Ad description
A promotional voucher for William Hill received from a slot machine in a William Hill betting shop on 3 April 2025, printed at 11:51 AM. The voucher stated “You’ve won a £5 cash match on any game!” and “Redeemable between 03/04/2025 – 03/04/2025 from 05:20 PM – 11:59 PM in any venue”.
Issue
The complainant challenged whether the timeframe between when the voucher was issued and when it was redeemable breached the Code, because it was socially undesirable by encouraging irresponsible use.
Response
William Hill Organization Ltd t/a William Hill said that they did not believe the promotion breached the CAP Code or encouraged behaviour that was socially undesirable or irresponsible. The promotional voucher was issued to customers who staked £50 or more on an eligible gaming machine prior to 17:20 on the day that the promotion was issued and valid. They clarified that this was the total value of stakes placed in-store, including both the customer's original cash-in, and any winnings that were subsequently played again. They provided evidence demonstrating that the average cash-in in relation to the three-day promotion was below the average spend for April and May 2025. Because of this, they did not believe that the amount needed to spend in order to qualify for the promotion was substantial, nor that the promotion encouraged excessive staking. If the customer met the eligibility criteria, then they would have received a voucher that stated “You’ve won a £5 cash match on any game!” and “Redeemable between 03/04/2025 – 03/04/2025 from 05:20 PM – 11:59 PM in any venue”.
The voucher offered them a £5 cash match on a game of their choosing. They believed that the promotion was a low-value, one-off reward and highlighted that it did not involve any progressive elements, wagering multipliers, or additional conditions beyond what was initially displayed. On that basis, they said it was not part of a broader incentive structure nor designed to drive repeated play. They said that the terms of the promotion (including the staking threshold and the redemption timeframe), were communicated to customers clearly and fully, and consequently they said customers were given sufficient information to make an informed decision before participating. They explained that the key qualifying conditions were displayed on digital promotional screens in the shop and the voucher reiterated those eligibility conditions. In their view, the voucher served as a confirmation of eligibility which reminded consumers of the pre-disclosed redemption timeframe.
Furthermore, they said that redemption of the voucher was entirely optional; there was no requirement for the customer to remain on premises after qualification, or to return later in the day. Customers could freely choose not to redeem the reward and doing so did not require any further spend or engagement. They provided data demonstrating that the majority of customers who qualified for the voucher did not redeem it. They believed that this showed that consumers understood that there was no obligation to redeem the voucher. The promotion provided customers with a one-off modest reward of £5 and therefore they did not believe that at any stage the promotion encouraged a customer to remain on the premises to engage in excessive consumption, nor encouraged irresponsible use. They acknowledged that the redemption window began at a specific time later on the same day the voucher was printed. However, they said that the promotion did not encourage participants to remain on the premises and therefore it did not create any time-sensitive pressure to continue playing. They provided a percentage breakdown of the time period between when the voucher was issued and redeemed. Very few customers redeemed the voucher within two hours. The majority of customers waited at least three hours. Due to extended gaps between when the voucher was issued and redeemed, they said that this strongly indicated that most customers had left the shop and returned later to redeem the voucher. They believe this undermined the suggestion that the redemption window pressured customers to remain in-shop or extend their play.
They highlighted that all staff in their retail betting shops received training to identify and act on signs of gambling-related harm, including repeated visits. Further, their gaming machines provided prompts to customers to remind them of their time and spend and allowed customers to set their own limits. They believed that had any concerns been raised regarding customer behaviour in relation to this promotion, action would have been taken in line with their policies.
Assessment
Upheld
The CAP Code required that promotions were not socially undesirable to the audience addressed by encouraging irresponsible use.
The ASA understood that the complainant received the voucher at 11.51 am on 3 April 2025 when it was automatically printed from a slot machine. The voucher stated “You’ve won a £5 cash match on any game!” and “Redeemable between 03/04/2025 – 03/04/2025 from 05:20 PM – 11:59 PM in any venue”. We understood that the voucher was only valid on that day and that the redemption window commenced at 05:20 pm – five hours and 29 minutes after the voucher was initially printed for the complainant. We also understood that consumers only qualified for those who had staked a minimum of £50, across cash-in, and any winnings that were subsequently played again, on an eligible gaming machine prior to 5.20 pm that day.
We acknowledged William Hill’s response that the voucher was optional, that only a proportion of eligible participants redeemed it, and that most participants redeemed the voucher at least three hours after they had qualified for it, all of which they believed demonstrated the redemption window of the promotion did not encourage irresponsible use. However, we considered that, because the redemption window was limited to a later time on the day it was printed, it meant that most participants could only benefit if they returned to the premises or stayed until the later start time. In addition, we noted that was reflected in the percentage breakdown of the time period between the voucher being issued and redeemed. We also considered that those who were eligible for the voucher may have already placed several bets earlier that day, as the voucher was issued once an individual’s total stake reached £50, which could include repeated play of winnings. We therefore considered that the timeframe between when the voucher was issued and when it was redeemable created an incentive for repeated play within a short period, including visiting the betting shop twice in a single day, increasing the risk of consumers gambling more than they otherwise would.
We thus considered that linking the reward to a same-day timeframe, particularly at a limited period later on the day, incentivised behaviours that could encourage irresponsible use.
For those reasons, we concluded that the promotion encouraged irresponsible use and breached the Code.
The ad breached CAP Code (Edition 12) rule 8.5 (Protection of consumers, safety and suitability).
Action
The ad must not appear again in the form complained of. We told William Hill Organization Ltd t/a William Hill to ensure that future promotions did not encourage irresponsible use.
