Why we need to talk about suicide in Great Britain and Australia
Expert Insight provided by Dan Waugh, Partner, Regulus Partners

This article is about a highly emotive subject which has become influential in shaping gambling policy globally. We have attempted to deal with the issue in an objective and compassionate manner but some readers may find the subject distressing. 

In recent years, suicide has become the most acutely sensitive of all of the controversies surrounding the operation of licensed gambling markets in Europe, Australia, New Zealand and beyond. The efforts of bereaved families in particular has propelled the issue to prominence; making it a staple of public policy discourse in legislatures and the mainstream news media. Despite this – and perhaps even because of it – there has been an absence of genuinely scientific inquiry or objective debate about the best ways to address risk of self-harm in a gambling context. In this article, we argue that the desire to apportion or avoid blame may be getting in the way of progress; and that stakeholders are either looking at the problem through the wrong end of the telescope – or simply not looking at all.

In commencing discussion of a subject as emotive and sensitive as self-harm, it is helpful to start with agreed facts or statements of the obvious. One such statement is that people with a gambling disorder are at elevated risk of self-harm. This may be true of most if not all mental health disorders but does not diminish its significance. A second observation, which should be uncontentious (but lately is not), is that suicide is complex. Professor Rory O’Connor, who leads the Suicidal Behaviour Research Laboratory at the University of Glasgow has written: “Without question, suicide is not caused by a single factor. Rather suicide results from a perfect storm of factors and…these factors can be biological, psychological, clinical, social or cultural, and many of them may be hidden.” The relationship between disordered or excessive gambling and self-harm demands a response; but that response requires contextualisation as part of a much wider phenomenon.

In recent months, a number of figures have claimed – specifically in relation to gambling – that invocations of complexity are “cynical”. We would agree in cases where complexity is used to deflect attention away from responsibility for actions (or inaction) that contribute to another’s self-harm; but it is not cynical to reflect on the repeated research findings on the large number of inter-related risk factors associated with suicide. Attempts to reduce this complex issue to a single factor are likely to impede understanding and may in fact expose well-meaning proponents to accusations of cynical behaviour. If stakeholders are able to grasp these two precepts of acknowledged risk and complexity – and suspend (at least temporarily) vexed questions of culpability – we may hope to move the discussion forwards.

The licensed gambling industry (with a few notable exceptions) has generally adopted a position of non-engagement on the subject of suicide. Demonstrably unscientific claims that it is killing 500 of its customers every year have largely been met with silence – a silence that could be mistaken for tacit acceptance. At the same time, it is not obvious that operators are doing very much about legitimate concerns, beyond putting in place procedures (including staff training) for situations of threat to life. Tolerance of wildly inaccurate claims about the prevalence of ‘gambling-related suicide’ and inaction in relation to genuine risk is a particularly disastrous combination. It is understandable why operators may not wish to spend their time talking about suicide; but the conversation is therefore taking place around them. 

In any case, the subject of gambling-related suicide is not going away. The Gambling Commission has kicked off a suicide research programme and consulted on a regulatory requirement for licensees to notify the regulator should they be made aware that any customer dies by his or her own hand. The Commission has also included questions about suicide ideation and suicide attempt in its new Gambling Survey for Great Britain (with the first iteration due to be published in February next year). The NHS Adult Psychiatric Morbidity Survey 2022 will cover similar territory when findings are published in 2024 and 2025 Gambling has been included for the first time in the National Suicide Prevention Strategy for England – suggesting action of some sort from the Department of Health and Social Care; and the Bishop of St Albans continues to push through Parliament his Coroners (Determination of Suicide) Bill. While Private Members’ Bills rarely make it onto the statute books, his efforts will ensure further discussion in Parliament. Even in the absence of such laws, it seems likely that gambling disorder may continue to feature in some inquests.

The Gambling Commission’s position may be well-intentioned but is also illogical. Its fixation with ‘gambling-related suicide’ – a term so loosely-defined as to serve little practical purpose – appears to reflect its own obsessions rather than anything resembling coherent policy. Given the complexity and heterogeneity of self-harm, it makes little sense to consider its relationship with gambling disorder in isolation. The idea that one can prevent suicide by gambling policy alone is questionable (and antithetical to the principles of public health). It would be more cogent, in our view, to start with an understanding of general risk factors for suicide – including social isolation, poor sleep, depression and feelings of entrapment - and then consider the extent to which dysregulated wagering might contribute to these. 

One unhelpful corollary of the Commission’s approach is that it may have inadvertently given its licensees the impression that they should only be concerned about suicide where gambling is implicated. This is both unhelpfully reductive and distinctly unambitious. An overwhelming majority of people who gamble do not develop a disorder (the past-year prevalence of DSM-IV ‘pathological gambling’ has been between 0.1% and 0.3% of the adult population or between 0.2% and 0.5% of people who gamble) but many will experience a range of other mental health conditions – entirely unconnected with their gambling - that may involve elevated risk of self-harm. It is not simply the case that gambling businesses could do more to prevent harm; but they may have an opportunity to promote positive mental health, so long as this is done in earnest and not for superficial reasons. 

Campaigners have been successful in raising the profile of suicide risk and should be commended for that. Having gained attention, they have an opportunity to move the conversation into a more objective and constructive orbit; but so far this has failed to happen. Instead, the issue has been used to justify a wide range of controls on consumers and operators, regardless of their relevance to self-harm. This may encourage suspicion that it is being used to secure a broader agenda rather than to solve a legitimate problem. There is also the possibility that a focus on recrimination may discourage gambling operators from engaging meaningfully with what is already a difficult subject.

The manufacturing of evidence in this domain is unhelpful. It is now commonplace in Parliament and the media to assert that one ‘problem gambler’ dies by suicide every day in Britain – but such claims are patently manufactured (the Gambling Commission has described them as ‘unreliable’). The Department of Health and Social Care has now admitted that Public Health England’s estimate of suicides ‘associated with problem gambling’ were incorrect (and its report has been withdrawn). There are serious problems too with figures produced by the Office for Health Improvement and Disparities. The most obvious is that they are predicated on the idea that there is no link between the presence, severity or complexity of mental health disorders and suicide risk (a ‘flat-earth’ theory in psychiatric terms). It is easy to see why, faced with a legitimate issue but lacking reliable data, there is a temptation to make things up. On the other hand, the use of misinformation in any cause (no matter how noble) can have unintended consequences. One is that it breeds a dynamic of claim and counter-claim, with attention drawn to proving or disproving numbers rather than finding solutions to important issues. The suggestion that the prevalence of gambling-related suicide can be quantified when we don’t even have an operationalised definition of the term reveals the shallowness of the waters waded by so many allegedly independent researchers. 

It is not cynical to highlight the complexity of suicide and suicide prevention; but that complexity must not be used to justify inaction. As awkward as it may seem, licensees must develop far greater curiosity about the extent to which their customers may be vulnerable to self-harm for whatever reason and the extent to which their actions can affect this for good or ill. The first step towards addressing any problem has to be an acknowledgement that it exists, followed by a willingness to discuss it. If operators are prepared to do this, they may find that organisations and researchers with expertise in the area – as well as the Gambling Commission - are prepared to engage rather than simply criticise. It may seem unpalatable, but gambling needs to talk about suicide.