English League – Written evidence (GAM0082)

Overview

1. Formed in 1888 by its twelve founder members, the (EFL) is the world's original league football competition and provides the template for leagues the world over. It is the largest single body of professional clubs in European football and is responsible for administering and regulating the Sky Bet EFL (which consists of the Sky Bet Championship, Sky Bet League One and Sky Bet League Two), the Carabao Cup and the Leasing.com Trophy, as well as reserve and youth football. It also represents its clubs’ interests within domestic football and the wider political structure, including representation on the FA Board and Council.

2. EFL clubs deliver competitive, exciting professional football in towns and cities throughout and to a dedicated fan-base of passionate supporters. With over 18m admissions last , more people watch EFL matches than any other sporting competition in the UK.

3. Professional football clubs are an integral part of the towns and cities from which they take their name and, in many, deliver the biggest single form of communal activity in their local area. They also play an active part in improving the lives of local people through the work of the EFL Trust and club Community Trusts.

4. The EFL Trust is a registered charity that governs, advises and audits the charitable trusts associated with the professional clubs of the EFL, who employ more than 2,500 members of staff including teachers, coaches, professional health and social workers. Using the ‘Power of Football’, The Trust continues to flourish, delivering life improving projects, which engage with over a 1.5 million people per year, focusing on education, sport, community development and health.

5. Traditionally the breeding ground for the stars of the future, the EFL continues to play a key role in identifying and developing the next generation of footballing talent and its clubs invest more than £100m every year in this area. There are more than 8,500 young footballers between the ages of 8 and 18 on the books of EFL clubs.

6. On behalf of its clubs, the EFL generates the commercial revenue that sustains football’s growth through the sale of collective rights, sponsorship, licensing and other commercial activity. EFL matches are beamed into the homes of football supporters in every corner of the globe and are shown in more than 180 countries every week, reaching approximately 290m homes. As a result, clubs generate more than £700m of revenue annually and contribute £300m in taxation to the exchequer.

7. While the EFL is not a gambling operator or a consumer of gambling products, it does nonetheless have a historic and sustained relationship with the gambling industry which today includes a title sponsorship of our competition and partnerships with a number of our clubs. It is therefore appropriate that the EFL responds to this call for evidence on the social and economic impact of the gambling industry by providing responses to questions 6 and 14 specifically.

Question Responses

Q 6 - What are the social and economic benefits of gambling? How can they measured and be assessed?

8. At the outset, it is important to acknowledge that gambling is a legitimate form of entertainment that has been a popular pastime in the UK for centuries. Historians suggest that gambling began in its earliest iterations in ancient civilisations of China, Greece and Rome and has taken place around the world for thousands of years. Gambling is always likely to be a feature of any society whether legal, illegal, tolerated or regulated, but in the UK today, the overwhelming majority of people are able to enjoy safe and responsible gambling in one of the most regulated gambling sectors in the world.

9. Football has a long standing relationship with that gambling industry, which for many years has been part of the social landscape of British life. From the Football Pools through to official associations with individual bookmakers, overall, this partnership has been beneficial to both industries, as well as fans, many of whom enjoy putting on a bet as part of their matchday experience.

10.In simple terms, the UK Government enjoys extensive economic contributions from a regulated gambling industry to the tune of billions of pounds to the exchequer. In the football context, similar benefits are derived from the gambling sector in the economic support it provides to clubs – particularly outside the - to ensure that they can remain economically sustainable organisations, representing the communities in which they are based.

11.Our unique four tier pyramid of professional football clubs is admired worldwide with clubs providing exciting matches week in, week out in front of a total annual audience of more than 30 million attending supporters, with millions more watching matches on television across the globe. Beyond that, EFL clubs play a crucial role in the towns and cities from which they take their name delivering a sense of civic belonging as well as important community work through our network of club community trusts that deliver health, education, inclusion and sports participation initiatives to more than 1.5m people every year, including many from disadvantaged backgrounds.

12.It would be naïve to believe that some of the significant investment currently being made by gambling operators into professional football is not predicated on the ability to activate those commercial partnership by advertising their services to the targeted market of football supporters that watch matches on television, with the demographic of the betting and football audiences being largely similar. Betting is an industry for which sponsorship has to deliver custom as well as brand awareness to be cost effective. Advertising during sporting events is pivotal to this, particularly in terms of promoting ‘in play’ betting opportunities.

13.For our part, the EFL’s league competition consisting of its three divisions of 24 clubs has been sponsored by Sky Bet, an online only UK based gambling operator, in a multi-million pound agreement that is now in its seventh year (of at least eleven). Since 2013/14, Sky Bet has been an excellent partner to football and the EFL. In addition, more than 60 of our clubs also have co-existing official arrangements with competitor betting brands (some including front of shirt sponsorship) and beyond that many carry paid-for advertising on pitchside perimeter boards and in matchday programmes.

14.Outside of the EFL, many other football organisations have similar official partnerships with bookmakers such as William Hill’s partnerships with the Football Supporters’ Association and the Football Writers’ Association, while other sports have similar title sponsorships, for example the and Betfred. As such, the investment made by the gambling industry into the sport but particularly football is a crucial element of the game’s financial model - the maintenance of which is a key aim for the football authorities.

15.While there is a common perception that football is awash with broadcasting and sponsorship money this is not necessarily the case for many professional clubs, some of whom struggle to remain financially sustainable. As demonstrated by the fact that as of May 2019, 52 of 72 EFL clubs ended the season in deficit, while the collective had a net deficit of £388 million.

