to allow the foundation to monitor inducements on an ongoing basis.
Methods
This study was conducted over seven weeks (4 May to 25 June 2015) and involved four main stages
of research:

Stage One involved a literature review to contextualise the study and to examine the existing
Australian and international evidence in relation to the project’s research questions.

Stage Two involved a policy analysis to examine the laws and regulations relating to
inducements across Australian jurisdictions and relevant international comparisons.

Stage Three entailed an audit of all inducements offered by 30 major wagering brands,
comprising 18 operators licensed in Australia and 12 popular offshore operators that accept
bets from Australian residents. All inducements offered on these operators’ websites were
audited twice (at the beginning and end of a three week period: 8th-28th May 2015) to
maximise the comprehensiveness of the audit, and to accommodate short term variations. 1
The audit documented the key attributes of these inducements in a customised database, and
analysed the results to produce summary statistics.

Stage Four involved the establishment of systems and processes to allow the continual
monitoring of wagering inducements. The customised database was developed in Access and
an accompanying manual was developed in order to enable comparable audits to be
conducted and analysed in subsequent monitoring exercises.
One offshore brand’s website became unavailable during the audit period, due to maintenance, and a replacement
brand was selected for the second, end of period count. The replacement brand had no inducements at that time. As the
replacement brand was not included in the first count and had no inducements on its website during the second count,
30 brands, rather than 31, are referred to throughout this report.
1
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Results
The study’s main results are summarised below in relation to the study’s three research questions
(RQs).
RQ1 How does the gambling industry use inducements to promote gambling
products?
The following key results were found in the audit of wagering inducements:

The 30 wagering brands offered 223 distinct inducements during the audit period that were
categorised into 15 different types which offered a wide range of incentives to bet.

The most common types of inducements offered were refund/stake back offers (27% of all
inducements), followed by sign up offers (13%), bonus or better odds (13%), and bonus or
better winnings (12%).

Other types of inducements comprised multi bet offers (9%), winnings paid on losing bets,
(7%), happy hours or similar (4%), match your stake/deposit (4%), cash rebates (4%), refer a
friend offers (3%), free bets to selected punters (2%), other free bets (2%), mobile betting
offers (1%), reduced commission (1%), and competitions (<1%).

Onshore brands (those licensed in Australia) offered nearly three times more inducements
(average 11.6) than offshore brands (4.1), with the former more commonly providing
refund/stake back offers, and the latter more frequently offering sign up bonuses.

The strategic importance of attracting new customers (sign up offers comprised 13% of
inducements) was reflected in the associated average maximum financial incentive ($200
overall, $226 onshore, $146 offshore); whereas promotions involving the refund of nonwinning stakes, which were more prevalent (27%), had a lower average maximum value ($85
overall, $80 onshore, $169 offshore).

Loyalty programs, provision of credit for betting, and affiliate referral programs also comprise
inducements to bet. These were not included in the audit as they are not widely advertised on
operator websites.

A recent development is ‘click to call’ technology which allows bettors to place in-play bets
through their computer or mobile phone without needing to speak to a telephone operator.
This system was introduced by williamhill.com.au and tomwaterhouse.com.au in May 2015. At
the time of writing, these operators were offering matched bonuses for the first click to call bet
made on any live market. However, these bonuses commenced after the audit period so were
not included.

Wagering inducements in the audit were characterised by being prominently promoted on
operator websites, subject to frequent change (except for the perennial recruitment
inducements), and focused mainly on sports betting (50%), compared to race betting (32%) or
both (18%). All inducements were a form of a price promotion offering temporary price cuts,
monetary savings, bonus bets or refunds. Many inducements were for complex bet types and
combined contingencies. All inducements were subject to a range of terms and conditions on
their uptake.

Wagering inducements rarely had a responsible gambling message embedded in their
website advertisements (12%), although almost all operator websites had a responsible
gambling message (95%) with links to further information (94%). However, where responsible
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gambling messages were provided, they were in small font, usually in the margins of the
screen, and therefore unlikely to be noticed, difficult to find and hard to read.

Inducements that incentivise the commencement of betting include sign up bonuses, refer a
friend bonuses and affiliate programs. Sign up bonuses had an average maximum value of
$200 which was usually paid in bonus bets requiring, on average, 4.9 play throughs (of the
bonus bet and/or the initial stake and/or any winnings from the bonus bet). Refer a friend
bonuses had an average maximum value of $69 and required an average of 2.6 play
throughs. Wagering inducements aimed at commencement of betting can increase the overall
number of bettors, overall betting consumption and the risk of possible harm. They also
increase the use of multiple wagering accounts which can extend time and money spent
through using bonus bets requiring matched amounts. Opening multiple accounts also
exposes bettors to a plethora of additional marketing that encourages further betting.

Some types of inducements inherently encourage continuation of betting. Inducements with
bonus bets and deposits received after an incentivised bet (or as a reward or through
redemption of loyalty points) require continued betting to benefit from the incentive. These
include the most common types of inducements identified in the audit. Mobile betting offers,
multi bet offers, refund/stake back offers, competitions, free bets to selected punters, and
other free bets all exclusively or mainly provided the incentive in the form of bonus bets or
deposits. In contrast, inducements which provide the incentive as cash or better
odds/winnings do not necessitate continued betting to benefit from the offer. They may,
however, enhance the appeal of these bets and thus encourage additional consumption;
alternatively, they may provide other benefits that serve to retain customer loyalty. Thus, the
type of incentive offered appears to have most potential influence on continued betting, with
bonus bets and deposits requiring subsequent bets clearly having most potential influence.

Some types of inducements stand out as having strongest potential for intensifying betting.
Those with stringent play through conditions clearly increase the volume of an individual’s
betting, the amount of time spent gambling, and exposure to a potentially addictive activity.
Many bonus bets also require a matching bet, thus intensifying betting expenditure.
Inducements for multi bets may encourage increased volume of betting, as these require
heavier product use. Inducements for multi bets and exotic bets also incentivise betting on
complex and combined contingencies with probabilities that are extremely difficult to calculate
and for which loss rates are high. They therefore incentivise risky gambling decisions and may
increase gambling-related harm as more losses occur. Happy hours can concentrate betting
into short time periods, while the promotion of inducements at point-of-sale and through direct
marketing can encourage impulse betting and therefore increase consumption. The provision
of credit for betting has the potential to greatly intensify betting as some individuals become
caught in a cycle of wagering losses, followed by betting on credit, leading to likely further
losses and an inability to repay the debt.

Effects of wagering inducements on maintaining problem gambling behaviours are unknown,
but there is no obvious reason to expect that they would be exempt from the heightened
negative impacts on problem gamblers found for other gambling advertising. The heavy
promotion of wagering inducements at point-of-sale, in mass media, social media and in direct
communications to bettors means that this advertising cannot be avoided, exposing problem
gamblers to an ongoing plethora of betting cues as inducements are continually refreshed.
These cues are highly incentivised through offers of ‘free’ bets, deposits and money-back
guarantees, and bettors can apply for credit for betting. Problem gamblers themselves have
reported harmful effects, but further empirical research is needed with larger samples than
included to date, and to determine any differential effects for different types of wagering
inducements.
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
Hing, Sproston, Brading & Brook
In addition to the potential harms raised from the sheer volume and diversity of wagering
inducements that encourage the commencement, continuation and intensification of betting,
and their likely detrimental effects on problem gamblers, other key issues undermining
consumer protection are: 1) the complexity and lack of transparency of terms and conditions
attached to inducements, which may be misleading and hinder informed choice; 2) minimal
provision of responsible gambling messages attached to advertisements for inducements; and
3) the likelihood of children and adolescents being exposed to marketing messages for
wagering inducements.
RQ2 What conditions does industry place on consumers taking up inducements?
The audit analysed the key terms and conditions of wagering inducements, with the following results
found:

All inducements were subject to certain terms and conditions, and their complexity and lack of
transparency were key characteristics of those audited.

Terms and conditions were often not contained in the website display advertisement itself, but
required clicking on a link to access them.

Inducements were typically also subject to a raft of general terms and conditions which were
located elsewhere on the operator’s website. In many cases, it was up to the customer to
locate these general terms and conditions, with no direct link provided.

The sheer volume of these general terms and conditions (e.g. 450 pages for one Australian
operator) and the legalistic language used meant that it was not always obvious, and in some
cases extremely difficult to ascertain, what restrictions applied to a particular inducement. The
terms and conditions examined indicate that many fail to meet the basic requirements to
enable informed choice.

The most commonly applied terms and conditions, applicable to more than half the
inducements audited, were restrictions on the use of bonus bets (76% of all inducements),
restrictions on the maximum value of the incentive/payout/bonus (60%), limited to recreational
gamblers (55%), exclusive to registered members (52%), and subject to a time restriction
(48%).

Terms and conditions applying to more than one-third (but less than half) of the inducements
audited were a limit of one per person/account or household (42%), a limit of one per event
(39%), a play through requirement (35%), and a limit to a particular betting medium
(predominantly online) (36%).

Those found in fewer inducements were that they could not be used with any other offers
(25%), they were limited to particular jurisdictions (27%, onshore only audited), they had
minimum and/or maximum value limits for the associated bet (18%), and an explicit
requirement for a minimum odds threshold was placed on the associated bet (13%).

Play through requirements were particularly difficult to understand, and varied in terms of
requiring the bonus bet and/or initial stake and/or any winnings from the bonus bet to be
played through.

Play through requirements were highest for mobile betting offers (5 times), followed by sign up
offers (4.9) and happy hour offers (3.3).

Offshore brands were more likely to have a play through requirement and to stipulate multiple
play throughs (average 5.8 times), compared to onshore brands that required an average of
1.1 play throughs.
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RQ3 How are inducements currently regulated in Australia and similar
jurisdictions?
The policy analysis found that the regulatory environment for wagering inducements currently lacks
clarity on what constitutes an inducement, provides little specificity about which aspects of
inducements are acceptable or not, and lacks consistency across Australian jurisdictions. A variety of
relevant legislation, regulations and codes of practice exist for gambling, advertising and broadcasting,
which might inform the provision and promotion of wagering inducements. However, their provisions
are typically vague and often provide little specific direction to ensure that these inducements minimise
gambling harm and provide adequate protection for consumers. International jurisdictions have
responded in a variety of ways, but their responses have also been piecemeal and fragmented.
More specifically:

Wagering inducements in Australia are currently regulated through a mix of:






Commonwealth laws, including the Interactive Gambling Act 2001 and the Broadcasting
Services Act 1992.
State laws, such as the Gambling Regulation Act 2003 (Vic).
Mandatory codes of practice, such as the Northern Territory Code of Practice for
Responsible Gambling.
Voluntary codes of practice, such as the Queensland Responsible Gambling Code of
Practice.
Individual operators’ codes, such as the TABCORP Wagering Responsible Gambling
Code of Conduct.
Broadcasting and advertising codes of practice.

Similar instruments are used to regulate wagering inducements in international jurisdictions
and they offer some additional options in regulating wagering inducements, e.g. Denmark
regulates how terms and conditions must be presented; some jurisdictions require preapproval of all gambling advertising material by the regulator.

The issue of inducements has attracted significant attention in recent years. Governments and
industry have made some progress in providing consumer protection measures; however, it
appears that more should be done.

The current situation where each Australian jurisdiction has a different approach is clearly
unsatisfactory and confusing for both the wagering industry and consumers.

The fact that most wagering operators are licensed in smaller jurisdictions with a low level of
regulation is also problematic.

In Australia, the Commonwealth has the potential to take a more active role in relation to
inducements.

Developments in Europe offer some additional options in managing wagering inducements.

Terms and conditions of inducements should be made accessible and easily understood so
they can be compared and enable informed choice.

Broadcasting and advertising codes of practice could be expanded to cover the advertising of
inducements in more detail.

Complaints resolution processes are important.

The availability of credit or delayed payment of betting accounts is an inducement that has the
potential to cause significant harm.
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
Affiliates and loyalty programs of wagering operators are rarely mentioned in regulation or
codes of practice.

There are a number of regulatory options available to better manage the provision of wagering
inducements.
Limitations of the study
The main limitation of this study was its reliance on secondary data. While use of secondary data was
adequate and appropriate to meeting the project requirements, lack of available data on the effects of
wagering inducements on betting behaviours limits the implications that can be drawn from this study’s
results. Other limitations of this study relate to the short time period available for the policy analysis
and audit. While the policy analysis is highly inclusive of numerous jurisdictions and of legislation,
regulation, codes and cases relevant to the provision and promotion of wagering inducements, a
longer timeframe may have allowed a more detailed analysis. The one month time period for the audit
precluded the capturing of any seasonal variations and a truly representative approach. While the
results of the audit are accurate for the time period covered, it is not known whether the same results
would be obtained in an audit over a longer time period. The rapidly changing nature of inducements
during the audit period suggests they may be highly variable over time. The short time frame also did
not allow the audit to include any terms and conditions relating to wagering inducements that were
contained in the vast volume of general terms and conditions on operator websites. Nevertheless, the
audit captured the key attributes of the inducements and enabled an analysis of the main features that
have the potential to impact on betting behaviour.
Conclusion
This study is the first known detailed examination of wagering inducements in Australia. The study
provided a comprehensive account of how the wagering industry uses inducements to promote its
products, the conditions placed on consumers taking up these inducements, how gambling
inducements are regulated in Australia and in similar jurisdictions, and a range of policy responses
available to governments. This study has therefore contributed foundational information to assist
efforts to evaluate, monitor, regulate and respond to the prolific supply and promotion of wagering
inducements in ways that best promote responsible gambling, consumer protection and harm
minimisation for bettors.
However, the lack of research into wagering inducements currently precludes an evidence-based
approach to policy. Empirical research is needed to draw firm conclusions about the actual influence
of wagering inducements on the commencement, continuation and intensification of betting, on the
maintenance of problem gambling, and on consumer protection when betting. Research that identifies
bettors’ responses to different types of inducements and incentives, and for bettors at different levels
of risk for gambling problems, is also urgently needed.
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Chapter One: Introduction to the study
1.1 Introduction
The increased proliferation of wagering inducements offered by sports and race betting operators has
been part of their broader intensification of wagering marketing. Many Australians report feeling
bombarded by wagering marketing, particularly for sports betting (ACMA, 2013). Concerns about its
potential to normalise betting, contribute to problem gambling, and expose minors to gambling
messages have been raised in several government inquiries (Department of Broadband,
Communications and the Digital Economy [DBCDE], 2012; Joint Select Committee on Gambling
Reform [JSCGR], 2011, 2013; Select Committee on the Impact of Gambling, 2014). Research has
also found substantial community unease about its proliferation, as well as preliminary evidence that
exposure to wagering marketing is associated with increased betting participation and betting
problems (Hing, Vitartas & Lamont, 2014a; Sproston, Hanley, Brook, Hing & Gainsbury, 2015).
One contentious type of wagering marketing that has recently emerged involves the offering of
inducements to bet, such as ‘free’ bets, money-back guarantees, matching deposits, and sign up
bonuses for opening a betting account. These wagering inducements represent point-of-sale
promotions as they are offered through each operator’s website and mobile betting apps where
consumers have an immediate opportunity to purchase. They are also advertised through other digital
channels including social media, online advertising banners, direct emails and mobile messaging, as
well as through traditional media including television, radio and print. While these inducements can
provide interest, entertainment, monetary savings and other benefits for consumers, they may also
encourage uptake, continuation and intensification of betting and contribute to betting-related harm.
However, very few studies have examined the nature and impacts of gambling inducements, and
research specifically examining wagering inducements is all but non-existent.
The increased proliferation of wagering inducements, along with related community concerns, have
prompted jurisdictions to consider how best to evaluate, monitor, regulate and respond to them. To
formulate appropriate responses, a clear understanding is needed of how these inducements are
offered and their intended effects, as well as their likely impacts on the commencement, continuation
and intensification of betting. Their implications for consumer protection and harm minimisation in
wagering are also critical considerations. This report analyses these issues to inform the Victorian
Responsible Gambling Foundation’s response to the use of inducements by the wagering industry.
1.2 Project requirements and research questions
The project requirements were to:

Review the literature on inducements to gamble.

Analyse the current legal status of inducements to gamble in Australian jurisdictions, and in
relevant overseas jurisdictions.

Document the ways the gambling industry uses inducements to encourage take up of
gambling, continued gambling or intensification of gambling.

Establish processes to allow the foundation to monitor inducements on an ongoing basis.
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Key research questions underpinning this study were:

How does the gambling industry use inducements to promote gambling products?

What conditions does industry place on consumers taking up inducements?

How are inducements currently regulated in Australia and similar jurisdictions?
1.3 Project definition of wagering inducements
No officially recognised definition of wagering inducements exists. The research team therefore
developed the following definition for this project based on a review of the marketing inducements
literature, as well as an examination of the array of wagering inducements on offer to Australians by
major wagering brands.
Project definition of wagering inducements
Sports and race betting inducements are typically presented as sales promotions and have the
following essential components:

They offer one or more incentives to bet that are additional to what is normally received as part of
the core wagering product.

The incentive to bet is offered in conjunction with a specified betting-related activity and/or
redeemed in a form that encourages betting.

This incentive aims to trigger one or more of the following consumer responses:
-
induce an immediate sale or move the sale forward
-
retain existing customers by matching or bettering competitors’ incentives
-
prompt brand switching from competitors to the promoted brand
-
increase or intensify purchasing
-
encourage future purchasing
-
increase the customer base (number of account holders)
-
encourage usage of particular betting channels (e.g. smartphone, tablet)
-
encourage betting on a particular event and/or
-
encourage betting during particular time periods.
1.4 Overview of the study’s methodology
This study was conducted over seven weeks (4 May to 25 June 2015) and involved four main stages
of research:

Stage One involved a literature review to contextualise the study and to examine the existing
Australian and international evidence in relation to the project’s research questions.
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
Stage Two involved a policy analysis to examine the laws relating to inducements across
Australian jurisdictions and relevant international comparisons, along with commentary on the
implementation of these laws and their effectiveness.

Stage Three entailed an analysis of sports and race betting inducements. An audit of all
inducements offered by 30 major wagering brands was conducted, including by 18 operators
licensed in Australia and 12 of the most popular offshore operators that accept bets from
Australians in AU$. All inducements offered on these operators’ websites were audited twice
(at the beginning and end of a three week period: 8th-28th May 2015) to maximise the
comprehensiveness of the audit, and to accommodate short term variations. One offshore
brand’s website became unavailable during the audit period, due to maintenance, and a
replacement brand was selected for the second, end of period count. The replacement brand
had no inducements at that time.2 The audit documented the key attributes of these
inducements in a customised database, and analysed the results to produce summary
statistics.

Stage Four involved the establishment of systems and processes to allow the foundation to
continue to monitor inducements offered by wagering operators. The customised database
was developed in Access and an accompanying manual was developed in order to enable
comparable audits to be conducted and analysed in subsequent monitoring exercises.
1.5 Scope of the study
In addition to methodological restrictions on the scope of this study, other limitations applied. The most
important of these related to the range of wagering inducements examined. The Stage Three audit
included the following types of sports and race betting inducements: sign up bonuses, refer a friend
offers, happy hour and similar offers, mobile betting offers, multi bet offers, refund/stake back offers,
matching stakes/deposits, winnings paid for losing bets, bonus odds, bonus winnings, free bets,
reduced commission, cash rebates, and competitions where the payout is in bonus bets. The audit
was restricted to inducements advertised on operator websites and able to be viewed without opening
an account.3 Some types of wagering inducements were not included in the audit because they tend
not to be promoted on operator websites and we assume they are directly targeted at individuals, via
email or within their account pages, and the terms/extent of rewards is dependent on expenditure.
These included loyalty programs, provision of credit for betting, and affiliate programs. These types of
inducements are discussed in the literature review and policy analysis, but are not included in the
audit.
1.6 Structure of this report
This report is divided into five chapters. Chapter Two contains the literature review, while Chapter
Three contains the policy analysis. Chapter Four presents the results of the audit, before Chapter Five
provides a discussion and conclusion. The audit database and accompanying manual are provided
separately to this report.
2
As the replacement brand was not included in the first count and had no inducements on its website during the second
count, 30 brands, rather than 31, are referred to throughout this report.
3 Wagering inducements publicly advertised through additional media are also displayed on operator websites. Thus, the
audit captured all publicly advertised inducements offered by the selected operators during the audit period.
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Chapter Two: Literature review
2.1 Introduction
This chapter reviews Australian and international literature to provide relevant context for this study
and its research questions. It commences with an overview of wagering in Australia in terms of
industry structure, products, betting channels and uptake. It then provides a synopsis of how wagering
is marketed in Australia, including media used, marketing investments, target markets and key
messages conveyed. The chapter then focuses on marketing inducements, describing their purpose,
characteristics, types and consumer responses. The impacts of marketing inducements for other
potentially addictive products are also considered. Inducements for gambling and for wagering are
then described and the research evidence on their influence on gambling/betting behaviour and on
gambling problems is reviewed.
2.2 Overview of sports and race betting in Australia
Wagering encompasses all legal forms of gambling on racing and sporting events. Race betting
comprises betting on the outcome of horse and greyhound races, while sports betting comprises
wagering on approved types of local, national and international sporting activities (Queensland
Government, 2014). This section provides some context for the study by describing the Australian
wagering industry’s structure in terms of operators, products and betting channels.
2.2.1 Wagering operators
Several types of wagering operators are licensed to accept bets in Australia:

Totalisator Agency Boards (TABs) are exclusively licensed in each jurisdiction to operate
totalisator (or parimutuel) betting. TABs operate through stand-alone retail agencies, as well
as agencies within hotels, clubs and casinos, and also through non-exclusive telephone and
Internet betting services (Productivity Commission, 2010; Queensland Government, 2014).

Corporate bookmakers are fully incorporated and often listed companies licensed to offer a
wide range of betting products by telephone and Internet 24/7 (Productivity Commission
2010). Since the first licensed Australian online sports bookmaker (Centrebet) commenced
operations in 1996, this sector has shown enormous growth, with about 20 online bookmakers
now licensed in Australia.

On-course bookmakers are licensed in each jurisdiction to operate at racecourses and
typically offer simple fixed odds bets such as win and place bets. Punters can wager any
amount above a specified minimum and will receive pay-outs based on the bookmaker’s odds
at the time of placing the bet (Productivity Commission, 2010; Queensland Government,
2014).

Betting exchanges create a marketplace for punters, similar to the stock exchange. Bettors
post potential wagers, odds and stake sizes on specific events which other individuals may
accept (Gainsbury, 2012; Productivity Commission, 2010). Betfair is the largest betting
exchange, comprising about 90% of the betting exchange market (Church-Sanders, 2011).
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2.2.2 Betting odds
Betting odds are calculated using one of two main systems. Fixed odds betting is where payouts are
based on the bookmaker’s odds at the time of placing the bet, regardless of whether these odds are
later revised by the bookmaker (Queensland Government, 2014). Fixed odds betting has been
increasing with the growth in popularity of corporate bookmaking services. Parimutuel betting is
operated exclusively by the TAB. To calculate payouts, the TAB deducts a percentage of total units
wagered (for costs including tax), with the remainder distributed as prizes based on multiples of the
unit wagered by each bettor (Queensland Government, 2014).
2.2.3 Types of bets
Bet types offered have expanded beyond simple win and place bets to now include a wide variety of
more innovative betting options, including the following that are relevant to this report:

Exotic bets are fixed odds bets that can be placed either before or during an event. They are
placed on individual events and contingencies occurring within the game, such as who will
score first or the score at half-time (Church-Sanders, 2011; Gainsbury, 2012).

Micro-bets are characterised by a high frequency of events, a restricted number of potential
outcomes and small timeframes (under five minutes) between bets being accepted and the
outcome being determined. Examples include betting on the outcome of the next ball in a
cricket match or the next point in a tennis match (DBCDE, 2012). Micro-bets are a form of inplay betting.

In-play betting involves betting on real time propositions about outcomes within the game,
such as which team will score next or whether a golfer will sink the next putt. In-play betting
can also refer to bets placed after the game has commenced (Church-Sanders, 2011;
Gainsbury, 2012).

