Getting ahead of the game

Having watched the backlash against the industry develop in other jurisdictions throughout the world, India’s rummy industry is taking proactive steps to self-regulate, discovers Joanne Christie

When it comes to the potential of emerging igaming destinations, India and Africa have much in common. Both have huge populations and strong sporting cultures, but both also come with big challenges in terms of the lack of regulation.

However, one key difference among the jurisdictions has emerged of late: the attitude to responsible gambling.

In recent times Africa has been plagued by tales of the irresponsible behaviour of operators in various countries, with claims that bookies accept bets from children making it as far as the mainstream British press. At the recent KPMG Malta Gaming eSummit, Gaming Intelligence director John Kamara lamented the fact that many of the operators that had entered the African market were “cowboy operators” that had influenced naive regulators into setting insufficient regulation that failed to adequately stipulate player protection measures. “That then creates a situation where you expect some of the operators who come into the market to self-regulate, but as we know, that never happens,” he told the audience at a panel entitled Spotlight on Africa. The sentiment is a familiar one; even in mature jurisdictions many have claimed regulators must adopt stronger regulations as operators themselves can only be relied on to do exactly what’s required and no more. But the recent efforts of the small sector of India’s igaming market that operates legally would seem to disprove this theory.

While games of chance are mostly illegal in Indian states, games of skill are mostly permitted. However, this is due to various courts ruling such games are not illegal rather than any regulatory system overseeing operators.

In the absence of regulation, there’s nothing to dictate how operators should behave in terms of responsible gambling.

But rather than take advantage of this by behaving irresponsibly, a group of the main rummy operators active in India decided instead to come up with a system of self-regulation.

Setting standards In late 2017 non-profit The Rummy Federation (TRF) was set up to develop a framework of standards for the growing industry. The goal, according to Sameer Barde, CEO of TRF, was to legitimise the industry. “We thought it was very important to actually be very fair, be very transparent and be able to very clearly say to our external stakeholders that we will be proactive. “Even if there is no regulation, we will self-regulate and we will ensure that we do it in a way that is stringent, that is fair and that ensures that the player gets a fair deal, that everything is safe and secure in terms of data, and similarly that the player has full control in terms of how much time or how much money he wants to play with.” In February 2019 the TRF’s code of conduct was finalised, following which a Big Four accounting firm was engaged to carry out an audit on a number of its operator members.

Seven operators signed up for the audit, which required six months of data to be available, with four found compliant with all elements of the code.

Those that didn’t make the grade this time around have been given detailed feedback to allow them to improve prior to the next audit, says Barde.

In December the four operators that passed the audit –  Ace2three, Junglee Rummy, Rummy Passion and RummyCircle – were awarded the TRF Dynamic Seal, with an advertising campaign set to launch in the early months of 2020 to educate players on what this means.

“The idea is to tell players about the seal itself,” says Barde. “We won’t be saying ‘XYZ operator has the seal, play with this operator’, because the operators will keep changing in the sense that more might get added.”

As well as telling players to look for the seal when choosing where to play, Barde says the campaign will focus on explaining all the responsible gambling tools available to players to help them remain within their limits. The prudent approach Seal holder RummyCircle, India’s largest real-money gaming operator with more than 500,000 monthly active players, has taken the commitment to responsible gambling a step further by setting up the Game Prudence initiative.

Avinash Agrawal, head of risk, payments and responsible play at Games24x7, which runs RummyCircle, says the free counselling service came about after the company started looking at regulations in other jurisdictions for best practice. “I have been part of quite a few forums where gaming operators from across the world were and we definitely had certain learnings from them. At the same time, I was in touch with GamCare and the whole idea of Game Prudence came from there.”

On its own platform, RummyCircle uses data science and artificial intelligence to identify players who may be at risk and requires these players to take a survey. “That journey is very well-crafted in a way that if the player does not take the survey within 14 days, then his limits are drastically reduced, so that way he is incentivised to take the survey. That survey uptake rate is close to 90%,” says Agrawal. Those who the survey identifies as demonstrating risky behaviour are then referred to counselling at Game Prudence, which is provided free of charge and by psychologists trained in responsible gambling.

Agrawal concedes that as the operator was the first to bring in such strict responsible gaming measures and mandatory surveys, some pushback from players was to be expected.

“Initially we saw some revenue dip, but we have realised over a period of time that players realise we are doing it for their wellbeing and the entire player base takes that as a positive thing.

“If you do anything like this, the kind of revenue you are losing versus the kind of comfort level you are creating with players balances out in the long run.”

Though at present RummyCircle is the only operator using Game Prudence, there’s a clear demarcation between RummyCircle and Game Prudence.

This is not only because Agrawal says it helps players feel more comfortable discussing their issues, but also because it is hoped that other Indian operators will also integrate with the system in the near term.

“Now that we are able to demonstrate the success we are driving out of this programme without much impact on the revenue, we find there are operators who see value in it and are keen on adopting it,” he says. Though the online rummy market isn’t new in India, with RummyCircle having been running for about nine years, it is still quite concentrated, with Agrawal estimating that the leading four operators account for about 95% of rummy play in India.

He says this means they have a unique opportunity to avoid the problems faced in other jurisdictions.

“In the West, initially most of the operators did not care about caring about players and ensuring they don’t turn out to be irresponsible players or risky and we have learned a lesson from them. “It is pretty easy to adopt responsible play practices when the industry is very small versus when the industry is very competitive.

"The Indian market is growing exponentially and the margins are very good. It is more like an oligopoly, with a few players dominating the market, so it is a lot easier right now to adopt these practices.

“If you don’t do that, there will be a government body or regulations will be forced upon you just like happened in the West. Those regulations at times are not very rational in themselves.

"Most of the time they do not actually solve the responsible play problem and are more operational in nature.”

Barde says that if the Indian states do eventually begin to allow other verticals – the possible legalisation of sports betting has been discussed at length in recent years – the rummy industry’s responsible gaming efforts could be used to apply standards across other areas.

“By that time, we would have not only already implemented this, but we would also have gotten a lot of learnings from it.

We would be very happy to collaborate with the government and we could contribute in a big way by saying, ‘here is a standard that is already there’,” he says.

Whether or not India is going to open up the chance-based verticals to legal operators remains to be seen.

But if it does, it seems the skill-based industry will have provided a useful blueprint to help ensure it doesn’t face the same type of backlash that has been seen in other emerging regions in recent times.