16.Therefore the commercial relationships that football clubs have with partners from various industries are critical to their ongoing viability. In the case of the betting industry, while the EFL does not have sight of individual club deals, it would seem reasonable to suggest that its investment into EFL clubs totals around £30m per season, perhaps more. Additionally, professional football receives significant funding from domestic broadcasters who recoup some of their significant outlay through the sale of advertising and sponsorship opportunities to betting companies.

17.As this consultation itself exemplifies, there remains extensive scrutiny about the gambling sector’s relationship with sport and in particular football, but it should not be assumed that the income football receives from the betting industry can easily be replaced by alternative commercial relationships with companies from other industries.

18.The sports sponsorship market is becoming an ever tougher environment for sport governing bodies and competition organisers. In the 2014/15 the FA Cup, a highly attractive property for potential commercial partners, went unsponsored for a whole season. In terms of our own competitions, the EFL Cup (formerly the ) ran for the whole of the 2016/17 without a sponsor, the first time this has happened since the competition became the first to carry a sponsors’ name back in 1981 following a ground breaking agreement with the Milk Marketing Board. A period of some 35 years. In seeking to attract a new partner the EFL approached more than 600 brands before finally agreeing a three-year deal that began in 2017/18 with Thai owned energy drink Carabao. The failure to find sponsors for these two competitions for a season apiece cost domestic football a figure in the region of £15m. Money that would otherwise have been distributed throughout the professional game and down into the grassroots game (from both competitions).

Q 14 - Gambling is becoming an integral part of a growing number of sports with increasingly close relationships between operators and sports clubs, leagues and broadcasters. What are the risks attached to this?

19.As is set out in the above response to question six, the nature of the commercial relationship that exists between professional football and gambling operators is crucial to the economic model of the game.

20.It is also the case that football is a socially responsible industry and the EFL is clear that in establishing links with responsible gambling companies, in no way does it wish to assist the proliferation of problem gambling.

21.As it stands, figures show that at present 0.7% of gamblers are classified as problem gamblers and the EFL is of the view that gambling operators, have a responsibility to ensure that effective mechanisms are in place to firstly identify those with issues and secondly help address problem behaviours and addiction.

22.As part of this, the EFL fully supported the announcement that the UK’s biggest gambling operators including owners of William Hill, Ladbrokes Coral, Paddy Power Betfair, Bet 365 and indeed Sky Bet have committed to increased their voluntary levy on gambling profits from 0.1% to 1% by 2023, which is expected to total a collective contribution of £60m.

23.Having a fully funded, progressive approach to tackling problem gambling is essential to restoring confidence in the betting industry, which is important to bodies like the EFL as we want to have a commercial relationship with bookmakers that is healthy for our clubs and not unhealthy for those fans that choose to gamble.

24.In respect to some calls in Westminster that have suggested shirt sponsorship of football teams and gambling advertising within football should be banned, there is little evidence to suggest that there is a link between gambling advertising and problem gambling. Beyond anecdotal calls, little appears to have changed since Per Binde’s 2014 survey of available evidence, which concluded that the impact of advertising on the prevalence of problem gambling is likely to be “rather relatively small”.

25.Notwithstanding, the EFL does note that the gambling industry has made moves to address levels of exposure of in game betting to young people by introducing a self-imposed “whistle to whistle” ban on gambling adverts being shown on live sport before the 9pm watershed.

26.For its part, the EFL maintains that football should always be able to partner with responsible and licensed operators and believes such moves highlight that the UK gambling industry is taking its duty of care to customers and the wider public seriously. This is a view that is reflected by the EFL fan base. In June 2019, an EFL supporter survey went out to over 27,000 fans, with 71% of fans responding to state that they felt the level of gambling companies’ involvement in the game was acceptable.

27.This is a theme which formed the key part of the extension terms of the EFL’s title sponsorship agreement with Sky Bet which will run until 2023/24. Specifically, it included a commitment to an enhanced Memorandum of Understanding (MoU) between the two organisations.

28.The MoU established an agreed set of commitments that aim to address the wider sporting integrity and societal concerns that often emanate from a commercial partnership between one of football’s competition organisers and a betting company. It included:

a. The arrangements put in place by the football authorities to protect the integrity of competition, such as the monitoring of global betting markets for irregular activity and the complete prohibition of football ‘participants’ betting on football. b. A commitment from both parties, enshrined in our commercial agreement, that marketing messages aimed at minors will not include reference to Sky Bet. c. The promotion of responsible gambling messaging, including on sleeve badges worn by all first team players for EFL matches from 2018/19 for at least two seasons. d. Education delivered to players on a range of personal and social education topics, including gambling. e. The EFL’s commitment, working in conjunction with the PFA, to support players with addiction issues, including gambling.

29.Significantly, the EFL and Sky Bet’s shared commitment to safer gambling also included a £1 million pound standalone investment to educate EFL players and staff at clubs about gambling related harm. This programme is underway and is being rolled out at clubs by EPIC Risk Management.

30.The EFL remains steadfast in its desire to work with a well‐regulated, socially responsible gambling industry and while scrutiny of football’s relationship with gambling continues, we do not believe that there is a need for regulatory change at the current time. However, we have always maintained that should any Government seek to alter the status quo with regard to the rules relating to that it do so working collaboratively with the EFL to enable us to try and mitigate the effects on our clubs.

11 September 2019