Multi bets are a type of bet where the bettor combines a series of single bets into one bet with
the odds multiplying with each additional bet. Each time a leg is successful, the dividend and
original bet from that leg are bet on the next leg. The more legs in a multi bet the larger the
dividend will be (http://bet-types.com.au/multi-bet/). Some multi bets allow up to 25 legs.
2.2.4 Betting channels
Betting channels available for most bet types include retail outlets (TAB outlets, both stand-alone and
in gambling venues), on-course bookmakers, telephone and online. An exception is that in-play bets
(those placed after commencement of an event) can only be placed in person at a venue or by
telephone (DBCDE, 2012). However, a recent development is ‘click to call’ technology which allows
bettors to place in-play bets through their computer or mobile phone. Bettors select their bets online,
use the click to call button to connect to a telephone operator and confirm their bet with another click.
They do not need to speak to the telephone operator. This system was introduced by
williamhill.com.au and tomwaterhouse.com.au in May 2015. At the time of writing, these operators
were offering matched bonuses for the first click to call bet made on any live market.
Uptake of online betting channels continues to gain popularity. Estimates in 2013 were that 40% of
Australian wagering was conducted online, 40-45% at off-course agencies, and only a small
proportion by telephone (JSCGR, 2013). By 2014, 50% of all wagering industry revenue was expected
to be derived through online channels, and anticipated to rise to 67% by 2023 (Morgan Stanley, 2014).
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An Australian household survey in 2012 found that 63% of wagering customers had online accounts
(CLSA, 2013). A recent Australian survey, weighted to be nationally representative, found that
approximately 55% of Internet gamblers used only online channels for sports betting and 39% for race
betting (Hing, Gainsbury et al., 2014).
2.2.5 Wagering participation and expenditure
Race wagering is now the third most popular gambling activity in Australia after lotteries and scratch
tickets (Hing, Gainsbury et al., 2014). However, a comparison between the most recent nationally
representative gambling survey (Hing, Gainsbury et al., 2014) and the only previous one (Productivity
Commission, 1999) reveals that participation in race wagering has declined over the last decade or so,
from 24% of the adult population in 1999 to 22% in 2012. Nevertheless, this rate of decline is less than
for all other forms of gambling, except sports betting. Sports betting is the only gambling form to have
attracted increased participation in Australia and it is now the fourth most popular activity with an
annual participation rate of 13% of adults (up from 6% in 1999). Prevalence studies have found that
both sports and race bettors tend to be young adult males aged 18–34 years (Billi, Stone, Marden &
Yeung, 2014; Hare, 2009; Humphreys & Perez, 2012; Sproston, Hing & Palankay, 2010; Wardle &
Seabury, 2012).
Race betting attracts substantially higher expenditure ($2.8 billion in 2012-13) than sports betting
($484.8 million), according to the most recent official Australian statistics (Queensland Government,
2014). Reflecting trends in participation rates, race betting expenditure has marginally declined over
the last decade; however, real sports betting expenditure (adjusted for inflation) has increased nearly
five-fold in the last 10 years (Queensland Government, 2014). This revenue growth has been
achieved not just through greater numbers of Australians participating in sports betting, but also an
increase in per capita expenditure. For example, real per capita expenditure on sports betting in
Victoria has increased from $3.19 in 1999 to $36.09 in 2012-13; at the same time, real per capita
racing expenditure declined from $190.82 to $138.27 (Queensland Government, 2014).
Wagering expenditure is concentrated through the TAB, which accounted for 79.4% of all racing
expenditure and 64.8% of all sports betting expenditure in Australia in 2012-13 (Queensland
Government, 2014). About one-third (33.8%) of sports betting expenditure is through fixed odds
betting with bookmakers, and this is a growing sector. Thus, the growth of sports betting at the cost of
race betting, and the increased popularity of fixed odds betting through corporate bookmakers, are
two recent trends in the wagering sector. Internet and mobile technologies have been key drivers of
growth, enabling expansion of services across national borders by multinational corporate
bookmakers, while providing advantages such as easy access, convenience, anonymity and better
prices for consumers (Gainsbury, Wood, Russell, Hing & Blaszczynski, 2012; Hing, Vitartas et al,
2014a; Sproston et al., 2015). Further adoption of mobile betting through smartphones and tablets,
and product innovations such as new sport markets, bet types, and offers are predicted to drive the
continued growth of Australian online wagering at 10-15% per annum (Morgan Stanley, 2014).
Regulated Australian wagering sites (as well as lotteries) are exempt from the Commonwealth
Interactive Gambling Act 2001 which prohibits the supply of other forms of online gambling to
Australian residents. However, Australians have easy access to illegal offshore wagering sites. In
addition to legal wagering, Australians are estimated to have lost $611 million in 2011 to offshore
online sports betting sites, a substantial increase from the $264 million spent in 2006 (Global Betting
and Gaming Consultants [GBGC], 2011). Illegal offshore wagering is estimated to be about 30% of the
size of the online wagering market (Morgan Stanley, 2014), with punters attracted by the ability to
place in-play bets and, sometimes, more competitive prices (Hing, Gainsbury et al., 2014).
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Wagering is particularly popular in Victoria, attracting the largest sports betting expenditure and the
second largest race betting expenditure in 2012-13 compared to other Australian jurisdictions
(Queensland Government, 2014). This partly reflects the popularity of signature events such as the
Melbourne Cup, and of Australian Rules Football (AFL). Together, the AFL and the National Rugby
League (NRL) attract approximately 50% of all sports wagering in Australia, with this expenditure
predicted to double by 2016 (Deloitte, 2012). In 2011, Australian wagering operators made profits of
$15.5 million on AFL betting and $13.4 million on NRL betting after deducting marketing and other
direct costs (Deloitte, 2012). As well as the AFL and NRL, Australians can place bets on a wide variety
of Australian and international sporting fixtures, as well as local and international racing events.
2.3 Marketing of sports and race betting
Increased offering of wagering inducements in recent years has been part of a broader intensification
of advertising and promotions for wagering products. A representative survey found that two-thirds of
Australians have noticed recent increased advertising for betting agencies (ACMA, 2013). Numerous
factors have heightened competition in the Australian wagering market, prompting betting agencies to
escalate their marketing. While demand for wagering products, especially for sports betting, has been
stimulated by widespread uptake of faster Internet and mobile technologies and increased race and
sports coverage, the deregulation of online wagering has also greatly increased the number of
operators competing for the wagering dollar (Hing, Vitartas, Lamont & Fink, 2014b). A major catalyst
to increased competition was a landmark High Court decision in 2008 which deemed it
unconstitutional to prohibit bookmakers operating in one jurisdiction from advertising in another. This
decision prompted strong interest in the Australian betting market from international wagering
operators, heralding the subsequent entry of numerous corporate bookmakers into the Australian
market (Horn, 2011; Nettleton, 2013). A proliferation of wagering marketing has ensued as new
entrants have attempted to gain brand recognition and market share. A wide range of advertising and
promotional techniques are used, including a variety of inducements for wagering which are promoted
through numerous digital and traditional media channels.
This section provides an overview of how wagering is marketed in Australia to provide further context
for the analysis of wagering inducements presented later in this report. This overview draws heavily on
a study recently conducted by some of the present authors and which conducted the most detailed
examination of wagering advertising in Australia to date (Sproston et al., 2015). It used a mixedmethods approach, comprising case studies of advertising by six major wagering brands (TAB,
Tattsbet, Sportsbet, Sportingbet, Tom Waterhouse, Betfair), media monitoring in traditional and social
media, content analysis of advertisements, observational studies of live and televised wagering
events, 10 focus groups with various research audiences, and a survey of 3,200 respondents from six
different research segments. Key findings are summarised below, supplemented with other research
findings where available. Research specifically into wagering inducements is covered in a later section
in this chapter.
2.3.1 Media used for wagering marketing
Sproston et al. (2015) reported that all wagering operators they studied used multi-channel marketing.
However, advertising on free-to-air and subscription television dominated advertising spend, and was
reflected in being the top-of-mind medium for wagering marketing amongst focus group and survey
respondents. Of all types of wagering advertising in traditional media, survey respondents reported
greatest exposure over the past 12 months to TV advertisements for betting companies, and
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promotions for betting companies during sports and race broadcasts. Outdoor signage, radio and print
media were also used, but more frequently by brands with physical retail outlets. Corporate
bookmakers providing only online and telephone betting services relied mostly on television and digital
media for their advertising.
All case study brands had digital marketing strategies, and focus group participants reported receiving
wagering marketing messages through social media, online advertising banners, websites, direct
emails and mobile messaging. Nearly six in ten survey respondents had seen online sports betting
advertisements in the previous 12 months, four in ten had received emails from sports betting
operators, and two in ten had received mobile messages. Similar figures were found for digital race
betting marketing. Active and increasing use of digital advertising channels by wagering operators has
also been reported by bettors in other research (Hing, Cherney et al, 2014b). An audit of social media
use by Australian gambling operators found that betting agencies have the highest social media
presence of all gambling operator types (Gainsbury, Delfabbro, King & Hing, 2015).
2.3.2 Investment in wagering marketing
The six case study wagering brands in Sproston et al.’s study (2015) each reported marketing and
advertising expenses of $10-$40 million during 2012-13. An audit of their wagering advertising during
a 10 week period from 30 August to 7 November 2014 found that they collectively aired approximately
13,000 advertising events just on free-to-air television, national radio and in major national press titles,
costing a total of $12 million. Advertising was closely tied to upcoming events and peaked prior to
major sporting events and racing carnivals. Thus, advertisements were continually refreshed, with the
number of discrete advertisements per brand ranging from 103 to 870 during the 12 months to April
2014. Similar marketing budgets were reported by Morgan Stanley (2014) for other operators in 2014:
$49 million for the Australian division of William Hill, and almost $20 million each for Bet365 and
Ladbrokes.
These substantial advertising expenditures reflect intense competition in the wagering industry and
that wagering operators require substantial financial reserves to support competitive advertising
strategies, including continual refreshment of message content (Sproston et al., 2015). Renewing
message content is necessary for advertisements which relate to promotional inducements as these
can change frequently. Websites and other electronic media are particularly suited to promoting
wagering inducements as changes to content can be made quickly and cheaply. However, it is
noteworthy that about one-fifth of the most expensive advertisements amongst six major brands were
for promotional inducements relating to specific bets (Sproston et al., 2015). The media monitoring of
wagering marketing conducted by Sproston et al. (2015) did not include online advertisements and
direct marketing through email and SMS, so the exact extent of digital advertising of wagering
inducements remains unclear. However, it is evident that they are prominently displayed on operator
websites and mobile betting apps, and bettors report receiving a plethora of direct electronic marketing
for inducements once they open a betting account (Hing, Cherney et al., 2014b).
2.3.3 Sponsored advertising and promotion of wagering marketing
Along with extensive commercial and digital advertising, as described above, sponsorship
arrangements have provided wagering operators with opportunities to use a wide range of other
marketing techniques. Studies of embedded promotions during live and televised sporting events, and
during sports entertainment shows, have documented a vast array of fixed, dynamic, integrated and
commercial break advertising largely tied to the wagering sponsorship of sporting teams, events and
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stadiums (Hing, Vitartas et al, 2014a; Milner, Hing, Vitartas & Lamont, 2013, Sproston et al., 2015;
Thomas, Lewis, Duong & McLeod, 2012a). Focus group participants in Sproston et al.’s study (2015)
particularly noted the heavy use of promotional inducements, presenting betting odds in a similar
format to news broadcasts, appeals to sports team loyalty, and use of celebrities to endorse brands.
All six case study brands in that research utilised sponsorship, with some spreading investments
across several racing and sporting codes, while others concentrated investments in fewer codes.
Qualitative research has indicated that sports viewers feel inundated by this marketing, while survey
research shows high levels of exposure amongst television audiences (ACMA, 2013; Hing, Vitartas et
al, 2014a; Sproston et al., 2015). A representative survey found that around 80% of Australians
support a reduction in wagering advertising during live sports broadcasts and restrictions on the time
of day that betting advertising can be shown in order to shield minors (ACMA, 2013). However, this
survey was conducted before broadcasting codes of practice were changed in August 2013 to curtail
the promotion of live betting odds embedded into sports broadcasts. The advertising monitoring firm
Ebiquity reported that gambling advertising has increased 251% since this ban (Schetzer, 2014),
reflecting that wagering operators have increased their paid advertising as one way of compensating
for reduced opportunities to promote exotic, micro and other in-play bets as part of in-match
commentary.
2.3.4 Target markets for wagering marketing
The major market for wagering is young adult males who themselves report feeling targeted by this
advertising (Hing, Vitartas et al., 2014a; Sproston et al., 2015; Thomas, Lewis, McLeod & Haycock,
2012b). Wagering advertisements often include attractive females, sexualised images and language,
images of betting in bars and other male social settings, and engagement in betting by young men
(Sproston et al., 2015). Milner et al. (2013) note the aspirational identities portrayed through wagering
advertising, reflecting the power of brands as social symbols. While wagering brands differ in their
appeals and personalities, their advertising messages variously convey that using the brand will
enhance the bettor’s power, success, wealth, male bonding, and attractiveness to women (Sproston et
al., 2015). A noticeable shift has been to portray betting as an activity engaged in by well-groomed,
professional, confident, tech-savvy young males, in contrast to its earlier associations with older
working-class men in dingy retail betting outlets (Milner et al., 2013). Research has also found a
widespread perception that wagering advertisements are targeted at young people as future
customers through normalising gambling as an everyday activity and by building their familiarity with
betting products and wagering brands (Lamont, Hing & Vitartas, in press; Sproston et al., 2015).
2.3.5 Major messages conveyed in wagering marketing
Wagering marketing is heavily brand focused. Sproston et al.’s (2015) content analyses of
advertisements revealed that the brand’s value for money was commonly emphasised through
promotional inducements such as ‘free’ bets and cash back offers, along with the best odds/pay-outs.
Ease of access to betting at any time (online or through mobile apps) was also frequently stressed.
Focus group participants recognised that constant branding subconsciously builds brand trust, brand
recognition, brand image and brand engagement, which may be further enhanced through use of
celebrities and linking brands with favourite teams. This aligns with findings by Ebiquity that televised
wagering advertisements have shifted over recent years from a focus on practical/retail themes, to
brand engagement and emotional persuasion. This was borne out in survey results: respondents with
higher exposure to wagering marketing reported higher brand recall and greater influence of marketing
on brand choice, suggesting that repeated exposure builds brand preference.
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While some wagering advertisements analysed in Sproston et al.’s study (2015) were factual and
direct, others were fast-paced, upbeat and humorous. Ease of access, winning, fun, excitement, low
risk, male bonding, power, success, wealth, sexual attractiveness, and value for money were
dominant themes, with themes of winning particularly noticed by adolescents and problem gamblers.
Similar messages were found in an audit of social media posts by Australian wagering operators: that
betting is glamorous, exciting, fun and action-packed and is quick and easy to access, with messages
leveraging off sports fans’ interests and team loyalties, emphasising winning, and encouraging brand
engagement (Gainsbury, Delfabbro et al., 2015). These findings generally align with previous research
noting that gambling advertising utilises stimulating colours, sophisticated graphics, humour and
upbeat music to depict gambling in an overwhelmingly positive light and as a fun, exciting, glamorous
lifestyle promising social and financial success (Derevensky, Sklar Gupta & Messerlian, 2010; Lamont,
Hing & Gainsbury, 2011; Milner et al., 2013; McMullan, 2011; McMullan & Miller, 2008; McMullan,
Miller & Perrier, 2012; Monaghan, Derevensy & Sklar, 2008).
However, advertising may not always elicit the desired response. Most survey respondents in
Sproston et al.’s study (2015) reported negative responses (e.g. sceptical, bored, annoyed) rather
than positive responses (e.g. excitement, hopefulness) to wagering advertising, in alignment with other
research findings that sports betting marketing in particular can diminish the pleasure of watching
sport (ACMA, 2013; Hing, Vitartas et al., 2014a; Lamont, Hing et al., in press; McMullan, 2011). Mixed
cognitive responses were found, with the majority of survey respondents having both positive (e.g. you
could be a winner) and negative (e.g. I don’t care) responses. The researchers concluded that this
may indicate that the message is understood but does not necessarily influence behaviour. Research
into the influence of wagering marketing on betting behaviour is reviewed later in this chapter.
Having provided some background on the Australian wagering industry and its marketing, this review
now turns specifically to marketing inducements, including their purpose, characteristics and influence
on consumers.
2.4 Marketing inducements
2.4.1 Definition and purpose
The purpose of any inducement is to change behavior through changing people’s judgments and
actions (Emanuel, Currie & Herman, 2005). An inducement to purchase has been described as an
advantage or benefit aimed at precipitating the action of buying (Gale Group, 2008). In marketing
theory, activities which provide inducements to enhance sales are categorised as sales promotions
and also referred to as promotional inducements. Beem and Shaffer (1981) explain that three distinct
modes of marketing are: 1) the basic offer mode, which is the core product that meets the needs of
target customers; 2) the persuasive communications mode, which stimulates consumer wants through
advertising and other forms of communication; and 3) the promotional inducement mode, which
triggers customer action desired by marketers. Thus, promotional inducements are recognised as
constituting specific offers that provide additional incentives to purchase beyond those routinely
provided by the core product.
Promotional inducements (in general) typically have three essential components. First, they offer one
or more inducements to purchase, that is an additional incentive beyond what is normally received.
Second, this incentive aims to induce an immediate sale or to move the sale forward. Third, sales
promotions are non-routine offers and are usually of short-term duration. Promotional inducements
therefore provide a temporary shift in stimuli aimed at prompting an immediate shift in purchasing
behavior through providing triggers to consumer action (Van Waterschoot & Van den Bulte, 1992).
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Through use of these triggers, or inducements, sales promotions attempt to overcome consumer
inertia due to psychological, physical, risk or competitive barriers (Ailloni-Charas, 1984; Beem &
Shaffer, 1981; Rossiter & Percy, 1987). They may also change how people balance benefits and risks
(Emanuel et al., 2005), including those associated with purchasing and consuming the product.
These generic characteristics of sales promotions were drawn upon to develop the definition of
wagering inducements presented in Chapter One. Two main adjustments were made. While many
definitions of sales promotions emphasise that they are short-term offers, our review of wagering
inducements revealed that many are offered continuously (e.g. sign up bonuses, refer a friend
bonuses, provision of credit for betting, affiliate referral programs). Thus, our definition does not
restrict wagering inducements only to short-term offers, because to do so would exclude many types
of inducements which have been the subject of criticism and concern. Additionally, our definition
unpacks the general goal of promotional inducements (to trigger an immediate or expedited sale), to
recognise that wagering inducements can also aim to increase the number of account holders, retain
existing account holders, prompt brand switching, increase and intensify purchasing, encourage future
purchasing, and encourage betting on specific events, during particular time periods and/or using
particular betting channels. While the ultimate goal is to increase sales, wagering inducements aim for
a variety of consumer responses which should lead to additional sales.
2.4.2 Types of inducements
While types of wagering inducements are examined later, generic examples of inducements used in
sales promotions include price cuts, cash back offers, extra product, higher quality product, extended
warranties, loyalty points, free delivery, free gifts, free samples, product trials, and entry into prize
draws. Inducements may temporarily enhance the product offered, its price or its accessibility, with the
offer communicated through advertising, publicity and/or personal selling. As such, sales promotions
may pervade all elements of the classic marketing mix of product, price, distribution and
communications (Van Waterschoot & Van den Bulte, 1992).
Chandon, Wansink and Laurent (2000) propose that sales promotions can provide consumers with
utilitarian benefits, including monetary savings, enhanced product quality and/or shopping
convenience; and hedonic benefits such as value-expression, entertainment and/or product
exploration. While many wagering inducements offer monetary savings to customers (although
restrictive terms and conditions can limit or negate these), little is known about the hedonic benefits
consumers may derive from them. Raghubir, Inman and Grande (2004) advanced Chandon et al.’s
model (2000) to identify three distinct consumer benefits of sales promotions: 1) an economic benefit
of saving money and the time and effort to make a decision; 2) an information basis that consumers
use as a cue to purchase or a basis to draw inferences about the product; and 3) an affective element
that impacts how consumers feel about their purchasing transaction. Individual wagering inducements
might provide one or all of these consumer benefits.
2.4.3 Consumer responses to inducements
Consumer responses to sales promotions can include brand switching, purchase acceleration,
stockpiling, product trial, repeat and additional spending (Raghubir et al., 2004). Evidence suggests
that different types of promotions tend to elicit different responses. For example, Shi, Cheung and
Prendergast (2005) found that monetary incentives were considered most effective in inducing
purchase acceleration, stockpiling and spending more, while product demonstrations were felt to be
mainly effective in encouraging product trial. In contrast, sweepstakes and games were perceived as
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relatively ineffective. From a review of related research, Blattberg, Briesch and Fox (1995) concluded
that price promotions (temporary price discounts) substantially increase short-term sales, but lower
consumers’ reference point with increased frequency, and therefore erode brand equity and produce
lower sales spikes over time. They also concluded that price promotions increase store traffic and
sales of complementary items.
Responses to sales promotions are also likely to vary depending on the nature of the product or
service being promoted. One study of 175 large-scale grocery sales promotions found that sales
increases were primarily from existing customers (Ehrenberg, Hammond & Goodhardt, 1994).
However, whether this finding holds true for non-essential purchases such as betting products is
unclear. While most wagering inducements target existing customers in the sense that consumers
need to have opened an account with that operator to access the inducement, operators also spend
considerable amounts to acquire new customers. For example, William Hill (2014) reported in
February 2014 that it was spending an average of £299 ($561) to sign up each new customer to one
of its Australian sites (at the time), Sportingbet, Centrebet or Tom Waterhouse.
Additionally, consumer responses to sales promotions may differ for potentially addictive products. As
noted earlier, wagering inducements can be considered as point-of-sale promotions as they are
offered where consumers have an immediate opportunity to purchase (on betting websites and mobile
apps). In relation to alcohol, growing evidence suggests that point-of-sale promotions are positively
associated with drinking and contribute to nurturing a pro-alcohol environment by offering incentives
for consumers to increase purchase quantities (Jones, Barrie, Robinson, Allsop & Chikritzhs, 2012).
Higher binge-drinking rates amongst university students in the United States (US) have been
correlated with point-of-sale alcohol advertising in bottle shops, including promotions offering volume
discounts, price specials or coupons (Kuo, Wechsler, Greenberg & Lee, 2003). An Australian study
found that point-of-sale promotions involving price or volume discounts have a strong impact on youth
and especially encourage increased volumes to be purchased (Jones & Smith, 2011). Overall,
however, surprisingly little research has been conducted into the impacts of point-of-sale promotional
inducements for alcohol, even though research into other types of alcohol advertising is extensive.
Thus, promotional inducements are an under-studied area in both alcohol and gambling research.
More research has been conducted into point-of-sale tobacco promotions, which have been found to
encourage product trial and to increase purchase volume (Gilpin, Pierce & Rosbrook, 1997). In the
UK, smoking status has been correlated with tobacco point-of-sale promotions, including free gifts with
purchases and discount pricing (MacFadyen, Hastings & MacKintosh, 2001). In Australia, adolescents
exposed to tobacco point-of-sale marketing were found to have higher recall of cigarette brands, and
weaker intentions to not smoke (Wakefield, Germain, Durkin & Henriksen, 2006). Further, adolescents
exposed to examples of point-of-sale tobacco advertising were more likely than those exposed only to
a cigarette pack for the same brand to report positive brand user imagery (Donovan, Jancy & Jones,
2002). Point-of-sale tobacco advertising also provides purchase cues to people intending or trying to
quit (Lavack & Toth, 2006). An Australian study found that 25% of adult smokers reported impulse
purchasing and a third of recent ex-smokers reported urges to start smoking after seeing tobacco
displayed (Slater, Chaloupka, Wakefield , Johnston & O’ Malley (2007). A systematic review
concluded that there was ample justification for banning point-of-sale tobacco displays (Paynter &
Edwards, 2009) which has now occurred in Australia. However, caution is needed in extending
findings from tobacco research to gambling, given that tobacco is addictive for all users. While
research into the influence of point-of-sale tobacco promotions on non-smokers may have some
parallels to gambling, research involving (addicted) smokers provides insights that may apply only to
problem/pathological gamblers and those in earlier stages of gambling addiction. Despite these
cautions, the general direction of research into promotional inducements for alcohol and tobacco is
clear: they are associated with increased product trial, increased purchase volume, impulse
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purchasing, stronger brand recall, increased purchase intention amongst youth, and heightened urges
amongst addicted and ex-users.
2.4.4 Benefits of marketing inducements for sellers
Real or anticipated advertising restrictions have been catalysts for increased use of point-of-sale
promotional inducements by the tobacco and alcohol industries (Howard Flora, Schleicher &
Gonzalez, 2004, Lavack & Toth, 2006). Point-of-sale promotions are advantageous to sellers because
they are subject to fewer regulatory controls and oversight than other forms of advertising, and the
adoption of voluntary regulations is rare (Howard et al., 2004). This also appears to be the case for
wagering inducements, as discussed in Chapter Three. With tighter restrictions on gambling
advertising in traditional media and on in-match betting promotions, wagering operators are
increasingly embracing digital advertising (Gainsbury, Delfabbro et al., 2015; Gardner, 2013; Sproston
et al., 2015), including those for promotional inducements which can be accessed through betting
websites and apps.
Point-of-sale promotions are also advantageous for retailers because they target customers at the
place where they can actually buy the product (Howard et al., 2004), thereby increasing the likelihood
of impulse purchasing (Donovan et al., 2002). Wagering inducements also provide this advantage for
operators, but little is known about their influence on impulse betting. Research has found that bettors
shop around for the best bonuses by purposefully comparing offers on wagering websites and apps
(Hing, Cherney et al., 2014b; Hing, Gainsbury et al., 2014). However, no research has investigated
whether and to what extent incidental exposure to these inducements prompts unplanned purchasing.
One study involving a convenience sample of 544 Australian sports bettors found that 30.3% of their
sports bets were reportedly made on impulse before match commencement, and 8.5% of bets were
made on impulse during a match (Hing, Lamont, Vitartas & Fink, 2015b). However, the role of
promotional inducements in triggering these impulse bets was not investigated.
Not all sales promotions are beneficial for retailers. From the seller’s perspective, the overall
profitability of sales promotions is increased only if consumers respond by switching to the promoted
brand, or by buying more of the promoted brand than they would have done without the promotion
(McAlister, 1985). This includes purchases by new users. Conversely, the profitability of sales
promotions is decreased if consumers do not respond to promotions, or respond by purchasing a
branded product that they would have chosen anyway. Thus, marketing inducements aim to attract
new users, prompt brand switching and increase purchasing to enhance the seller’s profitability.
From the perspective of the consumer, overall consumption does not change if only brand switching
occurs in response to a promotion. However, overall consumption increases where an inducement
increases an individual’s purchasing. For addictive products such as gambling, this increased
consumption can have harmful effects if it moves gamblers along the gambling continuum to higher
levels of risk and associated problems. Thus, it is critical to know which types of inducements increase
overall gambling consumption and their potential for shifting gamblers to higher levels of gambling risk.
This is a critical area for future research.
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2.5 How the gambling industry uses inducements to
promote gambling
2.5.1 Types of gambling incentives offered
In its study of gambling inducements offered by land-based venues, the Responsible Gambling
Council (RGC, 2013) identified several types of incentives which may be offered. These include cash,
free gambling credits, and free or discounted accommodation, food, beverages, merchandise and
entertainment (both within and external to the venue), as well as airfares or other transport to and from
the venue.
2.5.2 How gambling incentives are obtained
Three ways in which gamblers can obtain these incentives in land-based gambling venues are through
loyalty programs, comps and promotions (RGC, 2013), with each described below. Of note is that
loyalty programs and comps reward past gambling behaviour and are given to the most loyal
customers; conversely, promotions aim to influence future behaviour and therefore can target the least
loyal customers to encourage venue visitation and expenditure (RGC, 2013). Because of this,
promotional offers are considered the most important type of inducement for venues (RGC, 2013).
Gambling loyalty programs
The RGC (2013) explains that loyalty programs are very common in land-based gambling venues and
seek to both increase customer expenditure and maintain the current customer base through
heightening venue loyalty. Loyalty programs typically award points to patrons based on their gambling
activity, and also sometimes based on their food, beverage, entertainment and other venue
purchases. Points can then be redeemed for services or merchandise, sometimes including gambling
credits, with some programs awarding bonus points for gambling activity above a certain level. Most
gambling loyalty programs are tier-based, with higher tiers offering more rewards. Moving up a tier
requires the accumulation of a certain number of points, and remaining at that tier usually also
requires patrons to continue to earn a minimum number of points during a specified time period. The
RGC (2013) notes that, in Canada, gamblers may have to bet up to CA$35,000 to gain second tier
level and up to CA$400,000 to gain higher tier status. Membership at the highest tier is often by
invitation only, thereby conferring a certain prestige on these members.
Williams, West and Simpson (2012) are highly critical of loyalty programs, particularly in jurisdictions
with a single monopolistic gambling provider where, they argue, these programs simply reward people
for their amount of gambling so as to induce them to gamble even more. While loyalty programs may
be more justifiable as a competitive marketing strategy in jurisdictions with several gambling
operators, Williams, West et al. (2012) argue that they are incompatible with encouraging responsible
gambling behaviour because they promote further gambling and may help heavy and problem
gamblers to reconcile their losses. They are also incompatible with responsible provision of gambling
because operators collect and actively respond to knowledge of gamblers’ betting activity by providing
increasingly strong inducements for further gambling (Williams, West et al., 2012). Similar concerns
were shared by some interviewees in a qualitative study of venue-based responsible gambling
measures involving interviews with 36 venue managers, staff and patrons (Hing, 2007). Interviewees
criticised loyalty systems for providing undue encouragement to gamble through constantly rewarding
the behaviour and for cultivating a community of big gamblers.
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Gambling comps
A second type of reward often offered by land-based gambling venues involves complimentary goods
and services, or ‘comps’, which typically increase with money and time spent gambling. Indicators
which provide the basis of comps can include loyalty points, theoretical loss, or other variables (RGC,
2013). Low value comps, such as free food and beverages, can be provided to patrons irrespective of
their gambling activity; however, high value rewards such as free flights and accommodation are
typically reserved for high rollers. Comps are issued in venues by hosts, and also by mail, email, SMS
and telephone (RGC, 2013).
Gambling venue promotions
In-venue promotions have been a longstanding feature of gambling operations in Australia and
elsewhere. Some in-venue promotions are for rewards club members or venue members only, while
others are available to all patrons. The RGC (2013) notes that these promotions aim to enhance
frequency of venue visitation, gambling revenue and patrons’ venue experiences. Land-based venue
promotions are many and varied, but typical examples include members’ draws to win cash and other
prizes, slot tournaments, and special days (ladies days, senior days) with discount pricing and prize
draws (RGC, 2013). A qualitative study of club members in Australia (Hing, 2005) found that in-house
promotions were criticised as irresponsible because they encouraged patrons to gamble for extended
periods while waiting for prize draws, with winners only able to claim prizes if present in the venue.
2.6 How the wagering industry uses inducements to
promote gambling
2.6.1 Types of wagering incentives offered
No previous research has systematically examined wagering inducements, but a scan of operator
websites indicates that several types of incentives are offered. These include cash (which usually has
to be played through before it can be withdrawn), ‘free’ or bonus bets (which may or may not require a
matching bet), improved odds and winnings, payment or refunds for non-winning bets, reduced
commission on bets, loyalty points, prizes such as merchandise, and awards. Chapter Four presents
results from our audit of 30 wagering operator websites where the types of incentives they offer are
analysed.
2.6.2 How wagering incentives are obtained
Similarly to land-based gambling venue incentives, wagering inducements can be obtained via loyalty
programs, comps and promotions, as described below. Additionally, individuals may be incentivised to
bet through the offer of credit. Affiliate programs incentivise the referral of customers to a wagering
operator.
Wagering loyalty programs
No peer review publications have examined wagering loyalty programs, but some basic information
has been sourced from betting and betting information sites. Gamblingsites.com describes betting
loyalty programs as widely available and aimed at encouraging bettors to continue using a site by
providing on-going rewards to regular customers, including VIPs and high rollers as well as more
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infrequent and lower stakes bettors. Wagering loyalty programs typically reward customers based on
amounts wagered, or sometimes lost, with rewards comprising additional bonuses, cash back or ‘free’
bets. Gamblingsites.com explains that cash-back rewards are typically given at the end of a specified
period (usually one month), with customers receiving back a percentage of their month’s losses, which
they may or may not have to bet through before withdrawing from their betting account. Some
programs provide a cash reward based on amount staked and also sometimes factor in the odds of
these wagers. Together, these are converted to points and redeemed as a bonus at the end of each
month. Instead of cash bonuses, which may be able to be withdrawn without any betting requirements,
some sites reward bettors with ‘free’ bets. For example, points earned in the TAB Rewards program
can be used for free bets, as well as tickets to sporting events, racing hospitality, merchandise, gift
cards and competition entries. Crownbet’s loyalty program is a five-tier program offered in association
with Crown Resorts that enables redemption of loyalty points from Crown’s restaurants, hotels, retail
precincts and gambling products. However, loyalty programs may be less commonly offered by online
wagering operators as they derive less utility from them compared to land-based venues, given that
they already have details of their account holders to inform their marketing.
Wagering comps
The provision of comps for race and sports bets appears to be less common and less generous than
for other types of gambling. Land-based venues operate race and sports books on a commission
basis as agents for the wagering operator. Thus, their profit margins on wagering activity do not justify
the comping of bettors in the same way as for slots or table games bettors. Some casinos therefore
use a club or loyalty card system so that bettors earn points based on their betting volume, although
points earned are typically less than for other gambling forms (Nagel, 2011). It is unclear if and how
comping is offered by online wagering operators, although a review of some betting websites indicates
that free hospitality at major sporting events and other rewards may be offered to big punters. Other
wagering comps appear to be tied to loyalty programs, such as the discounted hotel rates and free
parking offered to all members of Crownbet’s Signature Club, regardless of betting activity.
Wagering promotions
As explained in Chapter Four, our audit of 30 wagering operator websites identified the following types
of wagering promotions:4

Sign up offers

Refer a friend offers

Refund/stake back offers

Winnings paid even if you don't win (e.g. protest payouts, in extra time)

Multi bet offers

Bonus or better odds (not including happy hour type inducements included below)

Bonus or better winnings

Happy hour or similar offers

Mobile betting offers
4
Loyalty programs were not included in our audit as very few wagering operators promote them on their websites. It may
be that customers are advised of loyalty programs after they have opened an account, e.g. through direct emails. As
such, loyalty programs were deemed out of scope for the audit element of the project which is restricted to inducements
presented on operator websites (without opening an account). For the same reason, provision of credit for betting and
affiliate referral programs were not included in the audit.
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
Competitions (where payout is in bonus bets)

Match (or partially match) the stake/deposit (with bonus bets)

Reduced commission

‘Free’ bets (for selected punters)

Other ‘free’ bets (e.g. predict the outcome of a match)

