Responsible gambling disclosure strategies of Nordic state‐owned gambling companies

The aim of the study was to identify the disclosure strategies employed by these companies. To this end, the framework developed by Leung and Snell (2021) was applied. The framework identifies six disclosure strategies:

1. Ethical reflexivity, consisting of consistent, critical evaluation of responsible gambling practices and acknowledgment of responsibility
2. Assertive façade, in which companies typically highlight and detail their responsible gambling efforts, achievements, and certifications
3. Defensive façade, in which companies give the appearance of responsibility while actually being passive or merely compliant, often characterized by vague, generalized language used to list goals or actions
4. Disclamation, referring to attempts to deny or obscure ethical responsibility for gambling harm
5. Curtailment, meaning minimal or superficial coverage of responsibility issues
6. Zero disclosure, which involves the complete omission of any discussion of harm-related issues.

However, curtailment and zero disclosure were not relevant here because all companies actively mentioned responsible gambling. The focus was thus on the remaining four strategies.

Responsible gambling as a form of political influence

Responsible gambling disclosures are often framed as part of corporate social responsibility practices, but they frequently serve strategic purposes, such as preserving legitimacy and warding off regulatory pressure. Critics argue that the gambling industry’s approach tend to focus narrowly on individual gamblers, overlooking systemic issues such as the addictive design of gambling products and aggressive marketing practices. Scholars argue that this individual-centered approach can obscure the industry’s vested interest in maximizing profits from high-spending gamblers—many of whom experience severe gambling harm.

In this analysis, responsible gambling is understood as a political and rhetorical tool. The study adopts a discursive approach, examining how companies talk about responsible gambling rather than evaluating the effectiveness of their measures.

Key Findings

Ethical reflexivity

This strategy was the least used, with only 11 instances identified across all companies. Veikkaus and Norsk Tipping showed some reflexivity—for instance, Veikkaus admitted to past shortcomings in harm prevention. Danske Spil showed no signs of reflexivity, while Svenska Spel displayed minor signs by acknowledging regulatory fines.

Assertive façades

All companies employed the assertive façade strategy to some degree. Veikkaus relied in it most heavily, with 35 per cent of its disclosures using this approach, followed by Svenska Spel. Examples included highlighting audits by gambling industry bodies, describing customer outreach efforts such as “care calls,” and reporting metrics like self-exclusion rates. The disclosures often focused on efforts and intentions rather than outcomes or ethical implications.

Defensive facades

The predominant strategy identified was the defensive façade, accounting for 57 to 74 per cent of disclosures from each company. For instance, companies would claim that enhancing customer experience and reducing harm go hand in hand, yet they failed to acknowledge or address potential contradictions in these claims.

Norsk Tipping framed its operations as fully aligned with national policy goals, positioning itself as a mere implementer of state intentions. Veikkaus often presented its regulatory compliance as voluntary responsible gambling effort. Meanwhile, Danske Spil acknowledged the risks of gambling addiction but underscored that responsibility for diagnosis and treatment lay beyond its scope, adopting a passive role in harm prevention.

Disclamation

Disclaiming language appeared in 5–7 per cent of the companies’ disclosures, often used to frame responsible gambling as a financial burden or shift responsibility onto gamblers or unregulated operators. All companies except Svenska Spel employed this strategy.

For example, Norsk Tipping reported that certain measures led to reduced revenue implying that responsibility comes at a financial cost. Danske Spil argued that effective harm prevention required collective industry-wide action, thereby diffusing its own responsibility. Veikkaus occasionally blamed unlicensed operators for gambling harm. At times, disclaiming language also involved stigmatizing terms. Referring to “problem gamblers” as a distinct group reinforced the idea that gambling harm is an issue of individual pathology, not of product design or business practices.

Comparison of the companies

Despite differences in national regulation and market structure – Veikkaus and Norsk Tipping operating as monopolies, while Danske Spil and Svenska Spel compete in open markets – the four companies employed similar disclosure strategies. However, there were some differences.

1. Veikkaus provided the most extensive reporting and adopted a more detailed and ambitious tone. This approach can possibly stem from public criticism and political pressure in Finland during the period studied.
2. Svenska Spel avoided disclaiming strategies more than the others, possibly reflecting Sweden’s regulatory context.
3. Danske Spil distinguished itself by framing responsibility as contingent on broader industry action, and showed limited engagement with reflexivity.
4. Norsk Tipping heavily emphasized its alignment with national policy, portraying itself as a mere executor rather than an independent actor.

Responsible gambling disclosures as post-political discourse

The strategic use of responsible gambling disclosures can be aligned with the characteristics of post-political discourse. Post-political discourse aims to mask political conflicts by stressing shared objectives. Such an approach depoliticizes the prevention of gambling harm, framing it as a consensual or technical matter. Responsible gambling, with its focus on industry self-regulation, exemplifies this, with the gambling industry often recognized by governments and regulators as a key policy actor in addressing gambling harm.

Promoting responsible gambling as a legitimate harm prevention strategy risks obscuring the conflict between public health and economic profit, potentially removing these competing values from the political agenda. Researchers and policymakers must recognize that such conflicts involve fundamental differences in values.

The article is written by Jani Selin, senior researcher, Finnish Institute for Health and Welfare

on the request of PopNAD.