Research Article: Applying Corporate Political Activity (CPA) analysis to Australian gambling industry submissions against regulation of television sports betting advertising

Date Published: October 16, 2018

Publisher: Public Library of Science

Author(s): Linda Hancock, Natalie Ralph, Florentine Petronella Martino, Dorothy Porter.


This research aimed to assess the application to the gambling industry, of Corporate Political Activity (CPA) analysis previously developed from public health research on tobacco industry interactions with political institutions and previously applied to the alcohol industry, but not the gambling industry.

A growing body of literature has confirmed how public interest outcomes are frequently opposed by vested interests. This research focused on gambling industry submissions to a 2013 Australian Parliamentary inquiry into sports betting advertising. Gambling advertising became highly controversial following deregulation of sports betting advertising in Australia subsequent to the 2008 Australian High Court Betfair challenge. The dramatic increase in gambling advertising during sporting event broadcasts at children’s viewing times and on new interactive technology, sparked public concerns. A series of national regulatory reviews followed and the gambling industry was actively involved in opposing further regulation.

The research used a corporate political activity (CPA) framework of analysis developed by UK tobacco public health researchers, which identified strategies and tactics used internationally by the tobacco industry, to broker pro-tobacco public policy outcomes. Testing the application of this CPA framework to gambling pro-industry strategies/tactics, this research focused on gambling industry submissions to the 2013 Australian Parliamentary Committee Inquiry.

Like the tobacco industry, the research found the gambling industry used identified strategies and tactics, some new tactics and a new strategy of ‘Corporate Social Responsibility’, promoting ‘responsible’ industry practices and pre-emptive establishment of internal ‘responsibility’ units/practices. Despite public concerns regarding sports betting advertising, the gambling industry reinforced individual choice/blame for harms and claimed it acted responsibly. It did this using strategies identified in the tobacco industry CPA framework: information strategy (and shaping the evidence base); financial incentive strategy; constituency building strategy; policy substitution strategy; legal strategy; and constituency fragmentation and destabilization strategy.

Similar to the CPA analysis applied to tobacco and alcohol industries, the research demonstrated the usefulness of the CPA taxonomy for analyzing and documenting pre-emptive industry policy strategies and tactics, exposing gambling industry efforts to maintain industry self-regulation via voluntary codes and avoid more government regulation. Cross-sectoral application of the framework signals great potential for use of CPA by policymakers and public health advocates as a tool in the analysis of corporate industry arguments/discourses.

Partial Text

The influence of powerful vested interests over policy processes has posed barriers to the implementation of harm prevention public policies in industries known for potential harms. Corporate strategies to influence policies away from increased regulation have been well illustrated by the application of corporate political activity (CPA) analysis to tobacco industry (TI) influence [1] and alcohol industry influence against marketing regulation [2, 3], but not applied so far, to gambling.

Despite regulatory variations, there is widespread agreement on age limits to participation in gambling. In the United States it is 21 years of age, in the United Kingdom (UK), 18 (except for lotteries and arcade games), Australia 18, Canada 18 or 19 (depending on the province), and in Macau, people must be over 21 to gamble. Age-restrictions on potentially risky activities like gambling and alcohol, reflect the moral and ethical commitment of governments and regulators to the protection of minors as vulnerable persons and gambling and alcohol as adult-only activities. In the UK for example, this is expressed formally in the third licensing objective of the Gambling Act 2005, which specifies the importance of protecting children and other vulnerable persons “from being harmed or exploited by gambling” [19].

Concerns about under age exposure to gambling have focused not only on advertising, but in combination with new gambling platforms, accessible through internet-connected devices widely used by young people and increasing concerns about harms associated with more pervasive forms of gambling like online sports betting [26, 27]. This facilitates marketing delivered by internet and during sporting events, at any time and any place. New of access via internet and internet-connected devices, such as smartphones and tablets, have smoothed the way for the expansion of internet-based sports gambling, which has become a thriving industry.

CPA has been a focus of research on corporate influence since the 1980s, with CPA defined by Baysinger [29], as corporate attempts to shape government policy in ways favorable to the firm. Despite public health advocates’ efforts to bring research evidence on the harmful impacts of tobacco, alcohol and processed food to the notice of governments, it is only recently that the corporate political influence of the TI has undergone systematic analysis. Release of confidential TI documents has enabled analysis of corporate strategies applied by the TI to influence public health policy [30, 31, 32, 33, 34]. Recent CPA research, applied to ‘Big Tobacco’ [1], alcohol [2, 35] and (processed) food [35, 36], has demonstrated the effectiveness of CPA research in the analysis of industry tactics applied by, what might be considered, ‘dangerous consumption’ industries. However, CPA analysis has yet to be applied to the GI (although there have been some more narrowly focused studies of agenda setting and political ‘framing’) [37]. Common observations of gambling industry ‘wins’ on regulation have included watered down reforms, industry self-regulation via voluntary codes, covert concessions on rates and taxes, and government regulation that ‘turns a blind eye’ to industry misdeeds [11, 38, 39, 40]. The GI shares many similarities with ‘dangerous consumption’ industries, and the global explosion of gambling over the last two decades merits the inclusion of the GI in studies of “increased consumption of unhealthy commodities” [35]. CPA analysis is potentially useful to gambling industry researchers by identifying the strategies/tactics used by the GI.

The Australian GI used all six of Savell et al.’s [1] strategies to oppose national re-regulation of sports betting advertising during sporting event broadcasts in analysis of the six GI submissions. A new seventh strategy, ‘Corporate Social Responsibility’, and four new tactics were also identified. These are highlighted by shading in Table 1 below.

The application of Savell et al.’s [1] taxonomy, which was developed to analyze TI strategies/tactics used to oppose increased government regulation, certainly resonates with GI CPA. The results confirmed the strategies of (1) Information (and identified two additional tactics), (2) Constituency building, (3) Policy substitution, (4) Legal, (5) Constituency fragmentation and destabilisation, (6) Financial incentive, and reveals a new strategy of (7) Corporate Social Responsibility with 2 new tactics.

The 2013 Select Committee Inquiry outcome ultimately recommended the status quo while recommending the current exemption of gambling advertising for sporting programs be reviewed; stating that, “(t)he changes do not affect general gambling advertising which would continue to be allowed during a sporting match” [5].




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