Cash rebates (no play through required)
Hing, Sproston, Brading & Brook
One classification of the above types of promotions is based on whether they are aimed at recruiting
new customers to register for an account or aimed at retaining existing customers as active accountholders (Weibe, 2008). Sign up bonuses and refer-a friend bonuses are clearly registration strategies.
The remainder of the above promotions can be considered retention strategies. Of note is that several
Australian jurisdictions (Victoria, NSW, South Australia and Western Australia) prohibit wagering
inducements aimed at recruiting new customers.
Provision of credit to bet with
Wagering operators can extend credit to their customers through ‘delayed settlement facilities’ which
allow a customer to place bets and reconcile the account later. This typically involves the customer
making an application for credit in increments up to $1,000. Wagering operators also accept payment
from customers’ credit cards. The ability to provide credit and accept payment from credit cards is
contrary to other forms of gambling where credit cannot be provided for gambling and where venuebased ATMs do not enable cash withdrawals from credit cards. These restrictions were introduced in
response to the obvious risks associated with credit betting. The Australian Wagering Council has
signaled that it will be adopting a self-regulatory industry-initiated code of practice which will define the
principles to be adopted by members when providing credit to customers.
Affiliate referral programs
These programs are offered by wagering operators to increase referrals and recruitment of new
account holders. Affiliates provide a link from their website to the betting website and are paid for
customers who click on the link and then open an account with the wagering operator within a
specified time period (usually 45 days). Payment can be a flat fee (e.g. $50 per referral) or a
percentage of the customer’s losses (often 25-30%) over the lifetime of that customer’s betting with
that operator, usually paid per month. The latter option can be particularly lucrative if heavy bettors are
referred. There is no cost to the referrer for participating in an affiliate program. Thus, these programs
incentivise the referral of customers to betting websites, but not the customers themselves, although
the latter can take up sign up offers and receive the associated incentives.
2.7 Influence of marketing inducements on gambling
behaviour
2.7.1 Influence of gambling inducements on gambling behaviour
As reviewed below, a small amount of research has investigated the impacts on gambling behaviour
of inducements provided by land-based venues. These studies have focused on the effects of loyalty
programs, comps and venue promotions. Many of these studies have focused on a single venue and
together have yielded mixed findings, so results to date are inconclusive.
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Gambling loyalty programs
Research into the impacts of gambling loyalty programs has identified limited effects overall, but that
different market segments respond differently. Barsky and Torzov (2010) used panel data from 4,894
US respondents who had recently visited a casino to identify differences in customer segments in their
responsiveness to casino loyalty programs. They found that elite membership creates a very engaged
group of customers; however, other market segments were largely unresponsive. Similarly, Palmer
and Mahoney’s (2005) research found little effect of loyalty programs and that different segments had
widely varying needs. They explained that the large numbers of gambling venues usually available to
consumers, their substantial marketing incentives to attract new customers, and low switching costs
between venues, means that gamblers have reasons and opportunities to patronise multiple venues
and to join multiple loyalty programs. Customer loyalty to one particular venue can therefore be very
difficult to gain.
Gambling comps
Inconsistent results have been found in studies examining the effects of comps on gambling activity.
Studies in individual Las Vegas casinos have found no positive effect on blackjack cash drop from
match-play coupons (Lucas, 2005), no significant increase in individual trip slot volume from a direct
mail campaign with free-play offers (Lucas, Dunn & Singh, 2005), and no effect on the gambling
volumes of slots and table games from complimentary showroom entertainment (Suh & Tanford,
2012). Further, Suh (2012) found that a $50 free-play incentive was more profitable than a $100 offer,
implying that a higher incentive value is not necessarily more effective in increasing slot gaming
volume and coupon profitability. Conversely, two studies have found positive effects of comps on
gambling activity. Suh, Tanford & Singh (2012) found that the incremental gambling revenue from
patrons receiving complimentary meals was much higher than those who paid for meals. Based on
two years of loyalty card data from a US casino, Narayanan and Manchanda (2012) found that
receiving comps was associated with a shorter time between venue visits, and that increased comps
increased both short-term and long-term gambling activity.
Gambling venue promotions
Mixed results have also been found for the effects of in-venue promotions. Two studies have found
that they increase expenditure on electronic gaming machines (EGMs). Research in a Las Vegas
casino indicated that prize draws with higher cash prizes produced higher slot machine volume,
reflecting that these promotions increased sales (Lucas & Bowen, 2002). An Australian survey of 414
respondents aged 60 years and over found that, of those participating in venue promotions (50%),
18% reported usually spending more time, and 14% reported usually spending more money, gambling
on EGMs than they would have done without a promotion, and 8% reported being introduced to
playing EGMs through a venue promotion (Southwell, Boreham & Laffan, 2008). Conversely, another
Australian study (Edelhoff, Grimes & Battista, 2014) found that venue promotions did not affect
gambling behaviour, although the combining of different types of promotions (loyalty programs, trade
promotion lotteries, raffles and bingo) may have obscured results. Amongst the 120 members of six
Australian clubs surveyed, about one-half agreed that these promotions had encouraged them to
become members of the venue; about three-fifths agreed they visited the club more often and stayed
longer due to promotions; and about two-thirds reported spending more money at the club during a
promotion. Higher perceived value of promotions was reported to increase members’ length of stay at
the club, how frequently they visited, and their expenditure in the venue, but not their reported
gambling activities. Use of self-reported data in both these Australian studies may limit the accuracy of
their findings.
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2.7.2 Influence of wagering inducements on betting behaviour
A few studies have examined the self-reported influence of marketing inducements on betting
participation, but none have distinguished the influence of different types of wagering inducements nor
quantified the extent of this influence.
Hing, Cherney et al. (2014b), in an interview study of 50 gamblers from the general population and 31
problem gamblers in treatment, found evidence of increased gambling consumption amongst both
samples in response to bonus offers such as ‘free’ bets and bonus deposits. Several respondents
reported that they found promotions quite influential and would seek them out to take advantage of
‘free’ credits and signed up with multiple operators as a result. While this study revealed limited
reported effectiveness of these inducements in converting non-gamblers to gamblers, they identified
some brand switching amongst existing gamblers and increased gambling in response to promotional
offers. However, their study focused on advertising and promotions for Internet gambling in general,
and so did not yield a clear picture of the specific influence of wagering inducements.
Also in a qualitative study, Thomas et al. (2012b) found that young men in particular reported being
encouraged by online gambling advertising to switch from physical to online betting environments, to
open accounts due to ‘free’ bonuses offered, and to move between sports betting websites to take
advantage of the different incentives offered. Many were reportedly focused on what was on offer,
rather than any long-term risks or consequences. However, whether conversion to online betting and
uptake of these betting incentives affected overall betting involvement amongst these participants was
unclear. Older males were reportedly more circumspect about these inducements, and felt that the
risks of signing up for these offers outweighed any longer-term benefits.
A series of surveys conducted as part of a large Queensland study (Hing, Vitartas et al, 2014a), and
published as several papers (Hing, Lamont, Vitartas & Fink, 2015a, 2015b; Hing, Vitartas et al.,
2014b) highlighted the appeal of sports betting promotions to adults, adolescents and sports bettors.
This study focused on types of promotional techniques (e.g. celebrity endorsement, gambling logos,
stadium signage) rather than types of inducement. However, the study did find that about one-third of
sports bettors agreed that the promotion of special bet offers (e.g. available only to the first 100
callers) during a sporting event encouraged them to bet on the sport to which this inducement applied,
and about one-quarter agreed that it increased the likelihood of them placing impulse bets during a
sports match.
A quasi-experimental stage of the same study (Hing, Vitartas et al, 2014a) also highlighted the greater
importance of type of bet in eliciting the desire to place a bet, compared to type of commentator, type
of promotional technique and type of appeal used. Amongst the types of bet included in the conjoint
design, bets offering a money-back guarantee (if the team bet on lost by 10 points or more) had more
appeal than a traditional bet (on the outcome of the match), an exotic bet (which team would score the
first point in the match), and a micro-bet (which player would give away the next penalty). In fact, the
utility for ‘risk-free’ bets was so strong that all other utilities had little weight in countering its effect. The
authors concluded that this indicates that, in the marketplace, a ‘risk-free’ offer will have very strong
drawing power on bettors and strongly entice them to make a bet.
In Sproston et al.’s study (2015), focus group participants drew attention to promotional inducements
conveyed through direct marketing including by email, SMS and telephone, as well as through mass
media, and also that these promotions increased in the lead-up to major events. They commented on
the pervasiveness of inducements offering matching bets and deposits, refer a friend bonuses, and
‘risk-free’ bets that offered a refund under certain conditions for losing bets. Some participants
commented that ‘risk-free’ bets in particular can create the false impression that winning the bet is a
certainty, and so they can be highly influential in encouraging betting. In fact, while participants
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generally felt that they themselves were not highly influenced by wagering marketing (although they
felt that others were, indicating a third-person effect), promotional inducements were one type of
marketing that was felt to directly influence even their own betting. These promotional inducements
were said to have encouraged some participants to open wagering accounts and others to shop
around for the best incentives, while some participants clearly enjoyed getting ‘free’ bonuses for bets
they placed.
While far from conclusive, the above findings suggest that promotional inducements do have an
influence on betting participation, and in fact may be more effective than other types of wagering
marketing in increasing betting behaviour. However, this influence has yet to be rigorously quantified
and is likely to vary amongst different demographic groups. While brand switching in response to
inducements was reported, there is also self-reported evidence that these inducements increase
betting consumption and impulse betting, especially amongst existing sports bettors who may also
shop around for the best deals. ‘Risk-free’ bets appear to particularly encourage additional betting,
although further research is needed to verify this contention.
2.8 Influence of wagering inducements on gambling
problems
This review now considers the role of wagering inducements in the development and maintenance of
gambling problems. Research into the association between problem gambling and race and sports
betting is briefly reviewed before risk factors for wagering problems are discussed.
2.8.1 Gambling problems associated with wagering
While gambling problems amongst Australians are most commonly linked to EGM gambling
(Productivity Commission, 2010), race wagering has also been strongly associated with problem
gambling. As Delfabbro (2012) points out, both EGM and race betting appear to be similarly risky in
terms of the development of problem gambling when the relative numbers of EGM and race gamblers
in the population are controlled for. In reaching this conclusion, he reviews evidence from several
studies of regular EGM and race gamblers. He cites the Productivity Commission’s national gambling
survey (1999) which found that 23% of weekly EGM gamblers compared to 15% of weekly race
bettors were problem gamblers. Further evidence is drawn from a NSW prevalence study (Dickerson
et al., 1996) where 30% of regular EGM gamblers and 22% of regular race bettors scored as probable
problem gamblers. A New Zealand prevalence study (Abbott & Volberg, 2000) found that about onequarter of regular EGM gamblers and about one-fifth of regular race bettors were lifetime problem
gamblers.
More recent evidence comes from a survey of 4,688 Australian gamblers, weighted to be nationally
representative (Gainsbury, Russell et al. 2015). This analysis found that 31.2% of moderate
risk/problem Internet gamblers and 4.5% of their non-internet gambler counterparts nominated race
betting as the gambling form contributing most to their gambling problems. Also in Australia, the
longitudinal Victorian study found that participation in race betting independently predicted moderate
risk/problem gambling after controlling for occupation, lifetime gambling risk, psychological distress
and depression (Billi et al., 2014). That study also found that 34% of at-risk and problem gamblers
participated in race betting, compared to 16% of the general Victorian population.
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Data on current levels of problem gambling amongst sports bettors are less reliable, given the
relatively recent emergence but exponential growth of this gambling form. Several studies have shown
an association between sports betting participation and problem gambling. A worldwide review of
gambling prevalence studies conducted between 1975-2012 (Williams, Volberg & Stevens, 2012)
revealed that sports betting is one of the gambling forms that is most strongly associated with problem
gambling. Specifically, participation in sports betting was found to be a correlate of problem gambling
in 18 national, 15 US, three Australian and two Canadian studies. Further, sports betting participation
was found to be a predictor of problem gambling in multivariate analyses of large nationally
representative US surveys when participation in other gambling forms was controlled for (Kessler et
al., 2008; Welte, Barnes, Wieczorek, Tidwell & Parker, 2004). Billi et al. (2014) found that 16% of atrisk and problem gamblers participated in sports betting, compared to 4% of the general Victorian
population. However, while these studies point to strong associations between engagement in sports
betting and increased risk of problem gambling, causal evidence is lacking. Stronger evidence is
provided from the weighted online survey cited above (Gainsbury, Russell et al., 2015a) which found
that 16.2% of moderate risk/problem Internet gamblers and 2.6% of their non-Internet gambler
counterparts nominated sports betting as their most problematic gambling form.
Evidence from treatment services also suggests that gambling problems amongst sports bettors are
increasing. One Australian clinic has noted a rapid rise in reported problems with sports betting,
increasing from less than 5% of clients in 2006-07 to 15-20% of new clients by 2010-11 (University of
Sydney Gambling Treatment Clinic, 2011). Similarly, sports betting was the most commonly reported
principal gambling activity for 40% of Internet gamblers attending NSW gambling help services in
2011-12, increasing from 25% in 2007-08 (Hing, Gainsbury et al., 2014). This pattern was reversed for
race betting: 25% in 2011-12 and 36% in 2007-08 (Hing, Gainsbury et al., 2014). Thus, increased
participation and expenditure on sports betting and declines in the same for race betting are reflected
in these help-seeking statistics. Amongst clients to Victorian Gambler’s Help Services in 2012-13, 32%
of Internet gamblers nominated race betting as their primary gambling activity, while 28% nominated
sports betting (Hing, Gainsbury et al., 2014).
2.8.2 Risk factors for gambling problems associated with wagering
Research suggests that there are certain demographic, behavioural and normative risk factors for
wagering-related gambling problems. These are important to consider when assessing the potential of
wagering inducements to contribute to gambling problems.
Being a young adult male has consistently been identified as a risk factor for problem gambling (Billi et
al., 2014; Delfabbro, 2012; Johansson, Grant, Kim, Odlaug & Götestam, 2009; Williams, Volberg et
al., 2012; Williams, West et al., 2012). Thus, the predominantly young male profile of sports and race
bettors indicates that, as a group, they are particularly vulnerable to gambling problems. Some
Australian empirical research supports this heightened vulnerability. Multivariate analysis comparing
non-problem gamblers to moderate risk/problem gamblers in a recent Victorian prevalence study
(Hing, Russell, Tolchard & Nower, 2015) found that risk factors for gambling problems amongst males
included being 18-24 years of age and betting on races or sports (as well as some other continuous
gambling forms). Analysis of nationally representative data from 4,688 Australian gamblers suggests
that young adult males may be particularly susceptible to problem gambling associated with online
wagering (Hing, Gainsbury et al., 2014). Amongst the moderate risk/problem gamblers in the sample,
online gamblers were more likely to be younger, male, married, living in Victoria or Queensland and to
bet on sports, races or poker compared to non-Internet gamblers. Treatment services also report that
young men in particular are increasingly reporting difficulties in controlling their online sports betting
(Blaszczynski & Hunt, 2011).
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Risk factors can also relate to betting behaviours. The Victorian longitudinal gambling study reported a
threshold effect, where PGSI scores increased at a race betting frequency of 1-3 times per month (Billi
et a., 2014). Other studies have found, not surprisingly, that more numerous, frequent and larger bets
distinguish at-risk and problem sports bettors from non-problem sports bettors (LaBrie & Shaffer,
2011; LaPlante, Nelson & Gray, 2014; Xuan & Shaffer, 2009). In-play betting has also been implicated
as a risk factor in several studies examining betting behaviours amongst online sports bettors
(Braverman, LaPlante, Nelson & Shaffer, 2013; Gray, LaPlante & Shaffer, 2012; LaPlante, Schumann,
LaBrie & Shaffer, 2008; Nelson et al., 2008). These types of bets were found to be particularly
attractive to problem gamblers in a study measuring sports bettors’ responses to different message
elements in sports betting promotions (Hing, Vitartas et al, 2014a). In-play betting may be inherently
risky as it provides opportunities for fast-paced continuous betting, and requires quick and perhaps
impulsive decisions without much time for reflection (Nelson et al., 2008).
A further risk factor appears to be the increased normalisation of betting in Australian society.
Participants in Sproston et al.’s study (2015) described how regular discussions and placement of bets
now occur in social and workplace settings, with advertisements portraying gambling as an everyday
activity, an important social lubricant amongst young adult males, and an activity no longer associated
with any social stigma. Survey respondents also noted that sports betting marketing has increased
how much their friends and family talk about sports betting, and their interest, desire and actual betting
on sports. Sports betting appears to be particularly normalised amongst young men. Thomas et al.
(2012b) found a growing sub-culture of sports betting amongst young adult males who reported peer
group pressure to bet in order to fit in with their friends and avoid social isolation. Similarly, Gordon,
Gurrieri and Chapman (2015) researched lifestyle consumption communities amongst 18-30 year old
males in the context of sports betting in Australia. They found that sports betting was embedded in
their everyday lives, a regular feature of their leisure and social interactions, manifest in their subculture and highly normalised. While participants were non-problem gamblers, shared cultural values,
within-group rivalry, loyalty to favoured sports teams, and the desire to display betting acumen, skills
and knowledge drove some risky consumption practices that could provide a pathway to sports betting
problems.
The above findings suggest that wagering inducements that target young adult males, that promote
more frequent, more intense and in-play betting, and that appeal to peer rivalry, sports team loyalty,
peer bonding and betting acumen, may undermine harm minimisation by targeting at-risk groups and
by encouraging risky betting behaviours.
2.8.3 Influence of wagering marketing on gambling problems
associated with wagering
Given the potential for marketing cues to reinforce addictive behaviours (Martin et al., 2013), it is not
surprising that problem gamblers tend to report more stimulus from gambling marketing, compared to
other gamblers (Binde, 2009, 2014; Derevensky et al., 2010; Grant & Kim, 2001; Hing, Cherney et al.,
2014b). In the few studies that have specifically investigated wagering marketing, higher risk gamblers
also report being more encouraged to bet by this marketing than do lower risk gamblers. Sproston et
al. (2015) surveyed a convenience sample of 2,681 Australian adults. Problem gamblers reported
higher exposure to sports and race betting marketing in both traditional and digital media, and more
positive emotional and cognitive responses to it. Higher proportions of problem (71%), moderate risk
(48%) and low risk gamblers (40%) reported being more likely to bet on sports after seeing sports
betting marketing, compared to non-problem gamblers (17%). The same pattern was reported for
likelihood to bet on races after seeing race betting marketing: 67% problem gambler, 47% moderate
risk and 37% low risk, compared to 15% of non-problem gamblers. Schottler Consulting (2012), in a
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weighted sample of 400 New Zealanders, also found that race and sports betting marketing had a
greater reported impact on problem/moderate risk gamblers in terms of making unplanned bets. This
finding applied to all media channels examined.
Focusing only on sports betting, Hing, Lamont et al. (2015a) specifically investigated gambling
marketing during sports broadcasts, including advertisements in commercial breaks and promotional
marketing embedded within match broadcasts. In a sample of 1,000 Queensland adults, the audience
most likely to be stimulated by this marketing were problem gamblers, who had greatest exposure and
a favourable disposition to it, and reported that this marketing had maintained or worsened their
problem gambling behaviours. Surveys with 544 Australian sports bettors also indicated that problem
gamblers had highest approval of these promotions and reported most encouragement and influence
to gamble from these promotions (Hing, Lamont et al., 2015b). Problem gamblers were also more
influenced to sports bet by contextual factors, particularly certain bet types including special offers. A
comprehensive review of gambling advertising research proposed that marketing for new and
relatively risky forms of gambling, such as sports betting, has a larger impact because it accelerates
consumer uptake before adaptation processes have started to work (Binde, 2014).
Overall, these studies have found associations between exposure to sports and race betting marketing
and problem gambling; however, the causal direction is unclear and confounded by the greater
likelihood of high risk gamblers to view more wagering marketing.
2.8.4 Influence of gambling and wagering inducements on gambling
problems
A few studies have provided insights into the relationship between non-wagering gambling
inducements and problem gambling, although most findings have been limited to self-report data and
all have investigated only associations and not causation. Southwell et al. (2008), in their study of 414
older club patrons, found that the self-reported impact of venue promotions on time and money spent
on EGMs was significantly greater for moderate risk/problem gamblers than for lower risk gambler
groups. In a study of 200 EGM gamblers in Australia (Schottler Consulting, 2010), player promotions
and prizes, loyalty points and incentives were predictors of self-reported excitement during EGM
gambling, while loyalty points and rewards were significant predictors of self-reported urge to continue
gambling beyond self-set limits. The author concluded that players may become more excited or
motivated to continue gambling due to these inducements and that their role in posing possible harm
to gamblers needs further research consideration.
Stronger evidence of a link between gambling inducements and problem gambling was provided by
Narayanan and Manchanda (2012). Their analysis of two years of loyalty data from a US casino found
that addicted gamblers (defined as those who increased their gambling amount over time) were twice
as responsive to comps received during a gambling session than the average gambler, both in terms
of amount bet and the number of gambling sessions during a trip. Further, addicted gamblers
receiving these comps were also more likely to bet larger amounts in their next gambling session.
Thus, both a direct and indirect effect of comps was found amongst addicted gamblers. The authors
concluded that comps do affect gambling behavior, they may increase gambling involvement and the
difficulties of controlling gambling, and that casinos focusing on the long-run effects of comps would
logically target addicted gamblers.
Detailed insights were collected during a focus group of eight problem gamblers in treatment and an
international expert stakeholder forum in Canada (RCG, 2013). All focus group participants had
developed a gambling problem before they joined a loyalty program, but subsequently joined as a way
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of recouping some losses. As well as receiving economic benefits such as cash rebates, free play
vouchers, free hospitality, entries into prize draws and gifts, participants reported the hedonic benefits
of ego-enhancement, pride, attention, recognition and feeling special, important or ‘a big shot’. This
ego boost then encouraged them to gamble more to gain higher tier status. Loyalty program members
were said to receive about 100 marketing communications from each program each year, and these
increased after winning large jackpots and on moving to a higher tier. At least one focus group
participant relapsed after receiving these communications, despite having requested that the casino
stop sending them. Participants who had self-excluded automatically started to receive these
communications as soon as their self-exclusion period ended even though they had not applied for
reinstatement.
All of the RGC’s (2013) focus group participants considered that these inducements had impacted on
their gambling. Gambling frequency increased for most due to the added incentive to gamble and the
guarantee of getting something back. Some conditions placed on rewards encouraged them to stay
longer in the venue and to spend more money. For example, some free-play vouchers could only be
redeemed several hours later, or after the person had gambled a specified amount of their own
money. Another reported effect was staying in the venue to redeem free-play vouchers only valid after
midnight, which then allowed access to more cash from ATMs as it was a new banking day.
Reminders that they only had to earn a certain amount of more points by a specified date to reach a
higher tier encouraged participants to gamble more. Some reported that receiving rewards made them
feel as if they had less of a gambling problem, and that it encouraged them to chase losses using the
venue’s money. Overall, many participants reported that these inducements made it more difficult to
manage their gambling, both by enticing them to attend the gambling venue to receive or redeem
rewards, and by encouraging them to gamble once they were there.
The RGC’s (2013) study is also the only one that appears to have collected data on when
inducements are considered to have ‘crossed the line’. Study participants (experts and focus group
participants) identified the following: when inducements encourage gamblers to over-extend
themselves or stay past midnight; when hosts offer incentives to gamblers they suspect may have a
problem; when incentives target vulnerable gamblers; when a patron receives incentives after
choosing to opt out; and when the venue makes personal calls to offer incentives.
Very few studies can shed light on the influence of wagering inducements on problem gambling.
Based on self-report from 544 sports bettors, Hing, Lamont et al. (2015b) found that agreement that
promotion of special bets encourages their betting and impulse betting increased significantly as
problem gambling severity increased. Amongst 31 treatment-seeking Internet gamblers interviewed
(Hing, Cherney et al., 2014b), all participants reported substantial increases in their online gambling
since commencement, and nearly one-half at least partially attributed this increase to advertising of,
and particularly promotions for, Internet gambling. Promotions had increased these participants’
gambling by making the activity more interesting and attractive, by providing inducements to gamble,
and by encouraging chasing losses. Participants who had resolved to control their gambling
particularly disliked these inducements because they triggered gambling sessions and relapses
through reminders to gamble and attractive bonuses. A small minority of interviewees who had
previously suspended their gambling relapsed in response to these promotions. Some explained how
the play through conditions of particular promotions and the difficulty of withdrawing winnings
increased their gambling time and expenditure. The authors concluded that these findings provide
preliminary evidence that promotions for Internet gambling, including sports and race betting
inducements, increase overall consumption amongst a sub-group of problem Internet gamblers. By
invoking uncontrollable urges to gamble, including amongst those attempting to curtail their gambling,
these promotions may maintain and increase problem gambling behaviours and serve to keep
problem gamblers in the addicted stage of consumption.
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In another interview study by the same authors (Hing, Cherney, 2014a), but with a sample of 25
moderate risk/problem gamblers recruited from the general population, excessive and irresponsible
promotions were identified as one of eight factors considered to particularly contribute to loss of
control when gambling online because they were thought to prey on vulnerable people, encourage
excessive gambling, and especially target and appeal to problem gamblers. In relation to wagering
inducements, some participants recounted specific promotions prompting them to gamble more than
intended and to gamble when they otherwise would not have. Online bettors spoke about the huge
volume of promotions received once they opened online betting accounts. For some, the offers of
‘free’ bets, matching deposits and ‘risk-free’ bets were particularly enticing and resulted in them
gambling more than intended.
In summary, while research is in its infancy, the studies reviewed above all point to an association
between gambling/wagering inducements and gambling problems, with qualitative research finding
that problem gamblers themselves report that these inducements encourage them to gamble, increase
the time and money spent on gambling, increase the difficulty of controlling gambling, and provide
triggers for relapse. However, research has not been conducted into causal pathways between
gambling inducements and gambling problems, and the relationship between uptake of wagering
inducements and problem gambling behaviour has not yet been examined. Both of these remain
critical areas for future research.
2.9 Chapter summary

Advertising and promotions for wagering products have intensified in recent years, targeting
young adult males with heavy branding and messages emphasising ease of access, winning,
fun, excitement, low risk, male bonding, power, success, wealth, sexual attractiveness, and
value for money.

A wide range of wagering inducements is offered at point-of-sale (websites and mobile betting
apps) and promoted through other media, including direct electronic marketing.

Wagering inducements aim to increase sales through increasing the number of account
holders, retaining existing account holders, prompting brand switching, increasing and
intensifying purchasing, encouraging future purchasing, and encouraging betting on specific
events, during particular time periods and using particular betting channels.

Gambling and wagering inducements can be classified into loyalty programs, comps and
promotions. Loyalty programs and comps reward past betting behavior, while promotions aim
to increase future betting activity.

Some wagering inducements are aimed at registering new bettors, while others aim to retain
existing bettors. Wagering inducements can also be considered in terms of those that lead to
commencement, continuation or intensification of betting.

Examples of wagering inducements include sign up bonuses, refer a friend bonuses, cash
back offers, multi bet offers, bonus odds, bonus winnings, happy hours, mobile betting
bonuses, click to call bonuses, competitions and loyalty programs. Provision of credit for
betting and affiliate referral programs can also be considered to be wagering inducements.

Promotional inducements for alcohol and tobacco are associated with increased product trial,
increased purchase volume, impulse purchasing, stronger brand recall, increased purchase
intention amongst youth, and heightened urges amongst addicted and ex-users.
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
While far from conclusive, research suggests that wagering inducements do influence betting
participation, and may be more effective than other types of wagering marketing in increasing
betting behaviour. However, this influence has yet to be quantified and is likely to vary
amongst different demographic and gambler risk groups.

While wagering inducements can prompt brand switching, self-reported evidence indicates
that they can also increase betting consumption and impulse betting. ‘Risk-free’ bets and
bonuses with stringent play through conditions appear to particularly encourage additional
betting, although further research is needed to verify this contention.

Wagering inducements that target young adult males, that promote more frequent, more
intense and in-play betting, and that appeal to peer rivalry and sports team loyalty, may
undermine harm minimisation by targeting at-risk groups and by encouraging risky betting
behaviours.

The risk of developing gambling problems linked to race betting is similar to that for EGMs and
problems associated with sports betting are increasing, especially amongst young men.

The few studies conducted all point to an association between gambling inducements and
gambling problems. Problem gamblers report that gambling inducements encourage them to
gamble, increase the time and money they spend on gambling, increase the difficulty of
controlling their gambling, and provide triggers for relapse.

However, research has not been conducted into causal pathways between gambling
inducements and gambling problems, and the relationship between uptake of wagering
inducements and problem gambling behaviour has not yet been examined. Both of these
remain critical areas for future research.

The current study provides a useful foundation for further research by identifying and
analysing promotional inducements offered by the most popular wagering operators accessed
by Australians.
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Chapter Three: Policy Analysis
3.1 Introduction
This chapter reviews Australian and international legislative and self-regulatory approaches to the
proliferation of wagering inducements offered by the growing Internet wagering industry.
Inducements are a form of marketing promotion and are closely tied to advertising. The definition of
inducements used in this study may be somewhat different to the meaning understood by lawyers.
Lawyers tend to view inducements somewhat negatively because of their potential to undermine
consumer protection.
Gamblers are consumers, and entitled to the same rights and protections as are available to
consumers of other products. The United Nations issued the UN Guidelines for Consumer Protection
in 1985. Regulators and the gambling industry generally accept that gambling consumers are entitled
to some degree of consumer protection. Protection of vulnerable groups such as minors and problem
gamblers is also an important regulatory and consumer protection issue.
Australia developed consumer rights through State and Territory consumer protection law and the
Australian Consumer Law 2011(Cth) (that replaced the Trade Practices Act 1974 [Cth]). These
general consumer protection laws prohibit commercial practices that are misleading, deceptive or
unconscionable. They apply to gambling amongst the range of available services.
This chapter firstly reviews the legal landscape, tracking the development of regulatory responses to
the challenges raised by the deregulation of the wagering market and the subsequent proliferation of
wagering marketing, including inducements to bet. Relevant court decisions, government reviews and
responses, and codes of practice are discussed. International developments are then reviewed across
a range of jurisdictions, including the provisions of various initiatives by international industry
organisations. Key policy issues are then discussed, before relevant laws and self-regulatory
measures are summarised. Finally, a range of viewpoints, considerations and options are outlined that
could be considered in any further regulation of wagering inducements.
3.2 The Legal Landscape
3.2.1 Background
The traditional State-based regulation of wagering has been significantly weakened as the industry
has grown both nationally and internationally. The Commonwealth has taken limited steps in
legislating, leaving most regulatory responsibility with the individual States and Territories. The
industry has responded to threats of increased regulation by developing and strengthening voluntary
codes of practice. Likewise, broadcasters and advertisers have taken steps to strengthen their
voluntary codes.
The development of gambling laws has focused on protection of revenue, eliminating criminal
influence and responsible gambling issues, following a different path to mainstream consumer law,
with its emphasis on informed choice and consumer protection. However, Blaszczynski, Ladouceur,
Nower and Shaffer (2005) assert that the primary responsibility of the gambling industry in responsible
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provision of gambling is to provide information to meet the conditions of informed choice and not to
mislead, exploit or take advantage of gamblers.
Mainstream consumer law regulators, such as State and Territory Fair Trading offices and the
Australian Competition and Consumer Commission (ACCC), have shown little interest in consumer
protection for mainstream gamblers, deferring to the specialist gambling regulators. Nevertheless,
consumer affairs agencies have warned consumers against gambling-related products, such as
purchasing expensive software that purports to pick the winners, viewing these as scams rather than a
genuine gambling issue, e.g. ACCC (2015).
The dramatic change in the gambling industry and its approach to marketing in recent years has
brought with it an awareness of the need for informed choice and consumer protection. Developments
in this area have been muddled by the need to address the major issue of problem gambling, and the
two areas remain tangled. Whilst there is an obvious need to promote informed choice and consumer
protection for recreational gamblers, there are also needs in this area for those at risk of developing
gambling problems. Some laws and codes of practice describe their responsible gambling strategies
as consumer protection, while offering little protection to those who do not have a gambling problem.
Concern about wagering inducements has arisen only very recently, as the Internet wagering industry
is very young and competition has only lately become intense. The growth of Internet wagering has
been marked by a progressive shift of control away from the populated States to some smaller
jurisdictions, such as the Northern Territory. As most customers of operators licensed in these smaller
jurisdictions reside elsewhere, the governments of these smaller jurisdictions prefer the self-regulation
model. This is similar to the European situation, where remote gambling operators have mostly
located in small, low tax, minimal regulation jurisdictions.
The State and Territory governments agreed in principle some time ago on the need for a unified
approach to consumer protection issues, but there is still much to be done to put this into practice. The
wagering industry has also called for greater uniformity between the States and Territories over
consumer protection measures, to simplify the regulatory complexities for national wagering operators
that strive to comply with a variety of local laws.
The role of the Commonwealth has grown due to its Constitutional powers over trade and commerce
as well as telecommunications, as wagering increasingly has become a national industry reliant on the
Internet and telephone. The Commonwealth also has power over financial services, which could be
relevant to the control of transfers of money to offshore operators, and over corporations, which could
enable it to take a much greater role in wagering industry regulation.
The Internet has enabled a third force to compete for the wagering dollar, that of international
wagering operators. These operators are outside the jurisdictional reach of Australia. The Interactive
Gambling Act 2001 (IGA) prohibits the provision of gambling services to Australian residents by
offshore operators, but allows Australian-licensed Internet wagering operators to operate legally and
market their businesses. The IGA prohibits unlicensed offshore operators from accepting certain bets
from Australians but does not make it an offence for Australians to place bets offshore. Complaints
about illegal offshore gambling operators can be made to the Australian Communications and Media
Authority (ACMA), which has the power to refer them to the Australian Federal Police. However, no
prosecutions have been instituted under the IGA since its inception.
Interactive wagering services and lotteries can be promoted and advertised by locally licensed
operators within Australia (as they are legal forms of gambling under the IGA). Generally these
wagering operators offer traditional approaches to race betting and sports betting but some, such as
the betting exchange operated by Betfair, offer an entirely new betting model. There are some
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restrictions on local licensed operators, such as a prohibition on in-play betting, that put them at a
disadvantage to offshore operators. The growth of the offshore wagering market has fuelled ongoing
calls from the Australian wagering industry for a lowering of local restrictions, to enable local wagering
operators to compete on a level playing field with the offshore providers.
The Betfair (2008) case was a significant legal development that weakened the ability of individual
State and Territory governments to control the forms of wagering available to their residents. The
basis of the case was Western Australian law which prohibited betting exchanges, preventing Betfair
from marketing its business to Western Australian residents. The High Court held that the law was
unconstitutional as it restricted trade and commerce between the States.
3.2.2 The Australian betting market opens
Betting has always been popular in Australia, commencing with local bookmakers and expanding with
the introduction of the totalisator in the nineteenth century. Illegal off-course SP betting grew from the
1930s to the 1960s, creating problems of corruption and reducing government revenue. State
governments responded by establishing off-course Totalisator Agency Boards (TABs). However, from
the 1970s onwards, gaming machine and casino gambling grew rapidly, while bookmaking and the
TAB’s share of the market contracted. The 1990s saw the privatisation of the main TAB networks, with
Victoria privatising its TAB in 1994. The Northern Territory licensed its first corporate sports
bookmaker in 1992 which then began offering Internet betting in 1996 and other States followed
(AIGR, 1999).
In response to the changing market, the established States sought to prevent interstate bookmakers
from advertising in their State. The NSW Government confidently reported to the Productivity
Commission (1999) that there was a general prohibition against advertising, by print and traditional
broadcast media, the availability of a bookmaker or totalisator in another jurisdiction. But even then it
was apparent that the ban on interstate advertising was under threat from Internet bookmakers who
had no ties to the local racing industry in the larger States. The Productivity Commission (1999) noted
that the location of the bookmaker was becoming largely irrelevant.
Significant differences existed between the States and Territories in relation to regulatory and revenue
issues, and some bookmakers responded by seeking registration in those jurisdictions that offered low
rates of tax and minimal regulatory controls. Due to the reduced levels of taxation, Internet
bookmakers were able to offer better odds, as well as the certainty of fixed-odds betting. Wagering
was only regulated at a State and Territory level until the commencement of the IGA. This
Commonwealth law gave a further boost to the business development of Australian Internet
bookmakers by greatly restricting offshore licenced competitors. Following the Betfair decision, some
States also changed their laws to permit interstate wagering businesses to offer wagers to their
residents, such as the Justice Legislation Amendment Act 2009 (Vic). These developments enabled
the share of the wagering market held by Australian-based Internet bookmakers to grow rapidly,
mostly at the expense of the incumbent State-based totalisators.
However, there are limits to the application of s.92 of the Constitution which establishes that trade
within the Commonwealth of Australia is to be free. In Sportsbet v New South Wales (2012), the High
Court dismissed a challenge brought by a wagering operator against a State fee imposed on
organisations that used race information, on the grounds that both local and interstate wagering
operators were treated equally by the fees so that there was no discriminatory burden of a
protectionist kind.
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This court decision clarifies the limits on the powers of the individual State and Territory governments
to legislate about consumer protection matters affecting their residents. Although there is no definitive
High Court decision on the issue of States restricting the offer of inducements to gamble, it seems
highly likely that such restrictions or prohibitions do not contravene s.92 unless they discriminate
between wagering operators licensed in different Australian jurisdictions.
3.2.3 Reaction to the impacts of change
The rapid growth in the Internet wagering industry was accompanied by a significant increase in the
volume of betting advertising in and around live and televised sporting events. As well, there was a
move from passive forms of advertising, such as advertisements displayed on playing fields and
sportspersons’ clothing, to a vigorous spruiking of the odds of each game by bookmakers, athletes
and sports commentators.
Public reaction to these changes was strong and overwhelmingly negative. The Productivity
Commission (2010) commented that behaviours by gambling operators, through advertising and
promotions, might accentuate consumers’ general vulnerabilities to make impulsive decisions that they
later regret. There were also concerns that the incidence of problem gambling would be exacerbated.
A number of health organisations, including the Australian Medical Association (AMA) and Australian
Psychological Society (APA), called for greater regulation of the marketing of gambling advertising and
promotion, as part of a public health approach to problem gambling (AMA, 2012; APS, 2012, 2013).
At the same time as the community developed a strong concern about the extent of sports betting
advertising, an increased awareness and growing concern has arisen about the nature and extent of
the inducements offered by wagering operators. Often it is the more extreme or novelty inducements
that have attracted the most attention. A Sportsbet promotion offering a $90 cosmetic pack to new
customers who signed up with Sportsbet and bet at least $5 was criticised by the chair of the Victorian
Inter-Church Gambling Taskforce as being aimed at young women who are less likely to gamble,
despite the fact that the promotion was unavailable to Victorian residents (Dow, 2014)
3.2.4 Inducements, problem gambling and the courts
In a series of court decisions from 1999 to 2013 the courts have clarified the legal nature of the
relationship between gambling providers and gambling consumers, particularly problem gamblers.
A series of court cases defined the common law duty of care. In 1999, a NSW District Court judge held
that a hotel was liable under the Commonwealth Trade Practices Act for unconscionable conduct in
trade or commerce by providing illegal cash advances to a problem gambler as an inducement to
gamble. The sentencing judge noted that the prohibition on unconscionable conduct in trade or
commerce was designed to have a broad reach and protect the public from unfair trading (Stefano &
Younes, 2001).
However, it is only in the most extreme cases of gross negligence of the operator (or deliberate
conduct on the part of the operator with knowledge of the vulnerability of the problem gambler), that
there will be any prospect of a successful action (Nettleton, 2012a, 2012b).
In Reynolds v Katoomba RSL All Services Club Ltd (2001), the NSW Court of Appeal held that a
gambling operator owed no duty of care regarding the potential losses of a problem gambler other
than in extraordinary circumstances.
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Litigation between the Commonwealth Bank and IASbet, an Internet bookmaker, was reported
following the arrest and conviction of a former Commonwealth bank manager, Kim Faithfull, who stole
$17 million from the bank and lost it gambling with the bookmaker. The bank sued the bookmaker,
arguing that the bookmaker wilfully shut its eyes to Mr Faithfull’s fraud, or consciously refrained from
inquiry as to the source of funds. The bank alleged that the bookmaker sent lavish gifts to Faithfull at
the branch of the bank where he worked and gave him an invitation to attend the Melbourne Cup as a
guest of the managing director of the bookmaker (Hughes, 2004). The litigation was settled on
undisclosed terms.
In Preston v Star City Pty Ltd (1999), a NSW Supreme Court judge commented that the common law
duty of care would probably extend to a prohibition on providing further liquor to an already intoxicated
problem gambler, or the provision of significant credit facilities, or excessive encouragement through
incentives to a person who has specifically asked to be barred or go beyond a pre-set expenditure
limit.
In Kakavas (2013), a high roller received substantial inducements to gamble at Crown Casino. The
High Court unanimously held that the inducements did not amount to unconscionable conduct,
because Kakavas was not at a special disadvantage, despite being a problem gambler. The court
considered that Kakavas was able to look after himself, and that Crown did not unconscientiously
exploit any disadvantage. The court noted that gambling transactions are a rare species of economic
activity in which each party sets out openly to inflict harm on the other.
The Productivity Commission (2010) concluded that an important underlying factor explaining why
Australian courts have been reticent in finding for a gambling duty of care is the notion of selfresponsibility, namely that gamblers are ultimately responsible for their own actions.
In the future, legal action brought by consumers of gambling products will probably be rare, including
actions for harm that may arise from the excessive provision of inducements.
3.2.5 Government reviews in Australia
Governments have also been aware of the importance of consumer protection in wagering for some
time. At its May 2001 meeting, the Australian Racing Ministers Conference endorsed seven objectives
under the National Guidelines for Responsible Wagering Practices to promote the adoption of
responsible wagering practices throughout Australia and establish uniform standards for such
practices. One objective is to promote informed choice by ensuring that wagering customers are fully
aware of how each betting product operates and their realistic prospects of winning. Another objective
is to require that advertising and promotion be conducive to responsible wagering patterns and
behaviours on the part of the individual bettor (Office of Gaming and Racing, 2006).
Concerns about gambling advertising and promotions have been discussed in several government
inquiries and reports. The South Australian Select Committee on Internet and Interactive Home
Gambling and Gambling by Other Means of Telecommunication in South Australia (Parliament of
South Australia, 2003) noted that there had recently been a focus on addressing some of the potential
social harms that flow from wagering by developing responsible gambling codes of practice and that in
South Australia the Independent Gambling Authority (IGA) required bookmakers to have codes for
responsible gambling and advertising.
In a review of current trends and regulation of interactive gambling commissioned by the Australian
Government, the Allen Consulting Group (2009) noted the growth in advertising of Internet wagering
services and the extensive advertising by Betfair, which was then a new entrant into the market. They
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commented that the extensive advertising by Betfair was criticised by some community organisations
as not protecting underage gamblers from being drawn into sports wagering.
The Productivity Commission inquiry (2010) concluded that online gambling should be legalised to
some degree so that it could be regulated, reducing the potential harms of an illegal and therefore
unregulated industry. However, it questioned the NSW and Victorian bans on advertising promotions
that included inducements to recruit customers saying:
It is not clear why customers attracted by inducements such as free bets are more likely to
develop gambling problems than customers attracted by other advertising strategies. Moreover, a
large number of the customers accessing free bet promotions are likely to be simply shifting from
one wagering provider to another (Productivity Commission, 2010, p.16.58).
The Productivity Commission (2010) suggested that these inducements are partly directed at
overcoming ‘switching costs’ between providers and enhanced competition. They also noted that
punters in the States that prohibit these inducements are at a financial disadvantage compared with
punters in the other States and Territories
The JSCGR inquiry into online gambling and gambling advertising (2011) recommended prohibition of
live odds promotions and advertising directed at children and called for the development of a
mandatory national code of conduct for advertising by wagering providers. The JSCGR (2011)
concluded that inducements to gamble, such offering credit and deposit matching to recruit new
customers, encouraged people to gamble for longer and in some cases, beyond their means. The
JSCGR (2011) was unconvinced that all inducements should be treated as simply standard
advertising practice and recommended that the COAG Select Committee on Gambling Reform, in
consultation with the COAG Legislative and Governance Forum on Consumer Affairs, develop a
mandatory national code of conduct for advertising by wagering providers, including (among other
things) inducements to bet.
The COAG (2011) directive required wagering operators to implement self-regulating strategies within
12 months, warning them that the government would legislate if it was not satisfied with their actions.
The requirements were:

