The radio advertisement stated the following:
MVO: “Football Index is reinventing football betting. You can buy and sell the world’s top players. Their value may go up and down but it's not over with the final whistle like a regular bet. Football Index - reinventing football betting.”
FVO: “Start building your portfolio today at footballindex.co.uk or download the app now. New customers only. Minimum deposit and conditions apply. Gamble responsibly.”
The complainant considered the advertisement to be in breach of the ASAI Code as it did not direct listeners to a source of information about gambling and gambling responsibly.
The advertisers said that the Football Index platform allowed their customers to gamble on the future success of football players, in a format which mirrored a stock market. They said their customers placed fixed-odds bets, known as Shares, for the chance to win daily payouts, referred to as a Dividend, calculated based on player performances on match days and their media presence.
They said the advertisement in question aimed to introduce the Platform to Irish customers and used the tagline “Reinventing Football Betting”.
They said they treated their responsibilities in relation to the advertising of the Platform with the highest importance and that all Football Index advertisements were reviewed in advance of being sent to various media organisations to ensure that they were in compliance with local laws and regulatory guidance. They said they were particularly conscious of their responsibilities in relation to responsible gambling and that all of their advertisements contained a responsible gambling message.
They said the advertisement contained a message to “gamble responsibly” and also directed listeners to their website www.footballindex.co.uk or their mobile application, both of which, were a source of information about gambling and gambling responsibly. They said that it was important to note that it was not possible for customers to access the platform or to place any bets unless they first accessed the website or the app.
They advertisers said that on each page of the website, a tab entitled “gaming responsibly” was accessible to anyone viewing the website and was linked to their Responsible Gaming policy which contained helpful information about gaming responsibly and advised customers to play wisely and within their budget. They said the page also included:
• Tips for customers on staying in control, for example by never chasing their losses, only gambling what they could afford to lose, and keeping track of their time and money spent.
• A self-assessment questionnaire for individuals who may be concerned about their gambling habits to help them decide if they had a problem and needed to seek help.
• An outline of the responsible gambling tools provided on the Platform, which included:
• Deposit Limit – a tool to set a deposit limit to manage the amount of money customers could deposit into their own account.
• Reality Checks – a tool to help customers manage the amount of time they spent playing at the Platform. Once set, a pop-up alert would be displayed as a reminder that a customer had been logged into their account.
• Time Out Tool – a tool which allowed customers to take a break from the Platform for a set period of 14 hours, 48 hours, 7 days or 30 days. Once activated, the customer would not be able to use their account.
• Self-Exclusion – this tool gave customers the option to self-exclude themselves from future participation in the Platform for a number of months, years or indefinitely.
• Links to a list of support organisations who could assist individuals who developed a problem with gambling.
• Their age verification policy and specific support and advice services for minors.
The advertisers said that the app’s account page contained a “Responsible Gambling” tile for all their customers. On clicking this tile a resource appeared which directed Irish customers to www.problemgambling.ie and directing UK customers to www.begambleaware.org. They said the “Account” tile was available from all areas of the app and that the responsible gambling tools were also available on the app.
They said that the policies and tools outlined have been created by BetIndex Limited to ensure that they provided a protected entertainment environment for their customers. They said they were committed to ensuring that their customers can access information on responsible gambling easily at all times.
They said that their website and app allowed them to provide detailed information on gambling and gambling responsibly, which was not possible to do comprehensively on some forms of media advertisements, including radio advertisements, due to their short duration. They said their customers could not use the platform unless it was accessed through their website or app, both of which contained detailed information on responsible gambling, as well as links to other independent sources of information on responsible gambling. They said they believed that this approach complied with the spirit as well as the letter of the rules of the ASAI Code. They confirmed that the advertisement in question was no longer running on any radio stations in Ireland.
The Executive confirmed that the website and the app displayed a link to a source of information about gambling and gambling responsibly.
The Complaints Committee considered the detail of the complaint and the advertisers’ response. The Committee noted that the advertisement had included a responsible gambling message.
While the advertisement referred to the advertisers’ website, where information on responsible gambling was available, the Committee did not consider that it fulfilled the requirement in section 10.10 of the Code, as the advertisement omitted explicit reference to directing people to a source of information about gambling.
In the circumstances the Committee concluded that the advertisement was in breach of section 10.10 of the Code.
As the advertisement in question would not be aired again, there is no further action to be made. The Committee told the advertisers that any future advertising must not only contain a message to encourage responsible gambling but also a direct reference, for example, a specific pathway, to a relevant source of information about gambling and gambling responsibly.