Chapter 3: Communications

Young woman holding an imaginary megaphone and shouting into it

Creative content

There are several steps that should be taken when developing a 360° marketing communications campaign.

First, define your audience, benchmark your campaign against the campaigns of other markets, and address your Unique Selling Proposal (USP) – i.e., the message you want to communicate about your product. Marketing campaigns that you might consider benchmarking your campaign against would include other lottery operators or any of the major global gaming platforms. The latter are generally very active in terms of marketing communication.

Having done that, you need to set clear guidelines for your creative agency so that it will deliver proposals that will meet your expectations in terms of responsible gaming. Below you will find a few tips for offering guidance when you brief your creative agency.

Key visuals and assets

Audience

All marketing and advertising must refrain from targeting minors or vulnerable people – e.g., problem gamblers, people in financial difficulty, people under the influence of alcohol or drugs, or people who have been previously banned from gambling.

1. Minors
The following marketing and advertising activities are to be prohibited:

  • Activities specifically aimed at minors or activities that include minors
  • Activities suggesting that the participation in lotteries and sports betting represents a transition from adolescence to adulthood
  • Activities that make specific reference to youth themes (e.g., popular protagonists)
  • Activities that are broadcast in places where young people hang out (e.g., in the proximity of youth centers or schools)

2. Vulnerable people
To protect vulnerable people, the following should always be observed:

  • Do not target people with your marketing communications who have been previously excluded from gambling sites or who have the propensity for gambling addiction.

The messages

Marketing communications should not mislead, deceive, or suggest any possibility of getting rich quickly. Giving false impressions about the odds of winning is misleading. It is
also misleading if it gives the impression that:

  • The players’ knowledge, skills, ability, or other characteristics influence their odds of winning. (Sports betting is considered a game of chance in which the player’s expertise may play a role but does not assure any foreknowledge of the result of a match or competition. Even an expert cannot predict the result of a match or a competition with complete assurance.)
  • Increased play increases your odds of winning
  • Gambling is an appropriate way to deal with financial or personal problems
  • Gambling is a viable alternative to working for a living
  • Increased gambling is the way to make up for gambling losses

Furthermore, sports betting operators should not under any circumstances convey messages that:

  • May create or sustain gambling addiction or encourage excessive gambling
  • Contain data relating to the odds of winning that is not verifiable
  • Imply that winning is dependent on anything other than chance or luck
  • Criticize non-gamblers
  • Make people believe that all players will win large sums of money
  • Discriminate against ethnicity, nationality, religion, gender, age, etc.
  • Incite violence or illegal behavior or have sexually explicit and suggestive themes
  • Play on the vulnerability of people experiencing personal or financial difficulties
  • Feature alcohol and/or tobacco (or where legal, cannabis)
  • Give the impression that the mission of a lottery to support charitable causes is a reason to gamble excessively
  • Provide links to entities offering loans and credit

Promotion and media planning

Ad placement

The various media providers, publishers, and agencies should be made aware of the need to take special care in the placement of gaming ads in appropriate environments.
It is highly recommended to avoid the following:

  • Media or venues intended for minors (e.g., TV ads before, during, or immediately following programs targeting minors)
  • Erotic websites or any other medium that caters to the erotic entertainment industry
  • Religious settings
  • Media that report exclusively on, or deal exclusively with war, disasters, or accidents

Newsletters, e-mailings, and digital platforms

Lotteries should pay particular attention to messages sent via electronic media (e-mails, SMS, application messaging systems, or social media networks). All clients must give their consent before being contacted through digital media. Any refusal on the part of the client must be respected.

The following is to be considered inappropriate:

  • Ads sent directly to players via digital media without their consent
  • Tracking the location of players and sending them ads via electronic media when they are in or near specific areas

Geolocation services on players’ mobile devices should not be used to send them push notifications when they are at a particular location that could make them more receptive – e.g., in the vicinity of a bank, a casino, or a sports betting outlet.

To be clear, the above does not concern ads on smartphone applications or websites. It is concerned primarily with marketing communication that addresses the players directly through messaging apps, social media, or e-mail.

Free games, game credits, and loyalty offers

Free games, game credits, and loyalty offers allow players to enjoy cash games free of charge. The distribution of such may be subject to the prior approval of the competent authority and regulated in regard to player protection. Warnings about the dangers of excessive gambling must be clearly and transparently displayed on free games, game credits, and loyalty offers. The distribution of such gratuities shall be subject to the following conditions:

  • Free games and game credits shall not target minors, at-risk gamblers, nor those that have been previously excluded from gambling platforms.
  • Free games and game credits should not promote gambling with the sole aim of winning more.
  • Free games and game credits should not be offered in an aggressive or misleading way.
  • Free games and game credit rules should be clear and easily accessible.
  • Free games and game credits should be easily redeemable (whether cashable or not) without forcing players to roll the credit value a number of time by placing multiple bets.

Promotions and field events

Active sellers and promoters must have received training in responsible gaming prior to their employment. No promotion shall target minors or vulnerable people.

Promotional measures that may be considered offensive include:

  • Telephone sales (cold calling)
  • Door-to-door sales
  • Sales on public transport or during at promotional events in conjunction with an advertising tour. In other words, no selling to a captive audience.

Sales activities that take place at trade shows or similar events or in public places – e.g., on the street, in train stations, at malls, etc. – are not per se considered inappropriate.

Once the key visuals are designed and the script for the promotional spot has been drafted and approved by the marketing department, we strongly suggest submitting all elements of the campaign to the responsible gaming department. This will help ensure that the agency proposal will meet responsible gaming requirements.

Social media

Source: https://s22.q4cdn.com/826641620/files/doc_financials/2020/q1/Q1-2020-Shareholder-Letter.pdf, https://www.agencedesmediassociaux.com/pinterest-chiffres-2020, https://www.oberlo.com/blog/tiktok-statistics#, https://investor.snap.com/

All the main global sports betting operators have social media pages. They tweet every single day, they promote special bonus offers on a regular basis, or they just post humorous content related to sports news.

To be competitive, and to build a community of sports bettingfans, some lotteries actively maintain a social media presence on Twitter, Snapchat, Facebook, Instagram, etc. Other lotteries have been less inclined to maintain a presence on these platforms as they know it is time consuming. In order to maintain a proper social media presence on these platforms, lotteries need to be proactive and they need to use the appropriate jargon for these media.

Although social media platforms have the potential to target sports-betting audiences – people between 18 and 35 years of age – it is important to consider that there are a lot of people under 18 years of age who can be found there as well. Therefore, communicating on these platforms requires care in developing the content and frequent monitoring. It is essential to have a dedicated social media staff to plan the content, set guidelines, and track and answer user comments.

To provide effective social media content, lottery operators should define an editorial line, have graphic design resources familiar with digital media, and a communications team that tracks the daily news. We also recommend that you have a dedicated budget for community engagement and reward active players with bonuses.

Beyond content, social media platforms can also be used to facilitate customer service. In order to offer a professional service on social media platforms, and react to players’ questions and comments in a timely and precise manner, the staff charged with serving players through these channels must have a solid sports betting knowledge and should be familiar with all of your betting offers. The quality of your customer service will distinguish your sports betting operation from the countless illegal operators vying for your players’ attention.

It is also possible to place paid ads directly on most social media sites without having a dedicated social media page for each product. For ads placed on Twitter, Snapchat, Instagram, and Facebook, target settings are provided that allow you to promote your gaming products to the appropriate audiences and ensure that the ads will not be shown on the pages of people under 18. The ads can also be geo-tagged so that they remain within their authorized jurisdiction.