Placement of responsible gambling messages in live sports promotions.

Live odds promotions not be directed at children or be portrayed as a family activity.

Promotions must be socially responsible and not misleading.

Promotions must avoid exaggerated claims, association with alcohol, or with success or
achievement.
On 29 June 2012, the Commonwealth announced that it had secured the agreement of commercial
and subscription broadcasters to reduce and control the promotion of live odds during sports
broadcasts. Broadcasters agreed to amend their existing codes of practice to restrict live odds
promotion, including by banning sporting commentators from mentioning live odds and banning all live
odds promotion during play. There was no mention of the advertising of inducements in the agreement
(DBCDE, 2012).
The JSCGR inquiry into the advertising and promotion of gambling in sport (2013) made a number of
recommendations for tightening restrictions on the advertising and promotion of gambling, with
particular focus on the protection of children. It did not make any specific recommendations regarding
the effect of inducements to gamble as a form of promotion of gambling services, and their impact on
problem gambling, commenting that this was included in the JSCGR (2011) report.
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In Victoria, a review of sports betting regulation (Gleeson, 2011) recommended improving the level of
regulation, greater enforcement of existing legislation, improved integrity assurance and the need for a
nationally consistent approach to best protect the integrity of sport. The Victorian Government agreed
to implement those recommendations which were within its power to implement and to work with other
governments, sporting bodies and the gambling industry to implement the others.
In NSW, the Select Committee on the Impact of Gambling (2014) took evidence regarding ongoing
community concerns about the quantity and content of sports betting advertising, and noted that
ACMA had undertaken to review and evaluate the changes to broadcasting codes so as to ascertain
their effectiveness.
3.2.6 Responses from Australian governments
At the Commonwealth level, a number of bills seeking to regulate or restrict interactive and sports
gambling were considered by the JSCGR in the period from 2010 to 2013. However, the final outcome
was to use the threat of restrictive legislation to motivate the gambling industry to agree to an
enhanced level of regulation, along with tighter restrictions on advertising and promotional rules. The
issue of wagering inducements was referred back to COAG to consider further.
Also at a national level, inducements to bet on sporting events have been discussed both through the
Australasian Racing Ministers Conference and through the National Wagering Advertising Working
Party. At the Australasian Racing Ministers 2008 Conference, State and Territory Ministers indicated
their support for a national approach to prohibiting the advertising of inducements to open new
wagering accounts. At a meeting of the National Wagering Advertising Working Party in December
2010, participants also raised that the definition of ‘inducement’ could be open to interpretation and
suggested a nationally consistent definition be adopted (JSCGR 2011).
At a state level, some States impose a prohibition or restrictions on the provision of inducements to
their residents, as outlined below. There are no prohibitions on licensees offering inducements in
Queensland, the Northern Territory and Norfolk Island.
Victoria
Sign up offers are prohibited in Victoria. The Gambling Regulation Act 2003 (Vic) s.4.7.10, provides
that a wagering service provider must not offer any credit, voucher or reward as an inducement to
open a betting account. This law has been used by the Victorian Commission for Gambling Regulation
(VCGR) to successfully prosecute a number of bookmakers in recent years (Nettleton, 2011, 2012a,
2012b). Two charges issued by the regulator related to:

Sportsbet’s offer of ‘Join now get $100 in free bets on the races’ and ‘Up to $200 free bet for
first time deposits’, and

IASbet.com’s offer of ‘$1000 free – 15% sign up bonus’.
Sportsbet and IASbet defended the charges on the basis that there was ambiguity in the word ‘offer’.
However, the sentencing magistrate held that these were firm offers, not invitations to treat, and
therefore the law had been broken. The process of accessing or downloading the websites, by the
consumer, from information on servers in the Northern Territory where Sportsbet was licensed still
amounted to the making of a prohibited offer. The offence was the making of an offer to a person in
Victoria, which occurred when the material was downloaded. An offence was still committed, even
though the offer was subject to conditions such as the consumer being over the age of 18, providing
an address and first making a deposit into a betting account.
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The VCGLR has conducted a small number of prosecutions since then, including Betfair, which was
convicted and given a good behaviour bond on 21 May 2013 and Betezy, which was fined $6,000 on
23 May 2014 (VCGLR, 2014).
South Australia
Sign up offers are prohibited in South Australia. In 2012 the South Australian Independent Gambling
Authority conducted a review of its codes of practice and issued a detailed mandatory Gambling Code
of Practice (2013) prohibiting gambling providers from offering or providing any inducement directed at
encouraging patrons to gamble or directed at encouraging people to open gambling accounts. The
prohibition does not apply to the offering or provision of an acceptable loyalty program or the offering
or provision of an acceptable trade promotion lottery of a complimentary gambling product.
The Authority has also specified detailed requirements for advertising, the provision of responsible
gambling information and warnings. The Authority has made it clear that it requires interstate betting
operators to apply for a dispensation from the advertising restrictions when advertising in South
Australia. Dispensations are provided when the Authority is satisfied that the advertising will not be
incompatible with family time or that the dispensation is otherwise in the public interest (Free TV
Australia, 2010, 2014a, 2014b).
Queensland
The Policy Direction for Gambling in Queensland (Queensland Government, 2000) envisages a
shared commitment by gambling industry providers to the guiding principle of ethical and responsible
behaviour that is consistent with the voluntary Queensland Responsible Gambling Code of Practice
(Queensland Government, 2015). The code of practice sets out a comprehensive list of requirements
including the provision of product information, responsible gambling information, help service contact
details, self-exclusion, complaints handling procedures and responsible advertising standards.
Provisions relevant to inducements include requirements that advertising and promotions do not give
the impression that gambling is a reasonable strategy for financial betterment, do not offend prevailing
community standards and do not involve any irresponsible trading practices by the gambling provider.
New South Wales
NSW prohibits inducements. The Racing Administration Regulation 2012 s.12(1)(h), makes it an
offence to offer any credit, voucher or reward as an inducement to participate, or to participate
frequently, in any gambling activity, including inducing a person to open a betting account.
Norfolk Island
The Norfolk Island Gaming Authority website information (2015) claims that its regulatory and
supervisory approach meets the very highest of international standards. However, the Norfolk Island
Gaming Act 1998 does not have any consumer protection provisions that would be relevant to the
offering of inducements to gamble.
Northern Territory
The provision of inducements is permitted in the Northern Territory. The Code of Practice for
Responsible Gambling (Northern Territory Government, 2003) requires gambling operators in the
Territory to ensure that any advertising or promotion is delivered in an honest and responsible manner
with consideration given to the potential impact on people adversely affected by gambling. Gambling
providers must also provide responsible gambling information, self-exclusion and a complaint
resolution mechanism.
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Crundall & Boon-Ngork (2005) reviewed compliance with the code in 2004, identifying Internet sports
bookmakers as 87% compliant. Major areas identified for improvement were adequate displays of
information about the risks of problem gambling, display of a responsible gambling mission statement,
ensuring patrons were aware of the passage of time, and having problem gambling warning signs at
the point of sale. It was noted that some of the items in the code of practice had little relevance to the
online wagering business.
Internet bookmakers are not allowed to verbally urge non-gambling Northern Territory residents to buy
gambling products but are able to use telemarketing elsewhere in Australia. A few years ago,
Sportsbet was criticised for sending SMS messages to random mobile phone numbers, offering $60 in
free bets provided the recipient opened an account. Concerns were raised about the making of these
offers to minors and problem gamblers and the general nuisance of cold call selling. The practice was
reportedly discontinued (Santow, 2008).
Tasmania
In Tasmania, the Responsible Gambling Mandatory Code of Practice (Tasmanian Gaming
Commission [TGC], 2012) prohibits operators from offering inducements that may lead to problem
gambling or exacerbate existing gambling problems. This includes persuading people to gamble when
they would not gamble normally or to gamble outside of their normal gambling patterns. Inducementbased sponsorships with sporting bodies are also prohibited.
Betfair (2012), in its submission to the TGC, urged the TGC to legislate for a level playing field
regarding the ban on inducements, and asked that any restrictions only apply to locally licensed
wagering operators in their dealings with Tasmanian customers. It also argued against the prohibition
on incentive-based sponsorships, claiming that it was uneconomic for a wagering operator, such as
itself, to provide up-front financial support, due to the lack of certainty regarding returns, and that
therefore a revenue sharing arrangement was the best model for both the sponsor and club itself.
Western Australia
Western Australia prohibits advertising that offers a benefit, consideration or reward in return for the
person participating in gambling; or continuing to gamble; or opening a betting account with the
operator (s.43(2)(e) Gaming and Wagering Commission Regulations, 1988).
Australian Capital Territory
The ACT Gambling and Racing Control (Code of Practice) Regulation 2002, reg. 1.30, states that the
licensee of a gambling facility must not conduct a promotion that requires or encourages people to
gamble at the facility for a minimum period of time to qualify for rewards; or conduct a promotion that
requires or encourages people to gamble a minimum amount to qualify for rewards.
3.2.7 Codes of practice and codes of conduct
Codes of practice (expressed in this report as including codes of conduct) may be either mandatory,
co-regulatory or self-regulatory. Mandatory codes are legislated and imposed by governments. Coregulatory codes are intended to develop a shared understanding between government, community
and industry. Self-regulatory codes are developed and enforced solely by industry (Fogarty & Young,
2008). Self-regulation through codes of practice benefits industries as they are more flexible than
legislation to meet changing needs, they are less intrusive than legislation, participants have a greater
sense of ownership and they act as a quality control benchmark for industry (Consumer Affairs
Victoria, 2015).
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The Productivity Commission (1999) compared mandatory codes of practice imposed by
governments, and voluntary codes of practice. Legal sanctions, such as criminal prosecution, may
result when a mandatory code of conduct is breached. Voluntary codes of conduct have more gentle
consequences, such as possible expulsion from an industry body. Gambling and sporting
organisations often have their own voluntary codes of practice, such as Greyhound Racing Victoria
(2015). There are also codes of practice for broadcasting and advertising which are registered with
ACMA.
Mandatory codes aim to balance operators’ legitimate use of inducements and other marketing
incentives from irresponsible behaviours that are likely to cause harm (such as appealing to minors or
encouraging loss chasing). Wagering operators seeking to differentiate themselves from competitors
and to attract customers may use forms of advertising inducements that could be considered
irresponsible. For example, a promotion that encourages people to gamble by requiring them to spend
a minimum amount within a relatively short period of time to qualify for rewards would be of concern
(JSCGR, 2011).
There are mandatory codes of practice in the Northern Territory, South Australia, Tasmania and the
Australian Capital Territory. Victorian licensed gambling operators are required to have an approved
code of conduct, such as the Victorian Bookmakers Association Generic Code of Conduct (2009) and
the TABCORP (2012) Wagering Responsible Gambling Code of Conduct. Queensland has a coregulatory, voluntary code, while the other jurisdictions rely upon legislation and voluntary codes to
regulate Internet wagering.
Codes of practice mostly provide a range of commitments that benefit gambling consumers, that
typically include:

A general commitment to the responsible provision of wagering

A detailed list of advertising restrictions

A general commitment to adhere to the principles of responsible conduct of gambling

Self-exclusion

Exclusion of minors from gambling

Complaints mechanism

Compliance with legal requirements

Provision of consumer information

Staff training
Some codes of practice state a commitment of relevance to the issue of inducements. For example,
the TABCORP Wagering Responsible Gambling Code of Conduct (2012) states that any advertising,
marketing or promotion does not offer any rewards, inducements or vouchers that encourage
customers to bet more frequently. Greyhound Racing Victoria (2015) says that that it will ensure that
there are no inducements or promotions which could encourage irresponsible or excessive wagering
by a consumer. All Australian wagering sites have responsible gambling information. Some state
limitations on inducements in their responsible gambling webpages and others in their terms and
conditions.
Independent evaluation of compliance with a voluntary gambling industry or organisational code of
practice may be required or facilitated by a government body and, in rare cases, the organisation may
voluntarily commission an evaluation of its code compliance. Perhaps the most important incentive for
compliance is the reputation of the industry body or individual operator concerned. The reputation of
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an industry body or individual operator is vital for ongoing governmental support and customer
patronage. The recent live-baiting scandal has caused immeasurable damage to the greyhound racing
industry and the wagering industry is very conscious of public sensitivities.
3.3 International Developments
3.3.1 Accessing offshore Internet wagering
There is no difficulty for Australians in finding offshore Internet wagering providers, opening accounts
and accessing their inducements. The Allen Consulting Group (2009) noted that in 2004 all major
search engines (including Google and Yahoo!) introduced a global ban on gambling advertisements
on their sites, meaning that no sponsored links to gambling pages would appear on their search
pages. This was believed to be in response to warnings from the US Department of Justice. However
Google chose to lift this ban in some jurisdictions, beginning with the United Kingdom (UK) in 2008,
and now hosts gambling advertisements in many jurisdictions, including Australia.
3.3.2 International directions
Internet gambling is legal to varying degrees in most of the European Union (EU). Some of the smaller
EU members, such as Malta and Gibraltar, have taken the initiative to license Internet gambling,
taking a light regulatory approach and attracting many operators.
Although online wagering is available in most countries, few governments have considered the impact
of promotional activities such as wagering inducements in any detail. Some countries, including the
US, New Zealand, China, Japan, Vietnam, Indonesia and Singapore have prohibited online gambling
(although some have exemptions) (Moisan. 2015). Europe, particularly the UK, has moved to legalise
and regulate online wagering.
The Allen Consulting Group (2009) identified payment blocking, ISP blocking, advertising restrictions,
direct enforcement measures, diplomatic pressure and international cooperation as potential
measures to limit the unlawful provision of online gambling services. The Allen report grouped
international online gambling regulation models to include:

Monopoly markets in Norway, Sweden and Finland where a broad range of gambling products
is offered.

The free market approach to the regulation of online gambling in the UK.

Ringed fenced markets, where a more restrictive approach is adopted through regulating
Internet gambling at the point of consumption, taxes are imposed, and players and operators
are protected from black market offerings.

Offshore licensing where some of the world’s largest online gambling companies hold licences
in one or more of these jurisdictions and target customers and revenues from outside of these
jurisdictions.

Fully restricted Internet gambling adopted in Germany and partially restricted gambling in the
US.
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3.3.3 Europe
The European Parliament has not passed a uniform law for gambling regulation, due to the wide
variation in approaches taken by its member nations. The European Commission (2011, 2011), a
government agency, noted that there are two broad models of national regulatory frameworks in
Europe for gambling, being licensed operators in a strictly regulated framework and also some strictly
controlled monopolies.
In 2011, the Commission sought feedback on consumer issues including inducements, which it
described as ‘sales promotions’, saying:
Sales promotions cover discounts of all forms; premium offers, free gifts, promotional contests
and promotional games. They are an important multi-faceted tool that can be adjusted to various
circumstances: to enter into markets with innovative products; to encourage customer loyalty; to
stimulate short-term competitive actions; or to rapidly respond to lost sales. One of the most
common type of sales promotions are the use and communication of registration and deposit
bonuses, i.e. where on opening a player’s account a sum of money is paid or extra funds are
added to deposits made by an already registered customer.
The European Commission’s public consultation identified the protection of consumers of online
gambling, including minors, as a priority area (European Commission, 2014).
On 10 September 2013, the European Parliament passed a resolution, calling for common principles
for responsible commercial communications in online gambling. It said that commercial
communications should be neither excessive nor displayed on content targeting minors.
On 15 July 2014, the European Commission (2014) made a Recommendation to its member States
for consumer protection of online gamblers, stating that commercial communication, including
advertising and sponsorship, should be carried out in a responsible way. The Commission noted that
‘misinformed choices can be made where information is not sufficiently clear or transparent. In
addition, online players look for competing gambling opportunities whenever they perceive a lack of
attractive offers’ (Recital 10). The Commission noted that general EU law already provided some
consumer protection for online gamblers, including the Unfair Commercial Practices Directive and the
Unfair Contract Terms Directive.
The Recommendation was intended to assist EU member states work towards uniformity of
regulation. Online gambling operators established in the EU increasingly hold multiple licenses across
several member states which have chosen license-based systems for gambling regulation. The
multiplication of compliance requirements unnecessarily increases the administrative burden on
regulators. A uniform regulatory approach would also benefit the licensed operators and improve their
competitiveness against unregulated online gambling sites (European Commission 2014).
Also of relevance is that the Audiovisual Media Services Directive (2013) states that the law of the
country where the transmission of audiovisual media originates (within the EU) is the applicable law.
Additionally, the Unfair Commercial Practices Directive (UCPD, 2005) encompasses gambling
activities in its regulation of advertising and marketing practices. Gambling advertising will contravene
the UCPD if it is contrary to the requirements of professional diligence or it is distorting the economic
behaviour of the average customer or a clearly identifiable group with an underlying vulnerability, such
as young persons, where the gambling provider can reasonably expect such a distortion. Misleading
and aggressive commercial practices are also prohibited.
It is up to the individual member countries of the EU to decide whether to adopt these measures into
their national regulatory frameworks.
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3.3.4 United Kingdom
The UK has legalised online wagering, subject to licence conditions, regulations and codes of practice.
The UK Gambling Commission (the Commission) is responsible for regulating online gambling
pursuant to the Gambling Act 2005, which commenced in 2007. It licenses gambling operators, sets
licence conditions, establishes gambling codes of practice and conducts enforcement of gambling law.
The Advertising Standards Authority (ASA) investigates complaints about advertisements, which are
alleged to be in breach of the Committee of Advertising Practice (CAP) and Broadcast Committee of
Advertising Practice (BCAP) codes (2014. Where complaints are upheld, the ASA requires
advertisements to be amended or removed. The advertising codes apply to all gambling operators,
including remote operators and advertisers permitted to advertise in Great Britain. The aim of the
codes is to ensure that gambling advertising is socially responsible. Guidance for operators as to what
is socially responsible behaviour can be found in the Gambling Industry Code for Socially Responsible
Advertising (UK Gambling Commission, 2007).
In 2010, the ASA’s Gambling Advertising Survey (2010) found that the majority of advertisements in
breach of standards offered free bets unfairly. Typical problems include not letting customers know
that they might have to deposit their own money, or failing to inform customers that if they won, their
‘free’ stake would not be returned to them. A recent review by the ASA (2014) found that the number
of complaints about gambling advertising was rising, both general complaints about gambling
advertising, and complaints about specific ads, particularly those advertising ‘free bets’ and other
promotional offers. Regular gamblers were critical of ‘free bet’ offers, believing they were likely to
appeal to younger people and prompt them to gamble, a view broadly supported by both qualitative
and quantitative data.
The gambling industry also has its own voluntary code, the Gambling Industry Code for Socially
Responsible Advertising (UK Gambling Commission, 2007), which prevents gambling products
(except bingo advertising) from being advertised on television before 9 pm, but with an exemption for
the advertising of sports betting around televised sporting events. From 1 October 2014, four leading
gambling companies, William Hill, Ladbrokes, Coral and Paddy Power, committed to a voluntary ban
on advertising sign up offers (free bets and free money) on TV before 9 pm (ASA, 2014).
In March 2015, the UK Gambling Commission (2015) announced that it would take active steps to
require all remote gambling operators that operate in the UK to apply for an operating licence, and
provide a detailed application with information about the business, finances, integrity, ownership,
compliance, and more. Lack of compliance may result in financial penalties or suspension of the
licence.
3.3.5 Denmark
Online gambling, including wagering, casino games and poker, was legalised in Denmark on 1
January 2012, and is regulated by the Danish Gambling Authority. Denmark permits the advertising of
gambling inducements, described as ‘bonus offers’, but subject to highly detailed requirements.
Essential conditions, such as benefits and restrictions, must be included in the first presentation or
mention of the inducement, and not simply located elsewhere among the fine print conditions (Danish
Gambling Authority, 2015a). These are examples of essential conditions:

The bonus only applies to a limited group, such as a bonus which only applies to new
customers.

Deposit requirements apply to receive the bonus.
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
Play through requirements apply to receive the bonus, including information about which bets
count in the play through.

Time limits in order to receive the bonus, such as the expiry of the bonus, or requirements of
play through within a specified period.
The Danish Gambling Authority (2015a) prescribes model wording for advertisements on TV, radio,
text messaging, banner ads, email, websites and print media. The directions require the inclusion of
as much of the essential conditions with the advertisement as is practicable, with easy access, such
as a direct Internet link to the full terms of the inducement. Gambling operators have the opportunity to
ask the Danish Consumer Ombudsman for an advance opinion as to the lawfulness of a contemplated
marketing campaign.
On 18 May 2015, the Danish Gambling Authority (2015b) announced that it would apply the EU Unfair
Commercial Practices directive (2005/29/EC) to sales promotion measures for gambling products.
This change was the result of the number of complaints that the Danish Gambling Authority had
received about gambling license holders’ sales promotion measures, specifically competitions with a
purchase condition.
3.3.6 Germany
The global law firm DLA Piper (2013) reports that the Interstate Treaty on Gambling, which
commenced at the beginning of 2012 heavily regulates gambling advertising in Germany.
Advertisements must be consistent with the Treaty requirements, including combatting gambling
addiction, preventing fraud and protecting minors. Gambling operators face a fine line between
promoting their own product and not making their product look excessively attractive. Advertising
guidelines specify what and when gambling advertisements are acceptable. Pre-approval of
advertising material from the regulator is required.
3.3.7 Italy
DLA Piper (2013) reports that Italian advertising regulations prohibit gambling advertising via press,
TV, radio and the Internet that can create an incentive to the gambling activity or to exalt games. The
very broad wording might include any type of gambling advertisement, which concerns gambling
operators as the maximum fine for violation is €500,000.
3.3.8 Small jurisdictions
Many offshore Internet wagering operators seek licensing in small jurisdictions such as Kahnawake,
Malta, Gibraltar, and Vanuatu which offer low rates of taxation and minimal regulation.
The Mohawk Territory of Kahnawake is located in Canada and the Kahnawake Gaming Commission
licenses Internet wagering operators. Its Regulations Concerning Interactive Gaming (1999) set out
the consumer protection matters. The Regulations empower the Commission to determine if an
advertisement or form of marketing is based on fact, and is not false, deceptive or misleading in a
material way.
In Malta, wagering is regulated by the Malta Gaming Authority that has a basic level of regulation.
There are restrictions on advertising in the Remote Gaming Regulations (Malta Gaming Authority,
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2004) but little that would be applicable to inducements. The Authority will receive and process
complaints against licenced operators.
Gibraltar is a leading remote gambling licensing jurisdiction. The Generic Code (Gibraltar Gambling
Commissioner, 2012) sets out the basic licence conditions, including basic advertising restrictions, a
requirement that the rules be readily accessible to customers, and that a complaint-handling process
be made available.
Vanuatu is an island nation located 1,750 kilometres east of northern Australia in the Pacific Ocean.
Online gambling in Vanuatu started in 1999 and attracted a number of online casinos in 2003 as some
Australian based Internet gambling companies moved offshore to avoid the impact of the Interactive
Gambling Act (Gamble Worldwide.net, 2015). Betjack is licensed in Vanuatu, which appears to have a
minimal regulatory regime. A recent media report claims that police raided Australian properties
connected to Betjack, seizing computers and financial records. The report says that Betjack is
suspected of links with organised crime (Bucci, Bartley McKenzie, 2015).
No small jurisdiction imposes a rigorous consumer protection regime. The small jurisdictions mostly
leave it to the Internet wagering operators to self-regulate.
3.3.9 International industry and organisational initiatives
Many international Internet wagering operators, particularly those based in Europe, subscribe to codes
of practice or other consumer protection frameworks.
The CEN Workshop Agreement (2011) incorporates a set of 134 consumer protection measures for
remote gambling operators in the EU. It was developed by a workshop of experts and representatives
from government and the gambling industry. The Agreement is an unofficial document available for
voluntary adoption by remote gambling operators. The responsible gambling measures include
responsible marketing, fair gaming, prevention of underage gambling and protection of vulnerable
customers. The provisions include:

Advertisements should contain factually correct information and should not be false or
misleading, particularly with regard to customer winnings.

Advertisements should not entice underage individuals to gamble, and should not be
displayed in media that is clearly targeted at underage individuals.

Customers should not be encouraged to chase their losses or re-invest their winnings and at
no time should it be suggested that gambling is a means of solving financial difficulties.

Advertisements and promotional content should be within the spirit of responsible gambling.

Terms and conditions applicable to promotional activities should be clearly displayed, date
and time stamped, and should not be unreasonably altered subsequent to the wagering
activity.

