One of the world’s largest gambling companies, Aristocrat Leisure, held its first ‘ESG Day’ for its many institutional investors late last year.

The ASX 20 company, which has AustralianSuper as its biggest shareholder, hosted briefings giving investors and other stakeholders an update on what it was doing in areas such as responsible gameplay (RG), climate action and modern slavery.

So what did investors learn about the ‘global entertainment and content creation company’ and its ESG credentials?

Source:  Aristocrat Sustainability Presentation December 2023

Responsible gameplay

Aristocrat highlighted its RG initiatives such as its ‘positive play’ consumer education campaign for electronic gaming machine (EGM) players in the US; Australia’s first-ever trial of cashless EGM technology, and the rollout of a targeted RG messaging model to its mobile social casino game player community.

However, The Future Fund asked Aristocrat if it felt there was any tension between designing games that use colours and sounds to attract customers and its various RG initiatives.

Aristocrat’s chief corporate affairs officer Natalie Toohey replied: “We really genuinely don’t see any conflict between being a growing business and being a business that is really active and serious in RG.”

“In fact, we think that it is  complementary because we really do believe that the number of players in the player cohort across all the products verticals who are experiencing problems is small,” Toohey said.

Source: Aristocrat Leisure

Asked later whether Aristocrat had any estimates on the number of players in the ‘at risk’ or ‘disordered’ categories, Toohey told the audience that “in our mobile business we don’t have a full view but we have some data points we can use as a bit of a proxy”, such as the level of self-exclusions.

For its regulated business, Toohey said coming up with any figures was also difficult as different jurisdictions had different definitions of ‘at-risk’ and ‘disordered’.

Toohey did say Aristocrat had previously cited a European online real money gambling (RMG) study that found a 1 to 2 per cent disordered rate.

“Rather than spend a lot of time trying to get to the answer on the number we feel as a supplier and industry leader” the company’s focus “just needs to be on what we can do – whether the number is 1 per cent, zero per cent or 3 per cent – … to make sure there are tools and strategies that address that and drive that number down,” she said.

It must, however, be a bit difficult for Aristocrat to know if it is driving the number down if it doesn’t know what the number is.

Aristocrat was also asked if there empirical studies had been done, linking its RG programs with the reduced prevalence of problem gambling. Again, Aristocrat had little to offer here, saying the purpose of its recent RG trials “is to start to get some clues”.

The company also declined to reveal how much it spends on RG research.


Aristocrat has funding partnerships in place to support various organisations including the Gambling Treatment and Research Clinic at University of Sydney.

The company says its funding of the clinic is contributing to a better understanding of development of harm over time to gambling customers and what resources or interventions would be useful to minimise risks.

So what is the clinic saying about gambling? In an article last year, clinic director Dr Sally Gainsbury said “the prevalence of harmful gambling is not one per cent”.

“Around one-fifth of regular gambling customers experience at least moderate levels of gambling harms,” she said.

“An additional 10 to 20 per cent of regular customers on most forms of gambling experience low levels of harm.

“This creates a sizable proportion of regular gambling customers who would arguably benefit from tools and resources to enhance their ability to gamble in a lower-risk way.”

Gainsbury also said “many of us are unaware of the factors influencing our decisions at any point in time”.

“It is very difficult for others, including gambling operators, to perceive whether someone is gambling in a risky versus sustainable way,” she said.

An Australian Gambling Research Centre study last year, Gambling participation and experience of harm in Australia, found that among those who gambled, almost half (46 per cent) could be classified as being at some risk of gambling harm in the past 12 months (based on the Problem Gambling Severity Index).

Meanwhile, the Australian Government is introducing mandatory minimum classifications for computer games containing gambling-like content from September this year.

Computer games containing in-game purchases linked to elements of chance, such as paid loot boxes, will receive a minimum classification of M (Mature – not recommended for children under 15 years of age).

Computer games containing simulated gambling, such as social casino games like Aristocrat’s Lighting Link Casino, will be legally restricted to adults only with a minimum classification of R18+.

The Government said “the changes respond to growing community concerns about the potential harms of children accessing gambling-like content in computer games”.

Climate Action

Aristocrat also outlined to investors what looks like some encouraging progress on its decarbonisation journey.

In November 2023, Aristocrat submitted its proposed emission reduction targets (see below) to the Science Based Targets Initiative (SBTi). The company expects the SBTi to respond to its submission by mid-2024.

Source: Aristocrat 2023 Sustainability Report

When or if the targets are validated by SBTi Aristocrat says “we will formalise our decarbonisation plan, promote our targets and approach with our stakeholders, and pivot from target setting to driving and tracking our abatement effort”.

However, Aristocrat flagged it is likely it will have to recalculate it 2022 greenhouse gas (GHG) emissions base year to take into account its recent $1.5 billion acquisition of US gaming software firm NeoGames.

Nearly all (97.9 per cent) of Aristocrat’s emissions are scope 3, mainly in the ‘use of sold products’ and ‘purchase goods and services’ categories.

Aristocrat’s 2023 Sustainability Report says a number of its customers, suppliers and competitors are taking or planning to take similar abatement actions and “this will assist us in delivering our abatement plan, as we will accrue scope 3 emissions reductions in our value chain as a result of customer and supplier targets for scopes 1 and 2”.

The company said “other industry participants taking similar action will enable us to form potential coalitions to assist with future customer and even supplier decarbonisation efforts”.

Anti-modern Slavery

In Monash University’s most recent assessment report of the top 100 ASX-listed companies’ modern slavery statements, Aristocrat’s 2022 Modern Slavery Statement received the highest “A” rating, with Monash noting that the company was the biggest improver.

While Aristocrat may have received an “A” rating there is still plenty of scope for the company to improve things on the activity and reporting fronts.

Aristocrat has a large complex global supply chain involving over 100 direct suppliers in 25 countries. The company said it had recently completed a pilot supplier audit program – however this audit covered just five suppliers.

Aristocrat’s 2022 statement runs for a lengthy 54 pages but has a lot of padding that doesn’t tell readers much. The statement includes a dull and opaque ‘case study’ on its Incident Response Guide and an unusual one on the risks of Aristocrat staff donating toiletries to charities.

As is the case with nearly all ASX companies required to lodge modern slavery statements, Aristocrat “did not identify any specific incidents of modern slavery in our operations or supply chain” in its 2022  financial year (it has yet to lodge its 2023 statement).

The 2023 Sustainability Report also claims the company’s work spans many of the United Nations Sustainable Development Goals (SDGs) and highlights 11 (out of the 17) SDGs that it believes “align closely with our business, our stakeholders’ expectations and where we can have the greatest impact”.

Source: 2023 Aristocrat Sustainability Report

Unfortunately the report provides little additional information. Aristocrat does not identify any of the many sub-targets for each of these SDGs that it plans to address; set any metrics for addressing these sub-targets; or explain how it will report on its progress. Nor does it say whether there any SDGs where it might be making a negative contribution.

By displaying the brightly coloured SDG tabs throughout the report Aristocrat risks leaving itself open to accusations of greenwashing.

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