Direct advertisements and promotional communication should carry an age restriction warning
where practical.

Email, SMS and bonus advertisements should have an unsubscribe, or opt out, facility.

Operators should ensure that an affiliate and/or third party performing advertisements on their
behalf is aware of and is willing to take appropriate steps to abide by the same measures.

An independent third party should be available for mediation or resolution of disputes.
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The European Gaming and Betting Association (EGBA) (2015) is an organisation of gambling
operators licensed in the EU. It seeks to promote a safe and reliable European online gambling market
with a high level of consumer protection. All EGBA members are audited on their compliance with the
CEN Workshop Agreement.
The Remote Gambling Association (2015), another industry organisation which is focused on the UK,
has adopted the CEN Workshop Agreement and also has its own Social Responsibility Code.
A number of remote wagering operators arrange for auditing and accreditation by eCOGRA, a
London-based online gambling compliance and certification organisation. Display of its Safe and Fair
Seal on a website provides assurance to consumers that the operator has passed its annual onsite
compliance review. eCOGRA’s Generally Accepted Practices (eGAP) (2014) are designed to achieve
player protection, fair gambling and responsible conduct without unnecessarily placing constraints on
business operations. There are no specific constraints on inducements, although one compliance item
requires advertising and promotional content to be within the spirit of responsible gambling.
The Interactive Gaming Council (IGC; 2005) is a non-profit trade association based in Canada, and
claims to champion initiatives that address the multi-various challenges and opportunities facing the
Internet gambling industry, in order to ensure an environment of fair and responsible gambling. The
IGC Advertising Code of Practice states that a Member’s website must contain clear information about
the requirements for any promotional campaign, including a link to the applicable terms established for
each specific promotion. The IGC will also accept and investigate complaints about members.
The Global Gambling Guidance Group’s (G4; 2014) e-Betting Code of Practice contains general
requirements about responsible gambling aspects of advertising but no specific references to
promotions or inducements.
The International Association of Gaming Regulators (IAGR), an organisation of regulators from a
number of countries and states, issued model eGambling guidelines (2008) for adoption by
jurisdictions that licence Internet wagering. The eGambling guidelines state that terms and conditions
and general information provided to the customer must be easily accessible and stated in a clear and
intelligible manner. Where it is not possible to present the full terms and conditions to the customer at
the point of registration, for example, for telephone betting, customers must be provided with easy
access to the operator’s terms and conditions. The IAGR also considered that normally customers
must be able to withdraw deposits from their account at any time. There must be an effective
complaints system. Socially responsible measures should apply to advertising and marketing.
3.4 Policy Issues
3.4.1 Terms and conditions of inducements
The JSCGR (2011) observed the importance of reading the fine print terms and conditions to
understand inducement offers, as the details are not usually presented in the advertisements. Few
jurisdictions or codes of practice include specific requirements regarding the provision of the terms
and conditions of inducements in a readily accessible and easily read form. Denmark has the most
prescriptive approach in requiring essential conditions to be displayed with the advertisement when
possible, or with direct links when space is limited. Although some of the codes of practice state that
terms and conditions are to be clear and accessible to consumers, the reality is that essential terms
and conditions are rarely provided in full with the inducement advertising.
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The audit of inducements (Chapter Four) found that the majority of inducements displayed a number
of associated terms and conditions or provided a hyperlink to the terms and conditions. However,
many others did not provide easy access to the terms and conditions, with the worst group simply
referring to the company’s general terms and conditions. General terms and conditions often ran into
hundreds of pages, expressed in legal terminology. The complications multiplied when the incentives
involved the provision of bonus bets, which were themselves subject to a separate raft of terms and
conditions.
It is not surprising that some wagering consumers feel misled by inducements when the conditions are
not easily accessible. There is a clear need to develop a minimum standard for the acceptable
presentation of the terms of inducements.
3.4.2 Broadcasting and advertising
Broadcasters have self-regulated for many years, with governmental support. In response to
government pressure, the broadcasting and advertising organisations in Australia strengthened their
voluntary codes of practice to limit the proliferation of gambling promotions during and around sporting
events. These included amendments to the Commercial Television Code of Practice, Commercial
Radio Australia Codes of Practice and Guidelines, and Code of Ethics of the Australian Association of
National Advertisers.
The revised version of the Commercial Television Code of Practice incorporates provisions relating to
gambling advertising that were strengthened in response to community concerns about gambling
advertising. The old version of the code simply provided that gambling advertising must not be
broadcast in G classification periods Monday to Friday, nor on weekends between 6.00 am and 8.30
am, and 4.00 pm and 7.30 pm. However, gambling advertising was permitted during news, current
affairs and sports programs, and lottery and keno advertisements are exempt. In 2013, a new section
was inserted into the code imposing detailed new restrictions on the promotion of odds and
broadcasting of betting advertising before, during and after live sporting events. Clause 8.10 of the
code requires betting advertising to be socially responsible and to not mislead or deceive the
audience. A responsible gambling message is required to be included with the advertisement.
The Australian Association of National Advertisers (AANA) brought in a new Code of Ethics at the
beginning of 2012 that requires its members to comply with the Prevailing Community Standards as
determined by the Advertising Standards Board. The Advertising Standards Board membership
reflects a wide range of community interests.
In December 2012, a Sportsbet advertisement was held to be in breach of section 2.6 of the AANA
Code of Ethics (Advertising Standards Board case no. 0476/2012). Section 2.6 of the AANA Code of
Ethics provides that advertising or marketing communications should not depict material contrary to
prevailing community standards on health and safety. The advertisement featured a mobile banner ad
with the text ‘Bet on every race, every day, from your mobile’. The Board noted that there is a genuine
community concern around gambling and any portrayal that encourages excessive gambling. The
Board agreed that the availability of a mobile phone app for the purposes of gambling is not of itself
encouraging excessive gambling. However, a majority of the Board considered that the phrase was
suggestive of frequent and continual betting and encouraged excessive gambling. Sportsbet
voluntarily withdrew the advertisement.
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3.4.3 Complaint resolution
An accessible, convenient and fair complaints resolution mechanism is an important consumer
protection measure. Stakeholders generally acknowledge the importance of consumer protection, and
many of the governmental and self-regulatory regimes provide for a specific complaint resolution
process. The availability of a complaints resolution process should be advertised on the operator’s
website.
Typically complaints are first made to the operator, which will investigate and determine the complaint
internally. In some cases, a dissatisfied complainant can then apply to a third party to have the
complaint considered, such as a government regulator, industry body or independent arbitrator. The
availability of a complaints resolution process is relevant to the issue of inducements, as terms and
conditions are often complex, and consumers may become dissatisfied.
The IAGR (2008) recommends that operators provide information on their website about their
complaints procedure, including how to make a complaint against the operator and provision for
adjudication of complaints by the regulator or an approved third party.
The Independent Betting Adjudication Service (2015) is an independent organisation based in London
that is used by a large number of offshore wagering operators including 10Bet, Betfair.com and Stan
James. It will determine consumer complaints made against member organisations when customers
are dissatisfied with outcomes from internal dispute resolution. The service is free to applicants and
offers procedural fairness, objective standards and confidentiality.
3.4.4 Credit
The provision of credit or delayed payment of betting accounts may be considered an inducement to
gamble. The JSCGR (2011) was unconvinced that all inducements should be treated as simply
standard advertising practice, referring to the case of a Melbourne man with a mental illness who ran
up $80,000 in debts with Sportsbet. The JSCGR noted that the case demonstrated the danger of a
combination of free bets and credit.
The provision of credit by bookmakers was established in the on-course bookmaking era, when the
presence of pickpockets at racecourses made it hazardous to carry large amounts of cash. There are
now many quick and safe methods of transferring funds to an Internet wagering operator anywhere in
Australia or the rest of the world. The provision of credit or delayed payment of betting accounts is
sometimes justified by the industry on the grounds that, if it was prohibited in Australia, the local
industry would be at a disadvantage to international operators. However, the availability of credit to
gamble is clearly an inducement that encourages some people to gamble more than they would if they
had to actually transfer funds into the wagering operator’s account first. Problem gamblers are also
greatly influenced by the availability of credit.
3.4.5 Loyalty programs
Loyalty programs have not been considered by regulators or specifically addressed in industry codes
of conduct. However, it is generally accepted that they are an inducement and need to be treated
similarly. For example, Betfair (2012) advised the TGC that it had recently implemented a player
loyalty program called ‘Betfair Black’ which provided a variety of rewards to key customers. Betfair
assured the TGC that it would take all necessary steps to ensure that the loyalty program complied
with the Responsible Gambling Mandatory Code of Practice (TGC, 2012).
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Although loyalty programs are clearly a form of inducement to gamble, they are not considered in any
detail in this study. Loyalty programs are not easily comparable with other types of inducement, as
they have little influence on the initial decision to sign up to a business and have greater significance
over a longer period of time.
3.4.6 Affiliates
Affiliates receive a payment or commission for referring punters to wagering operators and facilitating
the betting process. Typically, affiliates operate independent websites with a click-through process to
direct customers to the wagering operator. Most Internet wagering operators use affiliates. An
example is Bet365 (2015), which will accept referrals from affiliates and track their transactions,
providing a report of the customer’s transactions to the affiliate, and paying a referral commission of
30% of the net profit earned. Affiliates are required to use the wagering operator’s approved
advertising creative material. Affiliates are identified in some codes of conduct, such as the CEN
Workshop Agreement (2011), where operators are required to ensure that their affiliates abide by the
same standards as the operator.
Another form of affiliate arrangement involves the placement of a designated computer terminal that
directly links up to the wagering provider. In 2009, VenueNet Pty Ltd announced an intention to install
hundreds of touch-screen betting kiosks, also called ‘betboxes’ in hotels across Australia (Oakes,
2009). The company argued that the VenueNet kiosk was simply a computer with Internet access that
put the customer in touch with Sportsbet in the Northern Territory. The VCGR seized a VenueNet
kiosk from a Melbourne hotel and prosecuted VenueNet. The company was convicted in the
Melbourne Magistrates Court of assisting the hotel in conducting the business of an illegal betting
house and possessing unauthorised instruments of betting. The question of whether Victoria’s action
against betting kiosks was unconstitutional as being in restraint of trade and commerce was
considered by the Full Federal Court in The State of Victoria v Sportsbet Pty Ltd (2012). The court
held that the provisions were not discriminatory nor were they protectionist because the law applied
equally to Victorian bookmakers and interstate bookmakers.
3.5 Laws and self-regulatory measures
3.5.1 Types of measures
In Australia, the advertising and provision of inducements is restricted by:

Commonwealth laws, including the Interactive Gambling Act 2001 and the Broadcasting
Services Act 1992.

State laws, such as the Gambling Regulation Act 2003 (Vic).

Mandatory codes of practice, such as the Northern Territory Code of Practice for Responsible
Gambling.

Voluntary codes of practice, such as the Queensland Responsible Gambling Code of Practice.

Individual operators’ codes, such as the TABCORP Wagering Responsible Gambling Code of
Conduct.

Broadcasting and advertising codes of practice.
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3.5.2 Commonwealth
In Australia, the limited legislative role taken by the Commonwealth reflects the revenue arrangements
where most gambling tax flows to the States and Territories. The IGA stands as the entry point of
Commonwealth activity in gambling regulation, and recognises that the growth of Internet gambling is
eroding the ability of States and Territories to effectively regulate the industry. The growing role of the
Commonwealth is further evidenced by the two Productivity Commission inquiries and the work of the
Parliamentary Joint Select Committee on Gambling Reform. The Commonwealth was forced to
respond to widespread public reaction to the growth in television sports betting advertising, and would
have legislated for restrictions had the industry failed to self-regulate to a satisfactory degree.
The Commonwealth could act to force the development of a uniform national approach to Internet
wagering generally, as well as the specific regulation of inducements, creating a level playing field.
However, such an approach would remove the ability of the individual States and Territories to
regulate in ways that best suit the wishes of their particular constituencies.
3.5.3 States and Territories
The State and Territory governments in Australia have taken a wide variety of approaches to the
regulation of inducements, ranging from no restrictions to absolute prohibition. Legislation lacks
flexibility, but enables governments to prosecute and fine operators that fail to comply with restrictions
and prohibitions. However, it appears that only Victoria has actually prosecuted operators for
breaching its prohibition on inducements to open wagering accounts. It is possible that other States
have also issued fines or warnings to operators.
Mandatory codes of practice, such as exist in South Australia, the ACT and the Northern Territory,
provide more flexibility. Whilst the South Australian and ACT codes of practice have clear and precise
requirements that could lead to prosecution, it is difficult to imagine that a prosecution could ever
occur in the Northern Territory, due to the general wording of its Code of Practice for Responsible
Gambling, which is based on the voluntary Queensland code. In South Australia, the code specifically
states that a gambling provider must not offer or provide any inducement directed at encouraging
patrons to gamble or directed at encouraging people to open gambling accounts. The provision is very
clear. By contrast, the Queensland and Northern Territory Codes make the general statement that
advertising and promotions are to be delivered in an honest and responsible manner with
consideration given to the potential impact on people adversely affected by gambling.
The Queensland Responsible Gambling Code of Practice is voluntary, and relies upon the shared
commitment of gambling industry providers to the guiding principle of ethical and responsible
behaviour. The Queensland code does not prohibit or restrict inducements, in contrast with most other
states. Perhaps Queenslanders are content with this state of affairs, as they can access the full range
of inducements offered by Internet wagering operators, giving them a financial advantage over
residents of prohibitionist States.
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3.6 Identifying options
Stakeholders have presented a range of views on if and how wagering inducements should be further
regulated and other issues for consideration. Six general options are considered in this section,
ranging from total prohibition, to improved self-regulation. These options could be implemented in a
variety of ways, including combining elements of more than one option.
3.6.1 Elements of laws
The current laws relating to inducements vary considerably between jurisdictions. The way in which
the elements of those laws apply to actual inducements is often unclear, leading to a grey area in
which wagering operators may venture with some hesitation. It would be better to set out the exact
boundaries of what is legal and what is not.
Changes to some elements of laws applying to wagering marketing have been suggested. The
Australian Gambling Research Centre (AGRC) (Hing, 2014) said that exemptions for sport-integrated
gambling marketing during general TV viewing times, and the quantity and types of advertisements
and promotions allowed during live and televised sport could be reviewed. The AGRC (Hing, 2014)
also suggested that the types of sports betting advertising allowed could be reviewed, with particular
attention to bonus promotions such as money-back guarantees and ‘free’ bets requiring matching
deposits.
3.6.2 Determining the objectives of the regulatory approach
The objectives of regulatory and self-regulatory approaches need to be clearly articulated by
policymakers at the commencement. Existing measures rarely specify exactly what outcomes are
intended, and these vary amongst stakeholders. Regulators want precision in regulatory measures,
with clear rules about what can be followed. Gambling operators prefer vaguely expressed intentions
of responsible marketing, avoiding having their hands tied by details. Gambling operator codes of
conduct mostly have strength in responding to problem gambling, for example by providing warnings,
self-exclusion and links to help services. Broadcasters’ and advertisers’ codes consider the effect on
viewers’ sensitivities, referring to ‘prevailing community standards’. They have little focus on problem
gambling.
The wider community feels there is simply too much gambling advertising. DLA Piper (2013) argues
that the UK and Australia are now experiencing a media focus on the ‘normalisation’ of gambling, with
the main concern being that some children will grow up thinking gambling is an integral part of sport.
This is reflected in three key concerns that emerged during the inquiry by the JSCGR (2013):

Indirect marketing and its possible effects on children and vulnerable people from a high level
of exposure.

The pervasive nature of the promotion of sports betting.

The integration of sports betting into sporting commentary.
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3.6.3 Industry view
The Australian Wagering Council (2012) makes the following arguments against the prohibition of
inducements:

Wagering operators, like other legal businesses, have the right to advertise their services
responsibly.

A prohibition on all inducements could prevent operators from lowering prices to respond to
competitive pressures or pass on operating cost savings.

Inducements enhance the customer experience.

They may reduce the switching costs between incumbent wagering operators, and new
entrants, enhancing competition.

Inducements have facilitated the growth in the market share of Internet wagering operators at
the expense of traditional forms of wagering so that the real dollar per capita spend on
wagering in Australia has shown only minimal growth over the last decade.

There is no evidence that indicates that the availability of inducements to customers
encourages or has increased the prevalence of problem gambling.

Prohibition on the offering of inducements to establish a betting account favours retail based
operators and distorts a competitive wagering market.

Limitations on Australian wagering operators to use inducements puts them at a commercial
disadvantage in competing against illegal offshore wagering operators.
The Australian Wagering Council (2012) points out that a customer may seek recourse against a
wagering operator that unlawfully misleads consumers by making a complaint to the operator’s
licensing regulator, or through State Fair Trading offices or the Australian Competition and Consumer
Commission.
However, wagering, like other forms of commercial gambling, is a product that has the potential to
cause significant financial harm to consumers. As the High Court noted in its Kakavas (2013)
judgment, gambling transactions are a rare species of economic activity in which each party sets out
openly to inflict harm on the other. The extent to which the potential for harm is minimised is a matter
of concern for all stakeholders. Research indicates that the prevalence of problem gambling among
those who gamble on the Internet is higher than for conventional land-based forms. At particular risk
are young men who are subject to growing peer pressure to bet online, children who grow up in a
world where sports betting is normalised, problem gamblers and other vulnerable groups.
The Australian Internet Bookmakers Association (AIBA) submitted to the JSCGR (2011) that
inducements are such a standard and unremarkable feature of the marketing of the global Internet
gambling industry that they are the subject of specialist websites and services that compare the
bonuses on offer. As this is global practice, with various forms of bonuses being offered by all major
operators, a ban on Australian operators matching these modest offers has had the effect of making
the Australian industry less competitive in the global market, but at the same time making overseas
operators more attractive to Australian punters (JSCGR, 2011). In attempting to avoid this loss of
competitiveness, Betfair in its submission to the TGC urged the TGC to legislate for a level playing
field regarding the ban on inducements, and asked that any restrictions only apply to locally licensed
wagering operators in their dealings with Tasmanian customers. An offshore operator such as Betjack,
with reputed links to the criminal underworld and accused of failing to pay winnings to its customers,
provides another good reason to support the Australian industry.
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3.6.4 Option 1: Prohibition of all inducements
The extent to which operators actually comply with existing prohibitions on inducements is unknown.
There is no evidence available to this study of any prosecution for failure to comply with the prohibition
on inducements in any jurisdiction other than Victoria.
Reasons for the prohibition of all inducements include:

That gambling is not to be encouraged, even though it is a lawful activity. Sign up
inducements appear to offer a significant financial benefit or something for nothing. Many in
the community are concerned that sign up inducements unnecessarily encourage people to
commence gambling which may result in significant cost to them later.

That the offers motivate problem gamblers and other vulnerable persons to open more
accounts and to gamble more money and more frequently.

Inducements unnecessarily favour the internet gambling industry over land-based operators.
A blanket ban would put local operators at a disadvantage, as there is little to prevent consumers
opening accounts with offshore Internet operators. Also, there would be difficulties in deciding where
to draw the line between illegal inducements and promotional activity that was still permitted. If
wagering operators are not permitted to compete for business by one method of promotion, they will
inevitably look for alternatives.
Consideration should be given to the existing, and possible future, responses of wagering operators
to a blanket prohibition and the social value of alternative forms of promotion should be compared
with the social value of inducements.
No evaluation has been undertaken of the costs and benefits of the ban on inducements. Future
research could make a comparison between the outcome for consumers in jurisdictions where
inducements are banned, and those in jurisdictions where they are permitted.
3.6.5 Option 2: Prohibition of some inducements
A second option is to only prohibit those inducements that are considered to be the most harmful.
Research would be needed to identify those inducements that cause the most harm and then an
evaluation would be needed of whether prohibition is the most effective response, or whether
alternative responses could suffice to reduce the harm while maintaining the benefits.
As with total prohibition, the response from wagering operators to a partial prohibition should be
considered, as well as the loss of competitiveness with offshore operators.
3.6.6 Option 3: Restrictions on the type and terms of inducements
Restrictions could be placed on the type of inducements, such as allowing only some types of sign-up
inducements while prohibiting others.
Limits could be set on terms of the permitted inducements, such as a cap on the amount of bonus
offers or a limit on the number of times which a bonus amount needs to be turned over.
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These restrictions and limits could enable operators to offer a modest level of inducement to
encourage switching to new market entrants or brand loyalty, without putting pressure on consumers
to bet excessively or stimulating problem gamblers.
3.6.7 Option 4: Restrictions on the type and form of advertising
Commercial decisions are often made by gambling operators as they weigh up legal risks against the
benefits derived from advertising. These decisions have given rise to a commonly held perception that
betting operators are pushing the envelope when it comes to advertising (Nettleton 2013).
The detail of the restraints on advertising inducements is important. At present, most regulations and
codes of practice refer to inducements in general terms, such as requiring advertising to reflect
prevailing community standards and inducements to be socially responsible.
A strong case can be made for greater precision in defining the boundaries of acceptable advertising
and imposing clear limits on inducements. This will give certainty to the industry, and ameliorate the
public perception that the industry is pushing the boundaries of acceptable standards.
Concerns about the conditioning of inducements on minors could be addressed by limiting the times
when inducements can be advertised on broadcast media. The recent commitment by UK wagering
operators to refrain from advertising inducements on television before 9 pm is an example. Age gates
on social and digital media could also be strengthened. Restrictions on the form of advertisements are
relevant to the impact such advertising may have on problem gamblers and other vulnerable people.
The means of communication could also be targeted, or limits put on the number of communications
sent to each customer each week.
3.6.8 Option 5: Requirements for additional features – terms and
conditions, independent dispute resolution
The terms and conditions of inducements can be difficult to access and understand, leading to
consumer dissatisfaction. A prescriptive approach to advertising, setting out exactly how the terms and
conditions of inducements must be conveyed, offers the potential of empowering consumers to make
informed choices, thus reducing consumer dissatisfaction, whilst enabling Australian llicensed
wagering operators to compete on a level field. Because inducements can have detailed and onerous
conditions, a simplified, standardised summary could be mandated. The summaries that apply to
energy efficiency on appliances, fuel economy on motor vehicles, or comparison rates for credit are
examples. A comparison box could be mandated for advertisements for inducements, setting out key
information, such as the number of times the inducement must be turned over.
Generally, the amounts in disputes about inducements are too small to warrant court action and are
not of interest to general government consumer protection agencies. The availability of an
independent third party dispute resolution process enables dissatisfied consumers to have their
grievances determined when the operator’s internal dispute resolution process has failed to deliver an
outcome to the consumer’s satisfaction. Such a dispute resolution process should be easy to access,
quick, and able to make determinations that are binding on the operator but leave the way open for a
dissatisfied consumer to access any legal remedies that may be available.
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3.6.9 Option 6: Improved self-regulation
Improved self-regulation would reduce the need for government intervention. The Australian wagering
industry has the ability to raise the standard of its voluntary codes of practice, by ensuring that they
provide a detailed suite of clearly expressed and effective consumer protection features. Inducements
are just one area where self-regulation could be strengthened. Because of the wide differences in
approaches currently taken by governments, there would be benefits of uniformity, flexibility and cost
effectiveness if the industry were to take voluntary steps in this area.
3.7 Chapter summary
The policy analysis found that the regulatory environment for wagering inducements currently lacks
clarity on what constitutes an inducement, provides little specificity about which aspects of
inducements are acceptable or not, and lacks consistency across Australian jurisdictions. While a
variety of relevant legislation, regulations and codes of practice exist for gambling, advertising and
broadcasting, and which might inform the provision and promotion of wagering inducements, their
provisions are typically vague and often provide little specific direction to ensure that these
inducements minimise gambling harm and provide adequate protection for consumers. International
jurisdictions have responded in a variety of ways, but their responses have also been fragmented and
inconsistent.
More specifically:

The issue of inducements has attracted significant attention in recent years. Governments and
industry have made some progress in providing consumer protection measures; however, it
appears that more should be done.

The current situation where each jurisdiction has a different approach is clearly unsatisfactory
and confusing for both the wagering industry and consumers.

The fact that most wagering operators are licensed in smaller jurisdictions with a low level of
regulation is also problematic.

The Commonwealth has the potential to take a more active role in relation to inducements.

Developments in Europe offer some additional options in managing wagering inducements.

Terms and conditions of inducements should be made accessible and easily understood so
they can be compared.

Broadcasting and advertising codes of practice could be expanded to cover the advertising of
inducements in more detail.

Complaints resolution processes are important.

The availability of credit or delayed payment of betting accounts is an inducement that has the
potential to cause significant harm.

Affiliates and loyalty programs of wagering operators are rarely mentioned in regulation or
codes of practice.

There are a number of regulatory options available to better manage the provision of wagering
inducements.
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Chapter Four: The audit of inducements
4.1 Introduction
This chapter presents the results of the audit of wagering inducements found on operator websites.
The methods used to conduct the audit are firstly explained, before each type of inducement is
described. Summary statistics are then presented for each of the key attributes of the inducements.
The main terms and conditions of the inducements are examined, as well as their inclusion of
responsible gambling messages.
4.2 Method
The audit was conducted in May 2015 and covered the inducements offered by 30 gambling operator
brands during the audit period. The list of brands (Table 4.1) included 18 operators licensed in
Australia and 12 of the most popular offshore operators that accept bets from Australians in AU$
(sourced from casinocity.com on 28 April 2015).5 6
Table 4.1 Brands included in the inducements audit, onshore/offshore operators
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Onshore
Crownbet
Bet365
Betfair
Betstar
Topbetta
Bookmaker
Palmerbet
William Hill
Centrebet
Ladbrokes
Luxbet
Sportsbetting
Sportsbet
Tattsbet
TABtouch
ACTTAB
Tom Waterhouse
TAB.com.au
19
20
21
22
23
24
25
26
27
28
29
30
Offshore
Pinnacle Sports
SBOBET
10Bets Sports
BetVictor Sports
Stan James Sportsbook
BetDSI
TonyBet
Mansion 88
Intertops Sportsbook
Betjack/ Marathon Bet
Betplay
Betadonis
The websites of these 30 operators were accessed on two separate occasions. Count 1 took place
between the 8th and 13th May, and Count 2 between the 22nd and 28th May. Since there is a good deal
of variation between inducements offered by wagering brands at the start of the week, and those
5
Twelve of the most popular 13 brands were selected to give a broader range of licensing jurisdictions than if just the top
12 were selected.
6 Three of these brands (Tattsbet, TABtouch and ACTTAB) did not advertise any inducements during the audit period.
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offered towards the end of the week, each brand was audited once at the start of the week and once
at the end of the week (over Counts 1 and 2) to ensure that we captured the widest range of
inducements possible within the project timeframe.
Betjack was included in the audit at Count 1 (with two inducements on its website on 12 May 2015). At
the time of Count 2, its website was undergoing maintenance and was unavailable, so a replacement
offshore brand, Marathon Bet, was selected for inclusion in Count 2. This ensured that 30 brands were
audited in each count. Marathon Bet had no inducements advertised during Count 2. For this reason,
this report refers to 30 brands being included in the audit and only Betjack appears in any of the
inducement audit data.
All in-scope inducements (see Section 1.3 for the project definition of inducements) were identified on
the websites. Inducements were generally found in areas of the website labelled ‘promotions’, or
‘specials’ or ‘novelty’. Their prominence varied, with some websites opening up directly to a full page
‘sign up offer’, which needed to be circumnavigated in order to access the generic homepage. Most
websites displayed their inducements on their home page, as static and/or scrolling advertisements.
For a small minority of websites, the promotions page needed to be proactively searched for. The
majority of operators advertised only current promotions, with a small minority ‘archiving’ historical
offers (in one case, going back several years). Most inducements are assigned a promotional code,
which the bettor is required to type in during the process of taking up the offer.
Key attributes of the inducements, along with an inducement image taken from the website, were
recorded into a bespoke ACCESS database. A total of 223 inducements were recorded across the two
counts (165 for Count 1 and an additional 58 for Count 2). The attributes recorded in the database
were as follows:

Brand

Whether onshore or offshore

Inducement label and brief description

Type of inducement

Incentive provided

Whether it applies to sports and/or racing

Sporting code or racing type and geography (whether Australian or overseas)

Detail on whether limited to a particular sporting/racing round or event

Type of bets eligible (and ineligible) for the inducement

Minimum and maximum bet

Maximum payout

Terms and conditions of the inducement (these are described in detail in Section 4.5)

Whether a responsible gambling message is visible as part of the inducement advertisement
itself, and/or on the host website

The browser used to access the inducement was also recorded (since that affected what
could be viewed in some instances) as was the date it was accessed
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4.3 Inducement types
The audit covered 15 types of inducement, listed below. A number of inducements could be classified
in more than one of the categories; for example a multi bet offer might involve a refund of the stake if
one of the bet elements did not win. Therefore, we established a ‘priority coding’ order; in other words,
if an inducement fitted into more than one category, it was classified as the first category in the list
below. The hierarchy was designed to reflect the diversity of inducements; so, for example, if an
inducement was distinguished by encouraging ‘mobile betting’, and the incentive provided was a
refund, it was coded as a ‘mobile betting offer’, rather than a ‘refund/stake back offer’. It is important to
note that changing the priority order of this coding list would, of course, affect the number and
distribution of inducement types.

Sign up offer

Refer a friend offer

Happy hour or similar offer

Mobile betting offer

Multi bet offer

Refund/stake back offer

Match (or partially match) your stake/deposit (with bonus bets)

Winnings paid even if you don't win (e.g. protest payouts, in extra time)

Bonus or better odds (not including happy hour type inducements included above)

Bonus or better winnings

Competitions (where payout is bonus bets)

Reduced commission

Free bets (selected punters)

Other free bets (e.g. predict the outcome of a match)

Cash rebate (no play through required)
The main features of each wagering inducement type are described, in turn, below; and the results of
the audit are detailed in Section 4.4. All of the inducements offered some kind of financial incentive,
which were predominantly (53% of inducements) paid out as ‘bonus’ or ‘free bets’ or, less commonly,
provided as cash or credited to an account. The defining feature of bonus bets is that they are
required to be bet or ‘played through’ before they can be withdrawn; in other words the bettor must
make additional bets in order to take advantage of the financial incentive. These play through
requirements may apply to the bonus amount itself, to the bonus amount plus the stake required to
attract the bonus, to the winnings obtained through using the bonus amount, or to a combination of
these amounts. Play through requirements among onshore brands tend to require that the bonus
amount be bet through at least once; whereas offshore brands tend to stipulate multiple play through
requirements. As described in Chapter Two, this requirement, invariably attached to bonus bets, is
aimed at encouraging intensification of betting. The audit findings for play through requirements are
detailed in Section 4.5.2.
It is also worth noting that winning bets placed with bonus bets do not reimburse the stake, in contrast
with bets placed with cash. So, if a bettor placed a standard bet of $100, with odds of 2 to 1, s/he
would win $200, and the original stake would be returned (a net gain of $200). However, if a bettor
staked the same amount using bonus bets, s/he would only pocket the $200 winnings (a net gain of
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$100). Thus, bonus bets only yield a financial advantage to the bettor if they win. Play through
conditions nearly always require the bettor to risk some of their own money to have a chance to win by
using a bonus bet (see box below related to sign up offers).
4.3.1 Sign up offer
Sign up offers accounted for 13% of inducements captured in the audit. Sign up offers tend to be
displayed prominently on the brand’s home page and, in some cases, as previously described, clicking
on the web page link opened up a sign up offer advertisement which covered the whole screen, and
needed to be circumnavigated in order to access the home page (Figure 4.1).
Figure 4.1 Example sign up offer
Sign up offers provide incentives to new customers in the form of bonus bets, with an average (mean)
maximum value of $2007 and values ranging from $14 to $1,000 (among the wagering inducements
captured in the audit). These offers generally match, or partially match, an outlay from the customer in
the form of a deposit or first bet. In a small number of cases, the bonus bets exceeded the investment
amount required from the customer. The amount offered appeared to be subject to variation, for some
brands, with the amount changing, or more than one offer amount being displayed at once, during the
audit period.
Sign up offers are associated with a number of conditions including being restricted to one offer per
household and/or account, a time limit on when the new customer is required to deposit and or bet
money (between 30 and 90 days, although one operator had a 7 day time limit), and play through
requirements. These stipulate that the bonus bet incentive amount and/or matching deposit and/or
7
All monetary values are reported in AUD, unless otherwise stated. For this analysis, maximum values provided on the
websites in other currencies were converted to AUD at the rates published by the Reserve Bank of Australia on 29 May
2015.
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winnings obtained from the bonus bet must be played through (usually at least once) before
withdrawals can be made from the account. The bonus bets themselves are subject to an additional
layer of restrictions, including the type of bets and the minimum odds. Sign up offers are deliberately
‘open’ in terms of the activities on which bets can be placed. As described in Chapter Two, sign up
offers are prohibited in Victoria, New South Wales, South Australia and Western Australia. The box on
the next page provides some examples of play through conditions on sign up offers. Similar play
through conditions apply to bonus bets provided for other inducements.
4.3.2 Refer a friend offer
Refer a friend offers were far less common than the sign up offers described above, accounting for
only 3% of inducements, although they share many of their characteristics. Refer a friend offers tend
to provide incentives, in the form of bonus bets, to both the referring account holder and the friend.
The average maximum value of the bonus bets was $69, ranging from $26 to $100.
For these inducements, the requirements on betting and playing through rest with the referred
individual. The same four jurisdictions (Victoria, New South Wales, South Australia and Western
Australia) are excluded from these offers but, unlike the sign up offers, there were no limitations on the
number of times the offer could be claimed by referrers, with operators actively encouraging account
holders to refer multiple individuals.
Figure 4.2 Example refer a friend offer
4.3.3 Happy hour (or similar) offer
These inducements accounted for 4% of the total. They were characterised by offering a regular,
repeated, short term incentive to bet; for example, the ‘best industry price, every Saturday between 11
and 12’, or ‘in the two hours leading up to the match’. The incentive tended to be better odds, or better
winnings, but inducements were coded in the ‘happy hour’ category if the promotion was marketed as
being restricted to a particular time period, constituting a day or less. The maximum average payout
associated with happy hour offers was $58, with a range from $50 to $65. The maximum bet threshold
for this inducement ranged from $20 to $3,126.
Figure 4.3 Example happy hour offer
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Risks and potential returns from some sign up offers
The following examples of sign up bonuses illustrate what the bettor needs to risk in order to have a
chance to benefit from the associated bonus bets. Please note that these summaries are based on the
research team’s interpretation of much longer terms and conditions associated with each offer. While
we have made our best efforts to interpret these correctly, their complexity means we cannot be 100%
sure, suggesting that consumers would have similar difficulties. The following examples are based on
the maximum amount of each offer.
Bet365 Open Account Offer ($200 maximum)
The bettor deposits and bets $200, then receives the bonus bet of $200. The bettor must bet the
deposit amount + bonus amount 3 times ($400x3 = $1,200) at odds of 1.5 or more within 90 days
before withdrawing the bonus bet or any winnings made from the bonus bet. In this case, the turnover
requirement of $1,400 = $1,200 of bettor’s own money + $200 bonus bet. Because only the winnings
from bonus bets are paid (not the original stake), the bonus bet only has a financial benefit if it wins. In
this case, the bettor is required to risk $1,200 of his/her own money at odds of 1.50 or more for a
chance to win from a $200 bonus bet.
Sportsbet 1st Bet Bonus Sign Up Offer ($100 maximum)
The bettor deposits and bets $100, then receives the bonus bet of $100. The bettor must bet the
bonus bet of $100 within 30 days. Any winnings from the bonus bet must then be turned over once (5
times for international bettors) before being able to make any withdrawal from the account. Because
only the winnings from bonus bets are paid (not the original stake), the bonus bet only has a financial
benefit if it wins. In this case, the bettor is required to risk $100 of his/her own money and all winnings
from the bonus bet for a chance to win from the $100 bonus bet. The bonus bet therefore has a
financial benefit only if it yields winnings twice.
William Hill Up to $200 First Bet Offer ($200 maximum)
The bettor deposits and bets $200, then receives the bonus bet of $200. The bettor must bet the
bonus bet of $200 within 7 days. The bettor must then bet the deposit amount ($200) + any winnings
from the bonus bet once at odds of 1.5 or more before being able to make any withdrawal from the
account. Because only the winnings from bonus bets are paid (not the original stake), the bonus bet
only has a financial benefit if it wins. In this case, the bettor is required to risk $400 of his/her own
money and all winnings from the bonus bet at odds of 1.5 or more for a chance to win from the $200
bonus bet. The bonus bet therefore has a financial benefit only if it yields winnings twice.
Crownbet First Deposit Offer (3 x $50 = $150 maximum)
The bettor deposits $50 (or more), then receives 3 x $50 bonus bets. The bettor must bet the bonus
bets within 30 days and on different markets (thus requiring 3 bets). Any winnings from the bonus bets
must be turned over once (5 times for international bettors) at odds of 1.5 or greater before withdrawal
of those winnings is allowed. Because only the winnings from bonus bets are paid (not the original
stake), the bonus bet only has a financial benefit if it wins. In this case, the bettor is required to risk
$50 of his/her own money and all winnings from the 3 bonus bets at odds of 1.5 or more for a chance
to win from the $150 worth of bonus bets. Each bonus bet therefore has a financial benefit only if it
yields winnings twice.
Sportsbetting 100%Deposit Bonus ($50 maximum)
The bettor deposits $50 (or more), then receives a $50 bonus bet. The bettor must bet the bonus bet
within 30 days. The amount of the original deposit ($50) must be turned over twice at odds of 1.8 or
greater before withdrawals are permitted. Because only the winnings from bonus bets are paid (not
the original stake), the bonus bet only has a financial benefit if it wins. In this case, the bettor is
required to risk $100 of his/her own money at odds of 1.8 or more for a chance to win from the $50
bonus bet.
Intertop Sportsbook: Sign-Up Special - $20 Bet Token
The bettor deposits US$20 (or more), then receives a US$20 bonus bet. The bettor must bet the
bonus bet within 30 days. The bonus bet must be turned over 16 times at odds of 1.5 or greater “in
order to request the right to make a withdrawal”. No information could be found about whether any
payouts from the bonus bet include the original stake or not. In this case, the punter is required to risk
US$340 of their own money at odds of 1.50 or more for a chance to win from the US$20 bonus bet.
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4.3.4 Mobile betting offer
These inducements accounted for only 1% of the total. Their aim is clearly to encourage use of smart
phones and tablets for betting, and they tended to relate to only the first bet placed via this medium.
These inducements were usually ‘open’, i.e. they were not linked to particular codes or events. The
incentive tended to be provided in the form of bonus bets, the average maximum value of which was
$75 (range $49 to $100).
Figure 4.4 Example mobile betting offer
4.3.5 Multi bet offer
These inducements accounted for around one in ten (9%) of wagering inducements. They stipulate
that a multi bet (also known as an accumulator, or a parlay) must be placed, generally on a particular
sporting code or racing carnival. The incentive provided usually comprises a refund/stake back offer or
increased winnings; both of which might be paid either in the form of bonus bets or cash. As such, the
multi bet offer usually incorporated one of the other inducement types, for example the offer stipulated
a multi bet via a mobile phone, or a multi bet involving a refund, or attracting bonus winnings. In such
cases, the priority coding order was used (as outlined above). Multi bet offers tended to have a
maximum bet limit, which ranged from $50 to $100. The average maximum monetary payout
associated was $101, with a range from $50 to $200. Bonus bets were not eligible for this offer.
Figure 4.5 Example multi bet offer
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4.3.6 Refund/stake back offer
Refund/stake back offers were the most prevalent form of wagering inducement, constituting 27% of
the total. These inducements aim to reduce the perceived risk of betting by offering to refund the stake
(or part of it) if the bet does not win. These offers covered a wide variety of racing events and sporting
codes and tended to be linked to a particular race or match and/or associated with particular
conditions, such as ‘if your team is winning at half time’, or ‘if your team scores xx points but loses’, or
‘if your selected first try scorer scores at some point during the game’. Refunds are typically (68% of
cases) paid out as bonus bets, which need to be played through; but in some cases (32%) the refunds
are paid out as ‘cash’ (i.e. without play through requirements). The average maximum value of the
incentive (in the audit) was $85, and ranged from $25 to $357.
Figure 4.6 Example refund/stake back offer
4.3.7 Match (or partially match) your stake/deposit (with bonus bets)
This inducement type is very similar to the refund/stake back offer, in that the customer’s stake is
refunded (either in the form of cash or bonus bets). The differentiating factor is that, while refund/stake
back offers are provided for losing bets, and provided after the event, the ‘match your stake’
inducement type is provided either at the point of placing the bet (i.e. in advance of the event) or for a
winning bet. These offers were sometimes conditional on ‘reloading your account’ i.e. putting more
money into a betting account. All other characteristics are similar between the two types. These
‘match your stake’ inducements constituted 4% of the total. The average maximum value was $58,
with a range of $14 to $100.
Figure 4.7 Example match your stake/deposit offer
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4.3.8 Winnings paid even if you don’t win
These inducements accounted for 7% of the total and, as with refund offers, were marketed as
reducing risk; in this case the risk of a ‘near win’. As such, these offers tend to be linked to ‘close calls’
such as protest judgements in horse racing, or video referee decisions disallowing a first try scorer’s
try. These offers were usually restricted with a maximum cut-off on the bet value, which ranged from
$100 to $250. Thresholds on the value of winnings that could be claimed through this offer were high,
ranging up to $100,000. Winnings tend to be paid out as ‘cash’ rather than bonus bets, although bets
placed with bonus bets were invariably ineligible for this offer type.
Figure 4.8 Example winnings paid even if you don’t win offer
4.3.9 Bonus or better odds
Inducements offering ‘promotional odds’ incorporated both temporary offers, usually related to a
particular season or a specific race or match; and also a more generic and continuous promotion, with
the operator guaranteeing the ‘best tote odds all day, every day’. These inducements accounted for
13% of wagering inducements. The incentive related to this inducement type was characterised as
being paid out as ‘cash’ rather than bonus bets. These offers were usually restricted with a maximum
cut-off on the bet value, ranging from with $50 to $200. Again, the cap on winnings under this offer
tended to be very high, up to $20,000.
Figure 4.9 Example bonus or better odds offer
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4.3.10 Bonus or better winnings
This inducement type was similar to the previous offer (bonus or better odds) but was expressed in
different terms, for example as ‘double your winnings’ or ‘25% extra’ on your winnings. The additional
winnings were paid out as either cash (46% of this inducement type, and with a cap of $10,000) or as
bonus bets (54% of this inducement type). These inducements accounted for 12% of the total. These
offers were restricted with a maximum cut-off on the bet value, ranging from $100 to $250.
Figure 4.10 Example bonus or better winnings offer
4.3.11 Competitions (where payout is in bonus bets)
This inducement type was very rare (<1% of records). Most competitions involved prizes that were not
designed to directly encourage betting behaviour (for example a trip to America or a ticket to a
sporting event); and these were deemed out of scope for the audit (see Chapter One). There were
rare cases, however, where a competition was paid out in the form of bonus bets, and therefore
offered a direct inducement to intensify gambling behaviour; these cases were recorded in the audit.
The example below is awarded to the ‘customer who makes the highest net profit from a single parlay
bet in each calendar month’, providing $1,000 in bonus bets.
Figure 4.11 Example competition
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
4.3.12 Reduced commission
This inducement type was also very rare, constituting just 1% of the total. In the two records that were
captured in the audit, the inducement related to reduced rates of commission during a particular racing
carnival and ‘forgetting the 5p rule 4’ (for a UK based provider).
Figure 4.12 Example reduced commission offer
4.3.13 Free bets (selected punters)
This category covered a small minority of wagering inducements (2%) which were not explicitly
conditional on a specific betting behaviour (although they are only available to active bettors). These
promotions were deemed inducements to gamble in that their incentive was in the form of free or
bonus bets. The defining example is free bets to ‘selected punters’.
Figure 4.13 Example free bets offer
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
4.3.14 Other free bets (e.g. predict the outcome of a match)
This inducement category was very rare (2% of the total) and comprised ‘all other free bet’
inducements which did not fit into the other categories, for example, the inducement below providing a
bonus bet to bettors who predict the finalists of the English Champions League.
Figure 4.14 Example other free bets offer
4.3.15 Cash rebate (no play through required)
The final inducement type found in the audit constituted 4% of the total, and was found only in
offshore providers. This inducement was characterised by providing cash back on betting expenditure,
with no play through requirements, as a specified percentage of outlay. In some cases there were
specifications (for example horse racing) and/or around the type of bet, with differing percentage
amounts depending on whether it was an ‘exotic wager’ or a ‘win, place and show wager’.
Figure 4.15 Example cash rebate offer
Victorian Responsible Gambling Foundation
Page 76
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
4.3.16 Click to call bonus
At the time of writing, williamhill.com.au and tomwaterhouse.com.au were offering matched bonuses
for the first click to call bet made on any live market. However, these bonuses commenced after the
audit period so were not included in the counts. They are mentioned here for interest. ‘Click to call’
technology has been introduced only very recently and allows bettors to place in-play bets through
their computer or mobile phone (Figure 4.16). Because in-play bets can only be placed with Australian
licensed operators in person or by telephone, this technology aims to circumvent the prohibition on
placing in-play bets via the Internet. Bettors select their bets online, use the click to call button to
connect to a telephone operator, and confirm their bet with another click. They do not need to speak to
the telephone operator at all during this process.
Figure 4.16 Example click to call bonus offer
Victorian Responsible Gambling Foundation
Page 77
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
4.4 Summary statistics
4.4.1 Number of inducements, by brand
The audit captured 165 inducements at Count 1 and 176 inducements at Count 2. Many of the
inducements were long-running enough to be present during both counts (118 inducements). Table
4.2 shows the breakdown of inducements by brand, across the two counts and in total. Four of the
brands covered in the audit (Tattsbet, TABtouch, ACTAB and Marathon Bet) did not advertise any
inducements during the audit period, and therefore are not included in the table below.
Table 4.2 Total inducements by brand, by count
Brand
10Bets Sports
Bet365.com.au
Betadonis
BetDSI
Betfair.com.au
Betjack
Betplay
Betstar.com.au
BetVictor Sports
Bookmaker.com.au
Centrebet.com.au
Crownbet.com.au
Intertops Sportsbook
Ladbrokes
Luxbet.com.au
Mansion88
Palmerbet.com.au
Pinnacle Sports
SBOBET
Sportsbet.com.au
Sportsbetting.com.au
Stan James Sportsbook
TAB.com.au
Tom Waterhouse.com
TonyBet
Topbetta.com.au
Williamhill.com.au
Grand Total
Count 1
N
4
17
2
4
3
2
4
5
1
5
7
16
6
11
4
6
8
2
1
14
2
9
5
8
2
4
13
165
%
2%
10%
1%
2%
2%
1%
2%
3%
1%
3%
4%
10%
4%
7%
2%
4%
5%
1%
1%
8%
1%
5%
3%
5%
1%
2%
8%
100%
Count 2
N
4
17
2
4
1
4
3
2
3
5
18
7
21
10
5
13
3
1
14
2
10
5
10
2
3
7
176
%
2%
10%
1%
2%
1%
0%
2%
2%
1%
2%
3%
10%
4%
12%
6%
3%
7%
2%
1%
8%
1%
6%
3%
6%
1%
2%
4%
100%
Total
N
8
34
4
8
5
2
8
9
3
8
12
35
13
34
14
11
21
5
2
28
4
19
10
20
4
7
20
348
%
2%
10%
1%
2%
1%
1%
2%
3%
1%
2%
3%
10%
4%
10%
4%
3%
6%
1%
1%
8%
1%
5%
3%
6%
1%
2%
6%
100%
To prevent double-counting of inducements that were captured during both counts, the two counts
were combined to produce a total sample of 223 distinctive inducements for analysis (165 from count
1 and an additional 58 new inducements from count 2). All remaining tables and graphs in this section
are based on the aggregate count (223 inducements), unless otherwise specified. The chart below
depicts the share of the total by brand. It shows that the top five brands, in terms of the share of
inducements, were Ladbrokes, Crownbet, Sportsbet, Bet365, and William Hill (all onshore brands).
Victorian Responsible Gambling Foundation
Page 78
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Figure 4.17 Inducements by brand
Inducements by brand
12%
10%
8%
6%
4%
2%
0%
The majority of inducements covered in the audit were offered by onshore providers (78%); not
surprisingly, since more onshore brands were covered (18 vs 12). On average, onshore operators had
11.6 inducements, while offshore operators offered an average of 4.1 inducements.
4.4.2 Inducement types
As described in the previous section, the most common inducement type overall was the refund or
stake back offer (27% of all inducements), followed by the sign up offer (13%), bonus or better
odds(13%) and bonus or better winnings (12%) (Table 4.3 and Figure 4.18).
Table 4.3 Inducements by type
Inducement type
Refund/stake back (or partial) offer
Sign up offer
Bonus or better odds (not including Happy Hour type inducements)
Bonus or better winnings
Multi bet offer
Winnings paid even if you don't win/or there is a protest/or you win in extra time
Match (or partially match) your stake/deposit (with bonus bets)
Happy hour or similar offer
Refer a friend offer
Free bets (randomly selected punters)
Cash rebate (no playthrough required)
Other free bets (e.g. predict the outcome of a match)
Mobile betting offer
Reduced commission
Competitions (where payout is in bonus bets)
Grand Total
Victorian Responsible Gambling Foundation
Count 1
N
60
30
28
26
21
16
9
8
6
5
4
4
3
2
1
223
%
27%
13%
13%
12%
9%
7%
4%
4%
3%
2%
2%
2%
1%
1%
0.4%
100%
Page 79
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Figure 4.18 Inducements by type
Inducement types, all inducements
Refund/stake back (or partial) offer
Sign up offer
Bonus or better odds (not including Happy Hour type inducements)
Bonus or better winnings
Multi bet offer
Winnings paid even if you don't win/or there is a protest/or you win in extra time
Match (or partially match) your stake/deposit (with bonus bets)
Happy hour or similar offer
Refer a friend offer
Free bets (randomly selected punters)
Other free bets (e.g. predict the outcome of a match)
Cash rebate (no playthrough required)
Mobile betting offer
Reduced commission
Competitions (where payout is in bonus bets)
0%
5%
10%
15%
20%
25%
30%
Percentage of inducements
There were some clear differences between onshore and offshore brands in marketing strategies, as
reflected in the prevalence of the different types of inducement. While the most common inducement
for onshore brands was refund offers, offshore brands promoted a higher proportion of sign up offers
(Figure 4.19).
Figure 4.19 Inducement types by onshore/offshore
Inducement types, onshore/ offshore
Refund/stake back (or partial) offer
Sign up offer
Bonus or better odds (not including Happy Hour type inducements)
Bonus or better winnings
Multi bet offer
Winnings paid even if you don't win/or there is a protest/or you win in extra time
Match (or partially match) your stake/deposit (with bonus bets)
Happy hour or similar offer
Refer a friend offer
Free bets (randomly selected punters)
Other free bets (e.g. predict the outcome of a match)
Cash rebate (no playthrough required)
Mobile betting offer
Reduced commission
Competitions (where payout is in bonus bets)
0%
5%
10%
15%
20%
25%
30%
35%
Percentage of inducements
Onshore
Victorian Responsible Gambling Foundation
Offshore
Page 80
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Figures 4.20 and 4.21 show the top two inducement types (refund and sign up offer) as a percentage
of each brand’s total inducements. It is important to note that these percentages tend to be based on
very small denominators (i.e. the number of inducements offered by an individual brand).
Whilst refund offers constituted 31% of onshore brand’s inducements overall, this figure varied
considerably between brands. Nearly three fifths (57%) of Crownbet’s inducements were marketed as
refund offers, half of TAB’s (50%) and Palmerbet’s (47%) and two fifths of Sportsbet and Betstar
promotions (both 40%). This compared with only 6% of inducements promoted by Bet365.
As previously stated, refund offers were less common, overall, among offshore brands (12%), and
again this varied between brands. Refunds constituted one in two (50%) of the offers promoted by
Betadonis and a quarter of those offered by Betplay. For the other three offshore brands that
marketed refund offers on their website, this offer type constituted no more than a fifth of their total
(Stan James Sportsbook 20%; Mansion 88 17% and Intertop Sportsbook 14%).
Sign up offers were more commonly promoted by offshore brands (24% compared with 10% of
onshore inducements). Among onshore brands, Sportsbetting.com.au and Bookmaker.com were the
most likely to promote sign up offers (33%), followed by Centrebet and Topbetta (both 25%). Among
offshore brands, sign up offers were the only type of inducement promoted by SBOBET, and made up
half of inducements offered by Tonybet, BetVictor Sports, Betjack and Betadonis.
Figure 4.20 Top two inducement types by brand - onshore
Percentage of each individual brand's inducements
Top two inducement types, by brand - onshore brands
60%
50%
40%
30%
20%
10%
0%
Refund/stake back (or partial) offer
Victorian Responsible Gambling Foundation
Sign up offer
Page 81
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Figure 4.21 Top two inducement types by brand - offshore
Percentage of each individual brand's inducements
Top two inducement types, by brand - offshore brands
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
Refund/stake back (or partial) offer
Sign up offer
4.4.3 Incentive provided
This category focused on the characteristics of the incentive provided by the inducement. For some
inducement types (e.g. ‘match your stake with bonus bets’), this was the same as the inducement type
itself, but for others (e.g. ‘multi bet offer’) it provided an additional descriptive feature.
The five most common forms of incentive overall were the refund of the stake as bonus bets (21%),
followed by better odds (15%), matching the stake/deposit with bonus bets (14%), refund provided as
cash (12%) and all other free/bonus bets (10%) (Figure 4.22).
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Figure 4.22 Incentive types
Incentive types, all inducements
Stake back or partial refund (in the form of bonus bets/credit)
Better odds
Match your deposit/stake (or partial) with bonus bets
Stake back or partial refund (NOT in the form of bonus bets/credits)
All other credit/bonus/free bets
Bonus/better winnings paid (NOT in the form of bonus bets)
Bonus/better winnings paid (in the form of bonus bets/credit)
Winnings paid out even if you don't win (in the form of cash/credit that can be withdrawn)
All other financial incentives (i.e. cash or credit can be withdrawn without betting through)
Reduced commission
Match your stake/deposit with cash or credit
Winnings paid out even if you don't win (in the form of bonus bets/credit)
0%
5%
10%
15%
20%
25%
Percentage of inducements
As the pattern of inducement types differed between onshore and offshore brands, not surprisingly, so
did the provision of different types of incentive (Figure.4.23). Offshore brands tended to favour more
matching deposit incentives (27% of offshore brand inducements, compared with 11% of onshore) and
other free bets (20% compared with 7% of onshore brands).
Figure 4.23 Incentive types by onshore/offshore
Incentive types, onshore/ offshore
Stake back or partial refund (in the form of bonus bets/credit)
Better odds
Match your deposit/stake (or partial) with bonus bets
Stake back or partial refund (NOT in the form of bonus bets/credits)
All other credit/bonus/free bets
Bonus/better winnings paid (NOT in the form of bonus bets)
Bonus/better winnings paid (in the form of bonus bets/credit)
Winnings paid out even if you don't win (in the form of cash/credit that can be withdrawn)
All other financial incentives (i.e. cash or credit can be withdrawn without betting through)
Reduced commission
Match your stake/deposit with cash or credit
Winnings paid out even if you don't win (in the form of bonus bets/credit)
0%
Onshore
5%
Offshore
10%
15%
20%
25%
30%
Percentage of inducements
Analysis of differences between onshore brands showed that inducements offering refunds in the form
of bonus bets were most commonly promoted by Crownbet (38% of their promotions), followed by
Palmerbet (18%), and Luxbet (13%); this compared with 21% overall. Inducements promoting better
odds were most favoured by Palmerbet (47%), Ladbrokes (35%), and TAB.com (33%). Turning to
offshore brands, refunds in the form of bonus bets constituted 50% of inducements offered by
Betadonis, and 25% of those offered by Betplay; this compared with 14% overall. All of Pinnacle
Sports’ inducements included better odds incentives.
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Figure 4.24 Top two incentive types by brand - onshore
Top two incentive types, by brand - onshore brands
Percentage of each individual brand's inducements
50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
Better odds
Stake back or partial refund (in the form of bonus bets/credit)
Figure 4.25 Top two incentive types by brand - offshore
Top two incentive types, by brand - offshore brands
100%
Percentage of each individual brand's inducements
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
10Bets Sports
Betadonis
Betplay
BetVictor Sports
Intertops
Sportsbook
Stake back or partial refund (in the form of bonus bets/credit)
Victorian Responsible Gambling Foundation
Stan James
Sportsbook
Pinnacle Sports
Stan James
Sportsbook
Better odds
Page 84
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
4.4.4 Monetary value of incentives
Of all inducements, 63% explicitly stipulated a maximum monetary value on the incentive provided.
For some inducements, this stipulation related to the maximum amount that could be won through the
offer, and had a very high threshold. So, for example, one inducement offered 50% better winnings
against multi bets, and the maximum payout was $100,000. A distinction was apparent between limits
on the value of winnings paid out, versus the more ‘direct’ cost to the operator of incentives such as a
refund or sign up offer (which tended to have a much lower threshold). A decision was taken to
exclude those high maximum value inducements where the threshold related to winnings paid out.
This resulted in the exclusion of nine inducements, with values ranging from $500 to $100,000.
Among the remaining (n=131) inducements, the average maximum value was $137 (median $100)
with a mean range from $49 (Stan James Sportsbook) to $550 (Topbetta). Table 4.4 shows the
average maximum monetary value for each of the brands (where a maximum value was specified).
Table 4.4 Average maximum monetary value, by brand
Brand
Topbetta.com.au
Betplay
BetDSI
Betstar.com.au
Intertops Sportsbook
SBOBET
Bookmaker.com.au
Bet365.com.au
Centrebet.com.au
TonyBet
Ladbrokes
Tom Waterhouse.com
Williamhill.com.au
Luxbet.com.au
Sportsbet.com.au
Palmerbet.com.au
Mansion88
10Bets Sports
Betfair.com.au
BetVictor Sports
Crownbet.com.au
Sportsbetting.com.au
TAB.com.au
Stan James Sportsbook
Mean value
$ 550.00
$ 535.87
$ 375.00
$ 362.50
$ 275.49
$ 253.00
$ 200.00
$ 150.00
$ 150.00
$ 141.00
$ 138.89
$ 125.00
$ 123.15
$ 105.77
$ 105.26
$ 91.67
$ 86.00
$ 84.00
$ 75.00
$ 74.50
$ 55.56
$ 50.00
$ 50.00
$ 49.00
The average maximum monetary value of the incentive was higher among offshore brands ($197
compared with $124) (Table 4.5).
Victorian Responsible Gambling Foundation
Page 85
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Table 4.5 Average maximum monetary value, by onshore vs offshore
Onshore
N
5
25
77
Max value
Less than $50
$50 to less than $100
$100 to less than $500
$500 to less than $1,000
$1,000 to less than $1,500
Grand Total
Mean value
Median value
2
109
$124.32
$100.00
%
5%
23%
71%
0%
2%
100%
Offshore
N
9
2
9
1
1
22
$196.94
$85.00
Total
N
14
27
86
1
3
131
$136.52
$100.00
%
41%
9%
41%
5%
5%
100%
%
11%
21%
66%
1%
2%
100%
The average incentive amount differed between inducement types (Table 4.6). For example, the
average maximum value of sign up offers was $200, whereas refer a friend offers had an average
threshold of $69. Wagering inducements which offered to match a bettor’s stake had an average
mean cap of $58, and those that offered to refund a losing bet had a mean cap of $85. The
inducements with the highest payouts were competitions ($1,305) and free bets for randomly selected
punters ($857).
Table 4.6 Average maximum monetary value, by type of inducement
Inducement type
Competitions (where payout is in bonus bets)
Free bets (randomly selected punters)
Sign up offer
Bonus or better odds (not including Happy Hour type inducements)
Bonus or better winnings
Cash rebate (no play through required)
Multi bet offer
Refund/stake back (or partial) offer
Mobile betting offer
Refer a friend offer
Match (or partially match) your stake/deposit (with bonus bets)
Happy hour or similar offer
Mean value
$ 1,304.97
$ 857.24
$ 199.65
$ 150.50
$ 142.86
$ 125.00
$ 101.33
$
84.84
$
74.50
$
69.02
$
58.00
$
57.62
4.4.5 Sporting or racing
A third (32%) of inducements were related to racing, 50% to sports and 18% had no restrictions.
Onshore and offshore brands provided a nearly equal proportion of sports betting inducements, while
offshore brands tended to provide more inducements that applied to either code Table 4.7).
Table 4.7 Type of activity, by whether onshore or offshore
Max value
No restrictions
Racing
Sports
Grand Total
Onshore
N
25
62
87
174
Victorian Responsible Gambling Foundation
%
14%
36%
50%
100%
Offshore
N
15
9
25
49
%
31%
18%
51%
100%
Total
N
40
71
112
223
%
18%
32%
50%
100%
Page 86
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Table 4.8 shows how the different brands allocated their inducements to sports versus racing
activities, versus no restrictions.
Table 4.8 Type of activity, by brand
Type of inducement
10Bets Sports
Bet365.com.au
Betadonis
BetDSI
Betfair.com.au
Betjack/Marathon Bet
Betplay
Betstar.com.au
BetVictor Sports
Bookmaker.com.au
Centrebet.com.au
Crownbet.com.au
Intertops Sportsbook
Ladbrokes
Luxbet.com.au
Mansion88
Palmerbet.com.au
Pinnacle Sports
SBOBET
Sportsbet.com.au
Sportsbetting.com.au
Stan James Sportsbook
TAB.com.au
Tom Waterhouse.com
TonyBet
Topbetta.com.au
Williamhill.com.au
Grand Total
Racing
N
1
7
1
2
1
3
4
1
6
10
5
3
4
2
6
5
2
8
71
%
20%
41%
0%
25%
67%
0%
25%
60%
0%
67%
13%
29%
0%
43%
36%
0%
20%
0%
0%
20%
67%
60%
0%
38%
0%
50%
50%
32%
Sports
N
3
8
1
3
1
1
4
13
4
10
7
5
10
4
14
3
6
6
1
1
7
112
%
60%
47%
50%
0%
0%
0%
75%
20%
50%
0%
50%
62%
57%
43%
50%
83%
67%
100%
0%
70%
0%
30%
100%
46%
50%
25%
44%
50%
No restriction
N
%
1
20%
2
12%
1
50%
3
75%
1
33%
2
100%
0%
1
20%
1
50%
2
33%
3
38%
2
10%
3
43%
3
13%
2
14%
1
17%
2
13%
0%
1
100%
2
10%
1
33%
1
10%
0%
2
15%
1
50%
1
25%
1
6%
40
18%
As Table 4.9 shows, multi bet offers were almost exclusively targeted at sporting events (95%),
whereas the payment of winnings on losing bets was more commonly associated with racing events
(75%) – because of the high number of ‘protest payout’ inducements in this category. Refund offers
were more commonly restricted to sporting events (70%) whereas offers which matched the stake
were equally split between racing, sports and no restrictions (33% in each).
Victorian Responsible Gambling Foundation
Page 87
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Table 4.9 Type of inducement, by activity
Type of inducement
Sign up offer
Refer a friend offer
Happy hour or similar offer
Mobile betting offer
Multi bet offer
Refund/stake back (or partial) offer
Match (or partially match) your stake/deposit
(with bonus bets)
Winnings paid even if you don't win/or there is a
protest/or you win in extra time
Bonus or better odds (not including Happy Hour
type inducements)
Bonus or better winnings
Competitions (where payout is in bonus bets)
Reduced commission
Free bets (randomly selected punters)
Other free bets (e.g. predict the outcome of a
match)
Cash rebate (no play through required)
Grand Total
Racing
N
%
1
3%
Sports
N
%
3
10%
3
1
38%
33%
17
3
28%
33%
4
1
20
42
3
50%
33%
95%
70%
33%
12
75%
4
25%
11
39%
17
61%
15
58%
11
1
42%
100%
2
5
100%
100%
3
75%
1
25%
3
112
75%
50%
40
18%
1
71
25%
32%
No restriction
N
%
26
87%
6
100%
1
13%
1
33%
1
5%
1
2%
3
33%
4.5 Terms and conditions associated with inducements
4.5.1 Overview
The majority of inducement advertisements displayed a number of associated terms and conditions.
Some also (or instead) displayed a hyperlink, within the advertisement, that linked to a number of
terms and conditions that placed restrictions on the take up of that offer. These terms and conditions,
associated directly with the inducement, covered a range of generic restrictions; such as being limited
to one offer per household or account, being restricted to recreational gamblers, and maximum
monetary value of the bet and the payout. These generic conditions were captured in the audit. In
addition, some inducements included restrictions that were highly specific to that offer (e.g. ‘bet must
be placed on race 8 at Sandown’, or ‘the try must be converted within normal time’). These highly
specific criteria were not recorded in the audit due to their sheer volume and variety.
Many wagering inducements also stated that ‘general terms and conditions apply’; in some cases a
hyperlink was provided, but in many cases it was necessary to search the website to locate them. The
general terms and conditions were invariably lengthy documents, relating to general betting rules,
company policy and other offers, as well as (in some cases) providing further details on the
inducement itself. It was not feasible, within the scope of the audit, to also cover these terms and
conditions, particularly since these documents tended to be written in ‘legalese’, in many cases
requiring a legal background to interpret. However, the audit database includes a hyperlink, where
applicable, to these terms and conditions as well as an ‘open text’ field to record more ‘qualitative’
information about the status of the terms and conditions for that brand.
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Whilst this approach was determined by the constraints of the project scope, we would argue that it
exceeds, or at least represents the upper limits of, the likely level of examination of wagering
inducement terms and conditions by an everyday bettor.
Brands differed in the extent to which the inducement terms were directly accessible from the
inducement advert itself (and therefore covered in the audit), versus being consigned to the general
terms document/link (and therefore not covered in the audit). It is important to note, therefore, that just
because a restriction was not recorded against a particular inducement, it does not necessarily follow
that the condition does not apply (as stipulated in the operator’s general terms, somewhere on their
website). The audit is, therefore, likely to underestimate the prevalence of the terms and conditions
captured. It is particularly worth noting that one of the conditions, stipulating whether the bettor must
be a registered account holder, was not always explicit in the terms directly associated with the
inducement. It is likely that this condition would be made clear once the bettor has initiated the
process of taking up the inducement (e.g. through entering their details along with the promotional
code attached to that inducement).
Table 4.9 below shows the prevalence of each of the terms and conditions captured in the audit. It is
important to note that these terms and conditions refer to the bet relating to the inducement itself. So,
for example, a refund/stake back offer applying to a particular horse race might stipulate that it cannot
be used with any other offer, that the minimum odds for that bet must be 1.5, and that it must be used
by a recreational gambler. Similarly, for a sign up offer, restrictions are likely in terms of the number of
days in which the deposit/bet must be placed, the fact that it is restricted to one offer per household,
etc.
As described earlier, a large proportion (53%) of incentives involved the provision of bonus bets.
These bonus bets are themselves associated with a separate raft of terms and conditions (in addition
to the restrictions directed at the inducement itself). It was beyond the scope of this project to capture
these terms and conditions since they relate to future wagering activity, rather than the wagering
activity influenced directly by the marketing of the inducement. However, some examples of the terms
and conditions placed on the use of bonus bets associated with sign up offers were provided earlier.
The table below shows the proportion of all wagering inducements that specified each of the
conditions, both for the overall dataset, and separately for onshore versus offshore brands. As
previously stated, inducements were not always explicit about whether a restriction applied
(sometimes consigning this information to lengthy general terms and conditions documents elsewhere
on the website); therefore, the audit is likely to underestimate the prevalence of these terms and
conditions.
The most common stipulation, applicable to three quarters (76%) of audited inducements, is the
exemption of bonus bets (i.e. a bonus bet cannot be used to obtain the inducement); and this was
particularly true for onshore inducements (82%) compared with those offered by offshore brands
(55%).
The next most common limitation related to the maximum payout available through the inducement
(the values of which are discussed in Section 4.4.4). Two fifths (60%) of all wagering inducements
covered by the audit specified a maximum threshold on payout (either in the form of bonus bets or
cash). Again, this condition was more common among onshore wagering inducements (64%) than
offshore (45%).
Around half of the audit inducements were limited to recreational gamblers (55% overall; 67%
onshore; 14% offshore); were exclusive to registered members (52% overall; 48% onshore; 67%
offshore); and were subject to a time restriction (48% overall; 49% onshore; 43% offshore).
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Two fifths (42%) of wagering inducements stipulated a limit of one per person/account or household,
around twice as many onshore (47%) as offshore (24%) offers.
Around a third of inducements were associated with the following conditions: limited to one per event
(39% overall; 45% onshore and 18% offshore); has a play through requirement (35% overall, 30%
onshore; 53% offshore); and specified a particular betting medium (predominantly online) (36%
overall; 41% onshore; 18% offshore).
A quarter (25%) of audit inducements stated that they could not be used with any other offers (26%
onshore; 22% offshore) and a similar proportion (24%) placed minimum and/or maximum value limits
on the associated bet (18% onshore; 45% offshore). Just over a quarter of onshore inducements
(27%) were limited to particular jurisdictions; this information was not collected for offshore brands
(see Section 4.5.3 for more details on jurisdictional restrictions).
Finally, the least prevalent of the recorded terms and conditions, was the explicit requirement for a
minimum odds threshold with the associated bet, and this accounted for 13% of the total (9% onshore
and 24% offshore).
Table 4.10 Overview of restrictions, by whether onshore or offshore
Restrictions
Must be registered member
Has a limit of one per person/household
Has a limit of one per event
Has a minimum odds limit
Is only available for a specified period
Has a time restriction on when bet/deposit must
be placed
Cannot be used with any other offers
For recreational gamblers only
Has jurisdictional restrictions (within Australia)
Has a play through requirement
Must be placed via a particular medium
Bonus bets not eligible for use with inducement
Has a minimum/ maximum bet/ deposit limit
Has a maximum payout
Onshore
N
%
83
48%
82
47%
79
45%
16
9%
27
16%
85
49%
Offshore
N
%
33
67%
12
24%
9
18%
12
24%
13
27%
21
43%
Total
N
116
94
88
28
40
106
%
52%
42%
39%
13%
18%
48%
45
116
47
53
72
143
31
112
11
7
22%
14%
26
9
27
22
22
53%
18%
55%
45%
45%
56
123
47
79
81
170
53
134
25%
55%
21%
35%
36%
76%
24%
60%
26%
67%
27%
30%
41%
82%
18%
64%
Some of these terms and conditions – play through restrictions, jurisdictional restrictions, and betting
medium – are examined in further detail in the remainder of this section.
4.5.2 Play through restrictions
As previously discussed, just over a third (35%) of all inducements had a play through restriction
specified. As noted earlier, play through requirements may apply to the bonus amount itself, to the
bonus amount plus the stake required to attract the bonus, to the winnings obtained through using the
bonus amount, or to a combination of these amounts. The mean number of times the bet (and/or
stake, and/or winnings) needed to be played through (among those inducements with a play through
restriction) was 2.7. This figure was substantially higher among offshore brands (5.8) than onshore
brands (1.1). The vast majority of onshore inducements stipulated that the amount needed to be
played through once. Two onshore inducements had to be played through twice, but there were no
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
higher play-through requirements than this imposed by onshore brands. The highest individual play
through requirement was associated with a sign up offer from (offshore) Intertops Sportsbook, for a
US$20 bet token (AU$26.10 worth of bonus bets), which had to be played through 16 times. This
amounts to AU$417.60 worth of wagering, in addition to the customer’s own, self-initiated first bet.8
Table 4.11 shows the average play through requirements by brand, for those brands which specified
inducements with play through requirements.
Table 4.11 Average play through requirements, by brand
Brand
TonyBet
SBOBET
Betadonis
Intertops Sportsbook
BetDSI
Mansion88
Betplay
BetVictor Sports
10Bets Sports
Betjack
Sportsbetting.com.au
Palmerbet.com.au
Crownbet.com.au
Bet365.com.au
Betfair.com.au
Betstar.com.au
Bookmaker.com.au
Centrebet.com.au
Ladbrokes
Luxbet.com.au
Sportsbet.com.au
Tom Waterhouse.com
Topbetta.com.au
Williamhill.com.au
Grand Total
Mean value
12.0
10.0
9.5
9.0
6.0
4.8
4.3
4.0
3.0
3.0
2.0
1.6
1.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
2.7
As Table 4.12 shows, mobile betting offers were associated with the highest play through
requirements overall (5), followed by sign up offers (4.8) and happy hour offers (3.3). When onshore
and offshore inducement types were analysed separately, offshore sign up offers had the highest play
through requirements, with an average of 8.4 times. Similarly, offshore happy hour offers had notably
higher play through requirements (5.5) when analysed separately from onshore inducements of the
same type.
8
Among other conditions, to obtain this bonus bet, customers must sign up, make a deposit and a first wager of at least
AU$26.10.
Victorian Responsible Gambling Foundation
Page 91
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Table 4.12 Average play through requirements, by type of inducement
Inducement type
Mobile betting offer
Sign up offer
Happy hour or similar offer
Cash rebate (no playthrough required)
Refer a friend offer
Match (or partially match) your stake/deposit (with bonus bets)
Refund/stake back (or partial) offer
Bonus or better winnings
Free bets (randomly selected punters)
Multi bet offer
Other free bets (e.g. predict the outcome of a match)
Grand Total
Onshore
1.1
1
1.3
1
1.2
1
1
1
1
1.1
Mean value
Offshore
5
8.4
5.5
3
4.5
3.3
3.7
1
1
5.8
Total
5
4.8
3.3
3
2.6
2
1.5
1
1
1
1
2.7
4.5.3 Jurisdictional restrictions
For onshore inducements, the audit recorded whether there were jurisdictional exclusions. This
information was not recorded for offshore brands.
Just over a quarter (27%) of Australian inducements were subject to jurisdictional restrictions. No
jurisdictional restrictions were placed on bettors from the Australian Capital Territory, the Northern
Territory, Queensland or Tasmania; however, 24% of Australian inducements excluded bettors from
New South Wales, 24% excluded bettors from South Australia, 21% excluded bettors from Western
Australia, and 14% excluded bettors from Victoria.
William Hill was the brand most likely to promote inducements with jurisdictional restrictions (75%),
followed by Centrebet (63%), and Tom Waterhouse (62%). Crownbet (5%) and Sportsbet (10%) were
the least likely. These details are shown in Table 4.13. Five onshore brands did not specify
jurisdictional restrictions, and are therefore not included in the table .
Table 4.13 Jurisdictional restrictions, by brand
Brand
Williamhill.com.au
Centrebet.com.au
Tom Waterhouse.com
Palmerbet.com.au
Bookmaker.com.au
Sportsbetting.com.au
Topbetta.com.au
Betstar.com.au
Luxbet.com.au
Ladbrokes
Bet365.com.au
Sportsbet.com.au
Crownbet.com.au
Grand Total
Within restrictions
N
%
12
75%
5
63%
8
62%
7
47%
2
33%
1
33%
1
25%
1
20%
2
14%
3
13%
2
12%
2
10%
1
5%
47
Victorian Responsible Gambling Foundation
Page 92
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Exclusions on Australian jurisdictions were most common among (but not restricted to) sign up and
refer a friend offers. Table 4.14 shows the proportion of each type of inducement where a jurisdictional
restriction was stated in the associated terms and conditions.
Table 4.14 Jurisdictional restrictions, by type of inducement
Type of inducement
Mobile betting offer
Sign up offer
Refer a friend offer
Happy hour or similar offer
Bonus or better winnings
Refund/stake back (or partial) offer
Multi bet offer
Winnings paid even if you don't win/or there is a protest/or you win in extra time
Bonus or better odds (not including Happy Hour type inducements)
Match (or partially match) your stake/deposit (with bonus bets)
Reduced commission
Free bets (randomly selected punters)
Other free bets (e.g. predict the outcome of a match)
Grand Total
With restrictions
N
%
1
100%
17
94%
3
75%
2
40%
9
31%
12
22%
3
16%
0%
0%
0%
0%
0%
0%
47
27%
4.5.4 Restrictions on betting medium
Just over a third (36%) of inducements were subject to a stated restriction on the medium to be used
in placing the bet. As well as recording whether a restriction was in place, the relevant medium or
media were also recorded. Note that more than one medium could be coded, and so the percentages
in Table 4.15 sum to more than 100.
The vast majority of inducements with medium restrictions (96%) stipulated that the bet must be
placed online (97% onshore and 89% offshore); 46% via a smartphone or tablet, and 5% through
calling a landline.
Table 4.15 Restrictions on medium, by whether onshore or offshore (% of inducements with a
medium restriction)9
Max value
Online
Smartphone or tablet
Phone (call a number)
Base
Onshore
N
70
34
2
72
%
97%
47%
3%
Offshore
N
8
4
2
10
%
89%
33%
22%
Total
N
78
38
4
82
%
96%
46%
5%
9
Note that more than one type of medium was sometimes specified, so the sum of inducements which specified each
medium is greater than the total number which specified medium requirements.
Victorian Responsible Gambling Foundation
Page 93
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Table 4.16 shows the percentage of each brand’s inducements stipulating that the bet must be placed
through a particular medium (or media). It shows that the prevalence of medium restrictions varied by
brand, ranging from no restrictions through to 86% of offers promoted by Crownbet. Table 4.17 shows,
for those with a restriction, the medium specified (by brand).
Table 4.16 Has a restriction on medium, by brand (% of brand’s inducements)
Brand
% with a
medium
restriction
90%
86%
80%
75%
69%
50%
50%
40%
40%
25%
21%
6%
4%
Sportsbet.com.au
Crownbet.com.au
10Bets Sports
Williamhill.com.au
Tom Waterhouse.com
Centrebet.com.au
TonyBet
Palmerbet.com.au
Stan James Sportsbook
Betplay
Luxbet.com.au
Bet365.com.au
Ladbrokes
Table 4.17 Restrictions on medium, by brand (% of inducements with a medium restriction)
Online
Brand
Crownbet.com.au
Sportsbet.com.au
Williamhill.com.au
Tom Waterhouse.com
Palmerbet.com.au
10Bets Sports
Centrebet.com.au
Stan James Sportsbook
Luxbet.com.au
Bet365.com.au
Betplay
Ladbrokes
TonyBet
Grand Total
N
17
18
12
9
6
4
4
3
3
%
94%
100%
100%
100%
100%
100%
100%
75%
100%
1
1
78
100%
100%
96%
Smartphone or
tablet
Phone (call a
number)
N
4
5
12
5
4
%
22%
28%
100%
56%
67%
N
1
1
%
6%
6%
1
3
1
1
1
1
25%
75%
33%
100%
100%
100%
2
50%
38
46%
4
5%
Total with
a medium
restriction
N
18
18
12
9
6
4
4
4
3
1
1
1
1
82
Apart from mobile betting offers, which overtly set the use of a mobile medium as a prerequisite for
eligibility (100%), multi bet and refund/stake back (or partial) offers were the inducement types that
most frequently specified that a particular medium must be used (62% and 52% respectively), as
shown in Table 4.18.
Table 4.19 indicates that inducements which had medium restrictions usually required online access
generally, although many were also specifically limited to mobile online access. Besides mobile betting
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
offers (100%), bonus or better winnings and bonus or better odds were the inducement types that
most often stated that a smartphone (or tablet) must be used (78% and 75% respectively).
Table 4.18 Has a restriction on medium, by inducement type (% of type’s inducements)
Inducement type
Sign up offer
Refer a friend offer
Happy hour or similar offer
Mobile betting offer
Multi bet offer
Refund/stake back (or partial) offer
Match (or partially match) your stake/deposit (with bonus bets)
Winnings paid even if you don't win/or there is a protest/or you win in extra time
Bonus or better odds (not including Happy Hour type inducements)
Bonus or better winnings
Other free bets (e.g. predict the outcome of a match)
% with a
medium
restriction
23%
17%
50%
100%
62%
52%
33%
38%
16%
31%
25%
Table 4.19 Restrictions on medium, by type of inducement (% of inducements with a medium
restriction)
Online
Inducement type
Sign up offer
Refer a friend offer
Happy hour or similar offer
Mobile betting offer
Multi bet offer
Refund/stake back (or partial) offer
Match (or partially match) your
stake/deposit (with bonus bets)
Winnings paid even if you don't win/or
there is a protest/or you win in extra
time
Bonus or better odds (not including
Happy Hour type inducements)
Bonus or better winnings
Other free bets (e.g. predict the
outcome of a match)
Smartphone or Phone (call a
tablet
number)
N
7
1
4
%
100%
100%
100%
N
%
N
2
%
29%
25%
100%
38%
48%
33%
1
25%
100%
100%
100%
1
3
5
15
1
13
31
3
6
100%
2
33%
4
100%
3
75%
9
100%
7
1
78%
100%
Total with a
medium
restriction
N
7
1
4
3
13
31
3
6
1
25%
4
9
1
4.6 Responsible gambling messaging
Recording the features of the websites’ messaging around responsible gambling was challenging in
that the description/assessment of important factors such as the prominence and comprehensiveness
of such information is both subjective and difficult to reduce down to quantitative measures. The audit
aimed to capture characteristics that could easily be quantified and, therefore, the following factors
were recorded (where present):
Victorian Responsible Gambling Foundation
Page 95
Review and analysis of sports and race betting inducements

Hing, Sproston, Brading & Brook
A responsible gambling message is directly linked to, or embedded within, the inducement
advertisement:
(If yes) that message provides a hyperlink to further information in a new tab or webpage.

A responsible gambling message is visible, for example, if you scroll down to the bottom of the
home page:
(If yes) that message provides a hyperlink to further information in a new tab or webpage.
Figure 4.26 Example of a responsible gambling message embedded within the inducement (not
hyperlinked)
Figure 4.27 Example of a responsible gambling message when scrolled to the bottom of the
promotions page (contains hyperlink)
Victorian Responsible Gambling Foundation
Page 96
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
In addition to these four quantitative fields, an ‘open text’ field was included in the database in order to
record more ‘qualitative’ information, describing the perceived prominence, and comprehensiveness,
of the messaging. The remainder of this chapter focuses on the four quantitative variables.
The majority (88%) of inducements did not have any reference to responsible gambling embedded or
attached to them. However, most (95%) of the websites had a responsible gambling message on the
home page, which could be scrolled down to while the inducement advertisement was still open.
Of those with a responsible gambling message, 99% included a hyperlink to another page or site
related to responsible gambling. This constituted 94% overall.
Onshore brands were more likely than offshore brands to promote responsible gambling messages on
their home page (100% compared with 78%).
Table 4.20 summarises these results.
Table 4.20 Responsible gambling messaging, by whether onshore or offshore
Max value
Embedded in inducement
At bottom of page
Link to another page/site
No message
Base
Onshore
N
22
174
174
0
174
%
13%
100%
100%
0%
Offshore
N
4
38
36
11
49
%
8%
78%
73%
22%
Total
N
26
212
210
11
223
%
12%
95%
94%
5%
Table 4.21 shows a tick against each brand to indicate whether its inducements had a message
embedded/directly linked to the advertisement, and/or whether there was a responsible gambling
message at the bottom of the home page (or neither).
Victorian Responsible Gambling Foundation
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Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Table 4.21 Responsible gambling messaging, by brand
Brand
Embedded in
inducement
N
%
10Bets Sports
Bet365.com.au
Betadonis
BetDSI
Betfair.com.au
3
100%
2
25%
3
13%
Sportsbetting.com.au
1
33%
Stan James Sportsbook
4
40%
TAB.com.au
6
100%
Tom Waterhouse.com
3
23%
4
100%
26
12%
Marathon Bet
Betplay
Betstar.com.au
BetVictor Sports
Bookmaker.com.au
Centrebet.com.au
Crownbet.com.au
Intertops Sportsbook
Ladbrokes
Luxbet.com.au
Mansion88
Palmerbet.com.au
Pinnacle Sports
SBOBET
Sportsbet.com.au
TonyBet
Topbetta.com.au
Williamhill.com.au
Grand Total
At bottom of
page
True
Link to another
page/site
True
No message
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True
4.7 Chapter summary
The audit recorded the features of 223 wagering inducements, advertised on the websites of 30
brands (18 onshore and 12 offshore). A higher ratio of wagering inducements encouraged betting on
sports (50%) than racing (32%). The remaining 18% did not stipulate a particular code (most of these
were sign up offers).
Fifteen types of wagering inducement were classified; the most common of which were refund/stake
back offers for unsuccessful bets (27% of inducements), sign up offers for new customers (13%),
bonus or better odds (13%) and bonus or better winnings (12%). Onshore and offshore brands
differed in their marketing strategies, with onshore brands favouring refund offers (31% of onshore
wagering inducements) and offshore brands being more likely to promote sign up offers (24% of
offshore inducements).
Victorian Responsible Gambling Foundation
Page 98
Review and analysis of sports and race betting inducements
Hing, Sproston, Brading & Brook
Wagering inducements offered a variety of incentives, including refunding the stake in the form of
bonus bets (21%), improved odds (15%), matching the stake/deposit with bonus bets (14%), and
refunding the stake in cash (12%).
Bonus bets were invariably associated with ‘play through’ conditions, requiring the bettor to bet
through the bonus amount and/or initial stake and/or winnings at least once, before the bonus bet (and
sometimes the initial deposit and/or winnings) could be withdrawn/accessed.
The average maximum monetary value of incentives (where this could be established) was $137
(median $100). The average maximum financial incentive varied substantially between brands, from
$49 for Stan James Sportsbook through to $550 for Topbetta.com. Offshore brands tended to offer
higher value incentives (mean $197) than onshore brands (mean $124); but their play through
requirements were also higher (5.8 times on average, compared with an average of 1.1 among
onshore brands).
The two wagering inducement types offering the highest financial incentive were competitions offering
a prize of bonus bets ($1,305) and free bets for randomly selected punters ($857); these comprised
only a very small proportion of inducements (<2% combined). The strategic importance of attracting
new customers (sign up offers comprised 13% of inducements) was reflected in the associated
financial incentive ($200 overall; $226 onshore and $146 offshore); whereas promotions involving the
refund of non-winning stakes, which were more prevalent (27%), had a lower average maximum value
($85; $80 onshore and $169 offshore).
Wagering inducements were associated with a variety of terms and conditions (in addition to the play
through requirements discussed above) restricting their use. It is important to note that the audit
captured only a subset of these restrictions – those that were explicitly stated within, or directly
attached to, the inducement advertisement (due to the sheer volume and variety of terms and
conditions). These are summarised below:

Three quarters (76%) of inducements stipulated that bonus bets were exempt, and this was
particularly true of onshore inducements (82%) compared with those offered by offshore
brands (55%).

Two fifths (60%) of wagering inducements specified a maximum payout (64% onshore vs 45%
offshore).

Just over a quarter (27%) of Australian inducements were limited to particular jurisdictions;
mainly reflecting the fact that sign up and refer a friend promotions are prohibited in NSW, SA,
WA and Victoria.

Around half of the audit inducements (55%) explicitly stated that they were limited to
‘recreational gamblers’ (67% onshore vs 14% offshore) and a similar proportion (52% overall)
were exclusive to registered members (48% onshore and 67% offshore).

Two fifths (42%) of wagering inducements were limited to one offer per
person/account/household, around twice as many onshore (47%) as offshore (24%)
promotions.

Around a third of inducements were limited to one per event (39%), had a play through
requirement (35%), and specified a particular betting medium (36%).

A quarter (25%) stated that they could not be used with any other offer, and 24% placed
minimum and/or maximum value limits on the associated bet.

Finally, just over one in ten (13%) of audit inducements placed a minimum odds threshold on
the associated bet.
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Chapter Five: Discussion
5.1 Introduction
This chapter analyses the results of the study to discuss the main characteristics of wagering
inducements, their features that potentially encourage the commencement, continuation and
intensification of betting, and key considerations for harm minimisation and consumer protection.
5.2 Main characteristics of inducements
5.2.1 Prominence of inducements
Inducements were generally prominently displayed on operator websites, most often as colourful, eyecatching static or scrolling displays. While some inducements were confined to a specific promotions
or specials page that linked to the homepage, inducements were also frequently present on the
homepage, and were sometimes launched as full-page displays on opening the website (which then
had to be navigated past to get to the home page). Due to the prominence and placement of
inducements, customers would not be able to avoid seeing at least some of those on offer when
visiting most operator websites.
It was not within the project scope to examine the promotion of inducements on betting apps and in
other media. However, previous research indicates that wagering inducements are widely promoted in
a range of traditional and digital media, and through mass media, social media and personalised
communications sent directly to customers (Gainsbury, Delfabbro et al., 2015; Sproston et al., 2015).
Inducements are also heavily promoted on television when sporting and racing events are broadcast
(Milner et al., 2013; Sproston et al., 2015; Thomas et al., 2012a). Thus, the promotion of inducements
is a frequent feature of wagering marketing in Australia and this study has documented their prominent
and ongoing promotion through operator websites.
5.2.2 Most inducements change frequently, but some are perennial
Continual changes to the inducements offered during the audit period reflected the specific nature of
the bets/events to which they applied, although the audit’s classification of inducements into 15 overall
categories indicates that most are variations on a limited range of generic types. Not only did the
details of inducements change frequently, they also increased towards the end of the week in the
lead-up to weekend sports and racing events. This frequent refreshment of many inducements
provides a steady and continual stream of new short-term offers which may help to keep the betting
product interesting for customers and encourage frequent visitation to wagering sites to stay informed
about the latest offers. Previous research has also shown distinct seasonal variations in wagering
marketing, with increases prior to major events (Gainsbury, Delfabbro et al., 2015; Sproston et al.,
2015); however, this was not able to be measured in the short time frame of the current study.
Inducements that largely remained unchanged throughout the audit period were those specifically
targeting new customers: sign up bonuses and refer a friend offers. Attracting new customers is
clearly of high priority for wagering operators, with one company reporting in February 2014 that it was
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spending an average of AU$561 to sign up each new customer to one of its three Australian sites
(William Hill, 2014). Because these recruitment inducements were not tied to specific bets or events,
they did not need to be continually updated, although it is interesting to note that some brands did
alter the value of their sign up bonus during the audit period. The reason for this is unknown.
5.2.3 All inducements are price promotions
All inducements identified in the audit were price promotions offering temporary price cuts, monetary
savings, bonus bets or refunds. The incentive in each was some kind of financial bonus, mainly in the
form of bonus or ‘free bets’ (although with conditions on use and redemption). Previous research has
found that, amongst different types of sales promotions, price promotions are most effective in
inducing purchase acceleration and more spending (Shi et al., 2005) and substantially increase shortterm sales, sales of complementary items and store traffic (Blattberg et al., 1995). Thus, wagering
inducements offering price promotions may be likely to increase visits to operator websites, sales of
the incentivised bets, and sales of additional bets.
However, continual price discounting risks lowering consumers’ reference point, and can result in a
‘race to the bottom’ amongst brands in a highly competitive price war. This encourages bettors to
search for the best deals amongst operators, which has been facilitated by the emergence of websites
dedicated to comparing wagering inducements. This shopping around is a common practice reported
by bettors (Hing, Cherney et al., 2014a, 2014b; Thomas et al., 2012b), thus undermining rather than
boosting brand loyalty. Lower prices across the industry offer savings for customers on individual bets,
but are also likely to result in increased product usage, betting with multiple wagering operators, and
increased exposure to a plethora of marketing communications received as each additional betting
account is opened.
Both alcohol and tobacco pricing has been found to have public health effects. A systematic review
(Brennan, O’Reilly, Purshouse & Taylor, 2008) found that increases in the price of alcohol reduce
alcohol consumption, hazardous and harmful alcohol consumption, alcohol dependence, the harm
done by alcohol, and the harm done by alcohol to others than the drinker. Similarly, research has
found strong support for an inverse relationship between price and cigarette smoking (Gallus,
Schiaffino, La Vecchia, Townsend, & Fernandez, 2006; Scollo, Younie, Wakefield, Freeman &
Icasiano, 2003). Thus, lowering the price of betting is likely to increase overall betting consumption,
although the differential effects on non-problem, at-risk and problem gamblers has yet to be
ascertained.
5.2.4 Wide range of inducements and incentives
The inducements identified in the audit were classified into 15 different types, reflecting the wide array
on offer, especially when the continual changes to specific bets and events they applied to are also
considered. These inducements include diverse incentives to overcome consumer inertia related to
purchasing and appear to have variable aims.
Refund/stake back offers and winnings paid for losing bets are aimed at lowering perceived risk, while
inducements for multi bets might be considered a means of increasing the volume of bets, as are
some free bet offers (e.g. qualify for $1,000 in free bets if a bet is placed on every race that day at a
particular race meeting). Mobile betting inducements are clearly attempting to convert customers to
betting via smartphones and tablets so that future betting is more easily accessible, anywhere and at
any time. The payment of incentives in bonus bets or deposits with play through conditions before any
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winnings can be withdrawn locks customers into future betting with the operator. Provision of better
odds is a competitive strategy to attract bettors away from rival operators and build market share.
Offering better odds and winnings, matching stakes and reduced commissions for specific events
appear to be mostly aimed at stimulating sales through triggering more betting.
A few inducements focused on rewarding past behaviour, such as awards for the most successful
multi bet. However, this had the dual purpose of also encouraging continuation of betting by paying
the award in bonus bets. Thus, while all inducements aimed to increase sales, they presented
customers with a wide array of incentives to overcome psychological, risk or competitive barriers to
their purchasing and their future purchasing.
5.2.5 Many inducements are for complex bet types and combined
contingencies
Bet types range from simple win bets placed on match outcomes to highly specific bets on particular
in-match events and contingencies (Newall, 2015). Many wagering inducements are for complex bets,
which present difficulties for customers in working out the probabilities of winning. For example,
estimating the probability of a particular player scoring the first try is a highly complex calculation
which would require knowledge of the form of all players on the team and their relative
competitiveness against the opposing team. Some wagering inducements involve combinations of
contingencies, such as: if your team leads at half time but then loses; if your team achieves a
minimum specified score but then loses; if you pick the first try-scorer and he goes on to score another
try; and if your team wins and your selected player scores. These bets combine two outcomes, which
adds further complexity to understanding the true odds of winning and being able to search for the
best deal (Newall, 2015). Under conditions of complex probabilities such as these, people tend to rely
on heuristics (mental shortcuts) when making decisions and these can be subject to cognitive biases
which overestimate the probabilities of winning (Tversky & Kahneman, 1974).
The audit showed that incentivised bets were frequently for complex and combined bets. While these
bet types may add excitement and entertainment value for customers, associated inducements can
encourage customers towards bets that have higher expected losses. This trend has been found in
other research; an analysis of special bets offered by UK bookmakers during the 2014 soccer World
Cup found that they almost exclusively advertised complex bet types with high expected losses
(Newall, 2015). Further, people tend to overestimate the probability of finely partitioned bets,
suggesting that operators may be able to offer worse odds than the actual probability would suggest
and still attract customers (Newall, 2015). Bet types for which inducements were provided in the audit
may have a similar tendency.
It was outside the scope of the present study to calculate and compare expected operator margins on
different bet types for which inducements were offered, but this would be a useful exercise for future
research to see whether incentivised bets have higher, lower or equivalent expected losses compared
to non-incentivised bets. Examination of wagering operator data would also be insightful. Gainsbury
and Russell (2015) examined a year’s betting data from one Australian wagering operator. Highest
losses were for multi bets and exotic bets, where 88.8% and 86.6% of those bets, respectively, were
losses compared to 60.4% of place bets and 79.5% of win bets. The authors concluded that exotic
bets and multi bets are relatively risky, as they require several predictions to be fulfilled, although, as a
result they generally give a larger return if successful. This return may be even higher if accompanied
by a monetary incentive; nevertheless, many wagering inducements appear to be for the types of bets
that have a comparatively low probability of winning.
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5.2.6 Most common types of inducements
Four types of inducements made up nearly two-thirds (64%) of all inducements in the audit. The most
prominent were refunds/stake back offers which comprised 27% of all inducements. As noted above,
these help to lower perceived risk but also encourage future betting as the refund/stake back is nearly
always provided as bonus bets or deposits with play through conditions. This predominance of
refunds/stake back offers appears to align with customer preferences. A quasi-experimental study
comparing sports bettors’ responses to different marketing message elements (Hing, Vitartas et al.,
2014a) found that, of all bet types examined, a bet with a ‘risk-free’ offer elicited most interest,
temptation and likelihood of placing the promoted bet. This result was consistent amongst the 200
regular sports bettors, 207 non-regular sports bettors, and 204 non-sports bettors in the study, as well
as amongst all PGSI groups.
The three other most common inducement types found in the audit were sign up offers (13% of all
inducements), bonus or better odds (13%), and bonus or better winnings (12%). The latter two types
of inducement were very similar and the associated bonus was sometimes paid in cash. However, the
cash payout or bonus was usually tied to very specific and complex bets which often had combined
contingencies, such as picking the first try scorer and that try then being converted. As discussed
above, complex and combined contingencies in bets typically have high expected losses (Newall,
2015). Thus, the most prominent inducements in the audit lowered perceived risk, encouraged future
betting, aimed to attract new customers, and offered cash and other bonuses on bets with low
probabilities of winning. The most prominent inducement also aligned with customer preferences for
‘risk-free’ bets.
5.2.7 Inducements used by new entrants
It is of interest to note that the highest number of inducements in the audit was provided by the newest
entrant to the Australian wagering market, Crownbet. This finding suggests that new operators
perceive that inducements are needed to build brand awareness and market share, and that the
licensing of additional wagering operators is likely to increase the volume of incentives marketed to
bettors. Crownbet’s main type of inducement was the refund/stake back offer which constituted nearly
60% of its inducements offered during the audit period. However, it provided the lowest number of sign
up offers amongst all brands, which may reflect its business base in the state of Victoria where these
inducements are prohibited. Crownbet was also the most likely amongst all brands to provide
incentives in the form of bonus bets, but the least likely to provide incentives in the form of better odds.
As noted above, bonus bets typically have play through conditions, while bonus odds typically
increase the cash payout. Thus, providing incentives that prompt future betting with the operator
appears to be considered highly important by a new entrant.
5.2.8 Differences between onshore and offshore inducements
Several differences were observed in the inducements provided by the onshore and offshore
operators. Inducements were more common amongst onshore brands, and the five brands providing
the highest share of inducements were all Australian licensed operators. On average, onshore
operators had 11.6 inducements, while offshore operators offered an average of 4.1 inducements.
This may reflect the highly competitive nature of the industry in Australia, as discussed in Chapter
Two, as well as tighter restrictions for other types of advertising. Just as the prohibition of live betting
odds promotions during televised sports broadcasts prompted higher expenditure by gambling
operators on paid advertising (Schetzer, 2014), this prohibition may have similarly increased the
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promotion of wagering inducements on websites and in other digital media, due to the comparatively
liberal regulatory environment applying to wagering inducements.
The most common inducements provided by onshore brands were refund/stake back offers which, as
noted above, appear to be particularly appealing to Australian sports bettors (Hing, Vitartas et al.,
2014a). In contrast, offshore brands promoted a higher proportion of sign up offers, which may reflect
the prohibition of these inducements in several Australian jurisdictions. These differences were also
reflected in the incentives most commonly offered, with onshore brands most often providing bonus
bets/credit, while offshore brands most often provided matching deposits. The average maximum
monetary value of the incentive was also higher among offshore brands ($197) compared to onshore
brands ($124), which may reflect the more generous and widespread sign up offers being promoted
by offshore operators.
Some terms and conditions were more common amongst onshore brands. These included exemption
of bonus bets, a specified maximum threshold on the payout, a limit of one incentivised bet per
person/account or household, a limit of one incentivised bet per event, and limited to a particular
betting medium (predominantly online). Offshore brands were more likely to have a play through
requirement and to stipulate multiple play throughs (average 5.8 times), compared to onshore brands
that required bonuses to be played through an average of 1.1 times. Thus, onshore operators had
more modest and reasonable play through requirements, on average, compared to offshore operators.
5.2.9 Sports betting inducements vs race betting inducements
The majority of inducements in the audit for were for sports betting(50%), while 32% were for race
betting, and the remaining 18% applied to both. This pattern was the same for onshore and offshore
operators and reflects the global growth potential in the sports betting market, compared to the more
mature market for race betting. As discussed in Chapter Two, sports betting represents a lucrative
market showing both increased numbers of participants and increased per capita expenditure in
recent years (Queensland Government, 2014) with substantial future growth predicted (Morgan
Stanley, 2014). Its target market of young adult males of higher socio-economic status, employed full
time, better educated and with access to the Internet (Palmer, 2014) is one with disposable income,
and operators would be keen to attract and retain them through offering a wide range of attractive
inducements to bet. As only about 13% of Australian adults bet on sports, compared to 22% who
participate in race betting (Gainsbury, Russell et al., 2015a), significant growth potential remains in the
sports betting market.
Some differences were apparent between the types of inducements offered for sports and race
betting. Multi bet offers were almost exclusively targeted at sporting events (95%), as were the
majority of refund/stake back offers (70%). As noted earlier, these two types of bets appear to be
aimed, respectively, at increasing the volume of bets, and lowering perceived risk while encouraging
future betting. Multi bets have also been found to have high expected losses (Gainsbury & Russell,
2015). In contrast, payment of winnings on losing bets was more commonly associated with racing
events (75%), because of the high number of ‘protest payout’ inducements in this category. The
offering of protest payouts also lowers perceived risk of betting for customers.
5.2.10 Complex terms and conditions
All inducements were subject to certain terms and conditions, and their complexity and lack of
transparency were key characteristics of the inducements audited. Terms and conditions were often
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not contained in the display advertisement itself, but required the customer to click on a link to access
them. Inducements were also typically subject to a raft of general terms and conditions which were
located elsewhere on the operator’s website. In many cases, it was up to the customer to locate these
general terms and conditions, with no direct link provided. The sheer volume of these general terms
and conditions (450 pages for one Australian operator) and their legalistic language meant that it was
not always obvious, and in some cases exceedingly difficult, to know what restrictions applied to a
particular inducement. This hinders transparency and informed choice for customers, as discussed
later.
The most commonly applied terms and conditions, applicable to more than half the inducements
audited, were restrictions on the use of bonus bets (76% of all inducements), restrictions on the
maximum value of the incentive/payout/bonus (60%), limited to recreational gamblers (55%), exclusive
to registered members (52%), and subject to a time restriction (48%). Terms and conditions applying
to more than one-third (but less than half) of the inducements audited were a limit of one per
person/account or household (40%), limited to one per event (39%), a play through requirement
(35%), and limited to a particular betting medium (predominantly online) (35%). Those found in fewer
inducements were that they could not be used with any other offers (26%), had minimum and/or
maximum value limits on the associated bet (18%), were limited to particular jurisdictions (27%,
onshore only audited), and had an explicit requirement for a minimum odds threshold with the
associated bet (13%).
Naturally, terms and conditions varied according to inducement type. Of interest is that play through
requirements were highest for mobile betting offers (5 times), followed by sign up offers (4.8) and
happy hour offers (3.3), although these figures are inflated by the much more stringent play through
requirements of the offshore brands compared to the onshore brands audited. The highest average
play through requirements for onshore brands were for refer a friend offers (1.3 times), refund/stake
back offers (1.2 times) and sign up offers (1.1 times) The potential of play through requirements to
intensify betting is discussed later.
5.2.11 Minimal embedded responsible gambling messages
Very few display advertisements for the inducements audited contained an embedded responsible
gambling message. The majority (88%) did not have any reference to responsible gambling included
or directly attached, although this was slightly higher amongst onshore (13%) compared to offshore
(8%) brands. However, all Australian operators, and 78% of offshore operators, had a responsible
gambling message on their homepage which, in nearly all cases where this was provided, also linked
to another page or site containing responsible gambling information.
However, responsible gambling messages and links were invariably in very small font and often in
non-contrasting colours (e.g. grey writing on a light grey background), making them highly unlikely to
be noticed, difficult to find, and hard to read. This finding is consistent with other research that has
found that the ‘gamble responsibly’ message lacks prominence in wagering marketing (Gainsbury,
Delfabbro et al., 2015; Hing, Vitartas et al., 2014a; Milner et al., 2013; Sproston et al., 2015).
Research has found that this message is overwhelmingly considered ineffective due to low
prominence, poor legibility, lack of resonance, and competition from pervasive wagering marketing,
and therefore tends to be viewed cynically by the Australian public (Lamont et al., in press; Sproston
et al., 2015). Results from the current audit suggest that these messages are highly likely to go
unnoticed when customers view advertisements for wagering inducements on operator websites.
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5.3 Considerations for harm minimisation
Wagering problems have been found to increase with greater frequency and volume of betting (Billi et
al., 2014; LaBrie & Shaffer, 2011; LaPlante et al., 2014; Xuan & Shaffer, 2009), and wagering
inducements aim to encourage these responses amongst bettors. Thus, it is instructive to consider
how wagering inducements may influence the commencement, continuation and intensification of
betting, and the maintenance of problem gambling, in order to assess how they might influence the
consumption and harmful consumption of wagering products. Given that no data were gathered from
bettors for this study, the discussion that follows is based on reason, theory and previous research.
Naturally, empirical research is needed to provide definitive findings, and the issues raised below
should be viewed as considerations rather than conclusions.
5.3.1 Wagering inducements and the commencement of betting
Uptake of betting is specifically encouraged through sign up bonuses that reward the opening of a
betting account with bonus bets. The audit found that the value of these bonus bets ranged from $14
to $1,000, with an average of $200. In the vast majority of cases, the customer needs to first deposit
or bet the equivalent amount to be eligible for the bonus bet. The bonus bet itself and/or the initial
stake and/or any winnings from the bonus bet must then be played through a stipulated number of
times before any winnings can be withdrawn, usually at least once, but for an average of 4.9 times
over all brands covered in the audit (1.1 times onshore vs 8.4 times offshore). Use of the bonus bet is
also time limited, and typically must be used within 30 to 90 days, or forfeited (although one onshore
operator had a seven day time limit). Thus, sign up bonuses incentivise opening an account and
making a deposit or first bet, then making a bet with the bonus bet, and then making at least one
further bet within one or a few months.
Refer a friend offers also aim to encourage commencement of betting by rewarding both the referrer
and the new customer with bonus bets, although the audit found that these inducements are less
commonly offered and less generous in value than sign up bonuses. As with the sign up bonus, bonus
bets for the new recruit are subject to play through conditions, although the mean number of times
was less than for sign up bonuses amongst the brands audited (2.6 times for refer a friend offers vs
4.9 times for sign up bonuses) and less for onshore brands (1.3 times) compared to offshore brands
(4.5 times). No restrictions are applied to the use of bonus bets by the referrer, who can take up this
inducement any number of times. No research has examined the influence of refer a friend offers, but
they clearly capitalise on the power of word-of-mouth and the greater credibility given to friends’
recommendations over paid advertising messages. Being referred to betting by a friend may also help
to normalise the activity and encourage product trial. Affiliate referrals, as explained in Chapter Two,
are another mechanism by which referrals for new recruits are made by third parties, with the referral
incentivised by receiving either an ongoing commission of the recruit’s betting losses or a fixed referral
fee.
It is not known what proportion of customers recruited through sign up, refer a friend and affiliate offers
are new to betting, are existing bettors who are new to online betting, or are existing online bettors
opening additional accounts. Thus, the effects of these recruitment offers on brand switching versus
increased consumption is not known. However, this is a critical issue, as brand switching alone does
not necessarily increase an individual’s betting activity and may result in the individual receiving lower
prices, better services or other benefits which they value. Similarly, existing bettors migrating from
cash betting in retail outlets to account-based betting via the Internet may not necessarily alter the
frequency or volume of their betting activity. However, where these inducements recruit new users,
they necessarily increase those individuals’ consumption of wagering products. The total consumption
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model, predicting that more consumption causes more harm at all levels, is supported in some
previous research (Currie, Hodgins, Wang, el-Guebaly, Wynne & Chen 2006; Currie, Hodgins, Wang,
el-Guebaly, Wynne & Miller, 2008; Rockloff, 2012). However, Binde (2014) argues that the
consumption model may be limited because consumption and problem gambling are not always
linearly related, and different gambling activities and individuals carry different levels of risk. However,
the recruitment of new bettors to the market clearly increases the number of individuals who are
exposed to the risks of betting, and some of these may proceed to develop gambling problems and
experience betting-related harm (Binde, 2014).
Previous research has found that sign up bonuses do encourage some bettors to open accounts
(Hing, Cherney et al., 2014a, 2014b; Sproston et al., 2015; Thomas et al., 2012b). Further, sign up
and refer a friend offers encourage bettors to open multiple accounts. For example, some interviewees
in Hing, Cherney et al.’s studies of Internet gamblers (2014a, 2014b) described how wagering
promotions had prompted them to open accounts and bet with multiple gambling operators. This had
three main reported effects. One was to extend the time spent gambling as these individuals used the
multiple bonus bets received. Where these bonus bets required matching bets or deposits, this also
increased these individuals’ gambling expenditure. A second effect was that some bettors found it
more tempting to place further bets once they had an active account. A third outcome was that each
account opened triggered a plethora of additional inducements conveyed through emails and other
direct marketing channels encouraging additional betting. For some, the offers of free bets, matching
deposits and ‘risk-free’ bets resulted in them gambling more than intended. (Hing, Cherney et al.,
2014a, 2014b). Further, research with 3,178 Australian Internet gamblers found that multiple account
holders are more involved gamblers, gambling on more activities and more frequently, and with higher
rates of gambling problems than single account holders (Gainsbury, Russell, Blaszczynski & Hing,
2015b). Multiple account holders selected online gambling sites based on price, betting options,
payout rates and game experience, whereas single account holders prioritised legality of sites and
consumer protection features. Thus, although causal directions are unclear, having multiple active
gambling accounts is a risk factor for problem gambling.
Overall, the main potential risks arising from wagering inducements aimed at commencement of
betting are that they can 1) increase the overall number of bettors, 2) increase overall betting
consumption and the risk of possible harm, 3) increase the use of multiple wagering accounts which
can extend time and money spent through using bonus bets requiring matched amounts, and 4)
expose bettors to a raft of additional marketing that encourages further betting.
5.3.2 Wagering inducements and the continuation of betting
Inducements do not necessarily increase an individual’s overall consumption of wagering products if
they serve to simply attract customers away from competitors to a particular operator or retain
customers in the face of competition. However, they do increase consumption if they result in
additional betting to what individuals would otherwise have done.
Naturally, research undertaken for this study is insufficient to establish whether the inducements
examined increase the frequency or volume of betting beyond what would have occurred in their
absence. However, the few studies that have investigated wagering inducements (reviewed in Chapter
Two) have found evidence that some inducements can result in additional betting. Hing, Cherney et al.
(2014b) found that increased consumption was reported amongst both treatment-seeking gamblers
and those recruited from the general population in response to offers such as ‘free’ bets and bonus
deposits. Hing, Lamont, Vitartas and Fink (2015b) found that one-quarter of sports bettors surveyed
agreed that the promotion of special bet offers increased their likelihood of betting on them, while
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about one-quarter agreed that it increases the likelihood of them placing impulse bets. As noted
earlier, Hing, Vitartas et al. (2014) concluded from their quasi-experimental research that a ‘risk-free’
offer is a strong enticement to sports bettors. Some participants in Sproston et al.’s study (2015) also
reported that these ‘risk-free’ bets were highly influential in encouraging them to bet. While evidence is
thin, research results to date all suggest some influence of wagering inducements on the continuation
of gambling.
Logic also indicates that some types of inducements inherently encourage continued betting.
Specifically, inducements with incentives in the form of bonus bets and deposits that are received after
an incentivised bet (or received as a reward/comp or through redemption of loyalty points) require
continued betting if the customer is to benefit from the incentive. These include most of the more
common types of inducements identified in the audit. Mobile betting offers, multi bet offers,
refund/stake back offers, some competitions, free bets to selected punters, and other free bets all
exclusively or mainly provided the incentive in the form of bonus bets or deposits. Clearly, further
betting is required to use these bonuses, with play through conditions ensuring that they cannot be
immediately withdrawn from bettors’ accounts. In contrast, inducements which provide the incentive in
cash or offer better odds/winnings (e.g. happy hours, match your stake offers, winnings paid on losing
bets, bonus odds, bonus winnings, reduced commissions, cash rebates) do not necessitate continued
betting to benefit from the offer. They may, however, enhance the appeal of these bets and thus
encourage additional consumption; alternatively, they may provide other benefits to customers that
serve to build brand loyalty. Thus, it is the type of incentive offered which appears to have more
influence on continued betting, with bonus bets and deposits that require subsequent bets clearly
having most influence.
5.3.3 Wagering inducements and the intensification of betting
Because wagering is a potentially addictive behaviour, promotions that increase the frequency and
volume of betting can encourage transition to near-addictive or addictive use (Martin et al., 2013).
Inducements that result in intensification of betting can therefore contribute to the development of new
cases of at-risk and problem gambling. Some types of inducements stand out as having strongest
potential for intensifying an individual’s betting activity, although empirical research is needed to verify
their actual effect.
Inducements with stringent play through conditions necessarily intensify betting. For example, one
inducement from an offshore operator required that a US$20 bonus bet be played through 16 times.
This extreme example is provided to illustrate what can be required, with the average play through
required being 5.8 times for offshore brands and 1.1 times for onshore brands in the audit (overall
average was 2.7 times). Making redemption of an incentive conditional on placing numerous
subsequent bets clearly increases the volume of an individual’s betting activity. Many bonus bets also
require a matching bet, thus intensifying betting expenditure. Further, play through conditions increase
the amount of time spent gambling and therefore increase exposure to a potentially addictive activity.
The Pathways Model would predict that the strengthened behavioural conditioning that occurs through
this extended betting increases the likelihood of later developing gambling problems (Blaszczynski &
Nower, 2002).
Increased volume of betting may also be encouraged by inducements for multi bets as these reward
heavier product use by requiring bettors to wager on multiple legs. Further, multi bets and exotic bets
have comparatively high expected loss rates (Gainsbury & Russell, 2015), which mean that they may
increase betting-related harm and chasing behaviour as more bettors experience losses. While returns
might be high when these bets are won, multi bets and exotic bets represent particularly risky types of
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bets, yet these are the bet types that are most often accompanied by inducements. Responsible
gambling information typically encourages people to understand the odds when gambling and to avoid
risky betting behaviours; yet these inducements incentivise bets with probabilities that are extremely
difficult to calculate and for which loss rates are high. Thus, some inducement types appear to
discourage responsible gambling behaviour and incentivise risky gambling decisions. Of further
concern are inducements that reward a large volume of bets. For example, one inducement offered
$1,000 in free bets for punters who placed a bet on every race at a particular race meeting.
Happy hours are another inducement type that might intensify betting by encouraging the
concentration of betting into short time periods, often between 1-2 hours. Happy hours for alcohol
consumption have been recognised as potentially promoting rapid and excessive consumption of
alcohol, prompting regulations restricting their availability and related guidelines for responsible liquor
advertising and promotions (e.g. Victorian Commission for Gambling and Liquor Regulation [VCGLR],
2015). This is because offers of free drinks and extreme discounting have been recognised as
resulting in an environment of irresponsible consumption by creating incentives for patrons to
purchase and drink more than they normally would (VCGLR, 2015). It is not known whether
discounted happy hours for betting have a similar effect, and this is an area for future research.
A further consideration is that inducements to bet on wagering websites and betting apps occur at the
point-of-sale and can therefore encourage impulse betting which increases consumption. As
discussed in Chapter Two, alcohol and tobacco research has found that point-of-sale promotions
result in increased impulse purchasing and increased purchase quantities amongst some consumers
(Gilpin et al., 1997; Jones et al., 2012; Slater et al., 2007). Further, inducements communicated
directly to the consumer, such as through direct email or SMS, may be particularly salient as they are
difficult to avoid (Martin et al., 2013). Thus, the manner in which wagering inducements are marketed
may be an important influence on the effect that they have on betting behaviour, and this also requires
research.
A final consideration here is the provision of credit to bet. As discussed in Chapter Two, provision of
credit for gambling is prohibited on other forms due to its known risks for increasing gambling-related
harm, as demonstrated in some legal cases discussed in Chapter Three. There appears to be little
doubt that betting on credit has the potential to greatly intensify betting as some individuals become
caught in a cycle of wagering losses, followed by betting on credit, leading to likely further losses and
an inability to meet the debt.
Overall, the aspects of wagering inducements with most potential to intensify betting appear to be
those with stringent play through conditions, multi bets that increase volume purchasing, bonuses for
large volume betting, bets with high expected loss rates, those such as happy hours that can
concentrate betting into short time periods, the promotion of inducements at point-of-sale and through
direct marketing that can encourage impulse betting and increase consumption, and the provision of
credit for betting.
5.3.4 Wagering inducements and problem gambling
One reason that wagering inducements have been the subject of concern is their potential to maintain
and exacerbate problem gambling. While research has been limited, studies of wagering marketing,
as reviewed in Chapter Two, have consistently found that positive self-reported responses to this
marketing increase with problem gambling severity, including more positive emotional and cognitive
responses, greater approval of this marketing, and higher self-reported impact on betting behaviour
(Hing, Lamont et al., 2015a, 2015b; Schottler Consulting, 2012; Sproston et al., 2015).
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Studies of gambling inducements provided by land-based gambling venues, including loyalty
programs, comps and promotions, have also found that they are associated with increased urges to
gamble beyond self-set limits, more time and money spent gambling, increased gambling involvement,
chasing losses, increased difficulties in controlling gambling, and gambling relapses (Narayanan &
Manchanda, 2012; RGC, 2013; Schottler Consulting, 2010; Southwell et al. 2008). However, this body
of research into gambling inducements has not investigated causal relationships, has relied on selfreport data, and has not specifically investigated wagering inducements. Nevertheless, results to date
are consistent with findings from gambling advertising research more generally that gambling
advertising impacts most on problem gamblers. Indeed, a comprehensive review of this literature
(Binde, 2014) concluded that the only effect of gambling advertising for which there is direct research
evidence is that it maintains or exacerbates existing gambling problems. This can occur by 1) arousing
more frequent impulses to gamble, 2) hampering efforts to limit gambling, and 3) triggering relapse
amongst former problem gamblers (Binde, 2014).
All three of these effects were reported in the only studies to date to provide insights into responses by
problem gamblers to wagering inducements such as bonus bets and deposits. Hing, Cherney et al.
(2014a, 2014b) interviewed 31 treatment-seeking Internet gamblers and 25 moderate risk/problem
Internet gamblers from the general population, some of whom were sports and race bettors. As
discussed in Chapter Two, amongst the treatment-seeking gamblers in particular, wagering
inducements were reported to have increased some participants’ betting because the inducements
made the activity more interesting and attractive, offered incentives to bet, provided triggers and
reminders to bet, and encouraged bettors to chase their losses. These inducements also extended
gambling time because of play through conditions and difficulties sometimes encountered in
withdrawing winnings from betting accounts. Some interviewees attempting to curtail their betting
reported relapsing in response to these promotions. Amongst the non-treatment-seeking moderate
risk/problem gamblers, some recalled specific wagering promotions that had prompted them to
gamble more than intended and to gamble when they otherwise would not have. While these small
isolated studies do not provide conclusive evidence that wagering inducements impact negatively on
problem gamblers, their results are consistent with prior research into gambling advertising, wagering
marketing, and gambling inducements.
Overall, the weight of evidence, although scant, suggests that wagering inducements are more likely
to maintain or exacerbate harmful betting amongst existing problem gamblers than to have no effects
or benign effects on them. There is no obvious reason to suggest that wagering inducements are
exempt from the heightened negative impacts on problem gamblers found in research into gambling
advertising in general (Binde, 2014). Their heavy promotion at point-of-sale, in mass media, social
media and in direct communications to bettors means that this advertising cannot be avoided,
exposing problem gamblers to an ongoing plethora of betting cues as inducements are continually
refreshed. Further, these cues are highly incentivised through offers of ‘free’ bets, deposits, moneyback guarantees, and provision of credit for betting. Problem gamblers themselves have reported
harmful effects, but further empirical research is needed with larger samples and to determine any
differential effects for different types of wagering inducements.
5.4 Considerations for consumer protection
In addition to the potential harms raised from the sheer volume and diversity of wagering inducements
that encourage the commencement, continuation and intensification of betting, and their likely
detrimental effects on problem gamblers, other key issues undermining consumer protection are:
complex terms and conditions, minimal provision of responsible gambling messages, and frequent
exposure of minors to the promotion of wagering inducements.
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5.4.1 Complex terms and conditions
As discussed earlier in this chapter, the terms and conditions associated with many wagering
inducements are characterised as being complex, not always explicit in the display ad for
inducements, difficult to find, sometimes embedded in a raft of general terms and conditions, and
difficult to interpret because of the legalistic language used. Lack of easily accessible and transparent
information on the restrictions applied to inducements hinders informed choice, which is a cornerstone
of consumer protection and responsible provision of gambling (Blaszczynski, Ladouceur, Nower &
Shaffer, 2008; Parke, Harris, Parke, Rigbye & Blaszczysnki, 2014).
Central to informed choice in gambling is the provision of adequate, reliable and comprehensive
information to assist consumers to make optimal decisions that are not based on faulty information or
mistaken beliefs and to make responsible gambling decisions (Blaszczynski et al., 2008). This
includes information that outlines to gamblers how the gambling activity operates, including the
probabilities of winning (Parke et al., 2014). Blaszczynski et al. (2008) contend that the informational
basis for informed decision-making must be relevant, accurate, not misleading or deceitful, accessible
to all potential participants, provided in an understandable way, provided in full, and delivered in a
timely manner. The terms and conditions examined in this study indicate that many fail to meet these
basic requirements for informed choice.
In the United Kingdom, the Committee for Advertising Practice (2014, p. 47) also noted that
advertisements for wagering inducements can be misleading, and provided the following example and
actions taken:
Advertisements for promotional offers based on often complex mechanics have a significant
potential to mislead, if information is not properly presented. For instance, a ‘free’ bet offer might
have a variety of exclusions, such as, the requirement for consumers to stake a certain amount to
qualify or the need to play through any winnings before they can be withdrawn. As outlined in its
review of enforcement, the ASA has adjudicated on a variety of advertisements that have
breached the Codes because significant terms and conditions were not given adequate
prominence or the offers were structured in a manner that contradicted the headline claim.
5.4.2 Minimal provision of responsible gambling messages
Responsible gambling messages were provided in only a minority (12%) of display ads for wagering
inducements examined in this study, although the majority of websites contained a responsible
gambling message on the homepage and a link to further information. However, these messages were
highly unlikely to be noticed, difficult to find, and hard to read. Thus, the vast majority of wagering
inducements were displayed without any responsible gambling message, contrary to requirements for
other forms of gambling advertising in Australia. While the most effective way to deliver responsible
gambling information is still open to debate, and the generic, static and non-personalised ‘gamble
responsibly’ message is unlikely to gain attention, prompt self-evaluation or motivate a behavioural
response (Parke et al., 2014), the lack of any message on most wagering inducements is contrary to
the responsible provision of gambling services.
5.4.3 Exposure of minors to promotions for wagering inducements
A further consideration for consumer protection is the exposure of children and adolescents to a
plethora of marketing for wagering inducements through channels including social media, the Internet
and during live and televised sporting events. Of most concern is the potential effects on their future
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attitudes, intentions and behaviours in relation to gambling and gambling problems (JSCGR, 2011,
2013), given that youth lack capacity to properly evaluate this information and may be unable to
distinguish its promotional intent (Hing, Vitartas et al., 2014b). While gambling advertising regulations
and codes of conduct prohibit the targeting of minors by gambling advertising, they do not prevent
their exposure to this advertising. As discussed in Chapter Three, some jurisdictions have taken steps
to limit exposure of minors to gambling advertising. However, there are few restrictions that limit the
exposure of Australian youth to the widespread promotion of wagering inducements.
5.5 Limitations of the study
The main limitation of this study is its reliance on secondary data. While use of secondary data was
adequate and appropriate to meeting the project requirements, lack of available data on the effects of
wagering inducements on betting behaviours limits the implications that can be drawn from this study’s
results. Other limitations of this study relate to the short time period available for the policy analysis
and audit. While the policy analysis was highly inclusive of numerous jurisdictions and of legislation,
regulation, codes and cases relevant to the provision and promotion of wagering inducements, a
longer timeframe may have allowed a more detailed analysis. The one month time period for the audit
precluded the capturing of any seasonal variations and a truly representative approach. While the
results of the audit are accurate for the time period covered, it is not known whether the same results
would be obtained in an audit over a longer time period. The rapidly changing nature of inducements
offered suggests they may be highly variable over time. The short time frame also did not allow the
audit to include any terms and conditions relating to wagering inducements that were contained in the
vast volume of general terms and conditions on operator websites. Nevertheless, the audit captured
the key attributes of the inducements and enabled an analysis of the main features that have potential
to impact on betting behaviour.
5.6 Conclusion
This study is the first known comprehensive examination of wagering inducements in Australia. A
literature review, policy analysis and audit were the main stages of research that yielded information
on the types of wagering inducements offered to Australians, conditions on their uptake, and their
regulation.
The findings confirmed that a wide range of wagering inducements are available to Australians that
are continually refreshed and heavily promoted. These inducements offer a variety of financial
incentives to bet, including bonus bets, money-back guarantees, cash rebates and matched deposits.
Some inducements specifically encourage the commencement of betting through sign up, refer a
friend and affiliate referral bonuses. Many inducements encourage the continuation of betting through
structuring the incentive as bonus bets and deposits that require further betting. Play through
requirements, multi bets, happy hours, provision of credit for betting, and promotion of inducements
through direct marketing and at point-of-sale may encourage intensification of betting. Most
inducements were for complex bets and combined contingencies which have high expected loss rates,
thus encouraging bettors to make risky gambling decisions.
These factors raise issues for harm minimisation in betting, given that increased frequency and
volume of betting is associated with increased risk of gambling problems. There is no obvious reason
to suggest that wagering inducements are exempt from the heightened negative impacts on problem
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gamblers found for gambling advertising in general, and previous research indicates that this is likely
to be the case. Consumer protection deficiencies were also identified in this study, specifically the
complexity and lack of transparency of terms and conditions on the uptake of inducements which
hinders informed choice, lack of responsible gambling messages embedded in advertisements for
inducements, and the likely widespread and frequent exposure of children and adolescents to the
promotion of wagering inducements.
The policy analysis found that the regulatory environment for wagering inducements currently lacks
clarity on what constitutes an inducement, provides little specificity about which aspects of
inducements are acceptable or not, and lacks consistency across Australian jurisdictions. While a
variety of relevant legislation, regulations and codes of practice exist for gambling, advertising and
broadcasting, and which might inform the provision and promotion of wagering inducements, their
provisions are typically vague and often provide little specific direction to ensure that these
inducements minimise gambling harm and provide adequate protection for consumers. International
jurisdictions have responded in a variety of ways, but their responses have also been fragmented and
inconsistent.
Therefore, the challenge remains to regulate the prolific supply and promotion of wagering
inducements in ways that best promote responsible gambling, consumer protection and harm
minimisation for bettors. This study has contributed foundational information to assist these efforts.
However, the lack of research into wagering inducements currently precludes an evidence-based
approach to policy. Empirical research is needed to draw firm conclusions about the actual influence
of wagering inducements on the commencement, continuation and intensification of betting, on the
maintenance of problem gambling, and on consumer protection when betting. Research that identifies
bettors’ responses to different types of inducements and incentives, and for bettors at different levels
of risk for gambling problems, is also urgently needed.
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