Concerns raised 3 Reliance on industry regulatory standards rather than current good or best practice for gambling-customer protection View source Failure of the gambling-monitoring algorithm to flag problem gamblers View source Inadequacy of player protection tools to provide meaningful interaction or intervention for worsening problem gamblers View source
Actions described in response An action is something this recipient says it has done, is doing, or plans to do in response to the concern raised. 8
Action
Continue strengthening and improving Player Protection Tools and actively encourage customers to use them.
View source
Action
Participate in GamProtect to share information about highest-risk customers across major operators.
View source
Action
Review observed betting patterns, including the sawtooth pattern, to inform future safer-gambling model and control changes.
View source
Action
Strengthen the time-spent-on-site control to identify repeated moderate-duration use and escalate triggered cases for human review.
View source
Action
Update the predictive safer-gambling model with additional risk factors and greater weighting for customers returning from self-exclusion.
View source
Action
Analyse reported betting behaviours and deposit-limit changes to assess their suitability for future control-framework iterations.
View source
Action
Apply mandatory monthly net-deposit limits to customers returning from self-exclusion.
View source
Action
Operate a dedicated Customer Safety Tribe of over 300 colleagues to advance safer-gambling controls.
View source See 5 more actions
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AI-generated summary
Luke Anthony Ashton · Prevention of Future Deaths report
This summary was generated using AI from the published report. Please read the original report for the complete account.
Report summary
Luke Anthony Ashton, a 40-year-old man, was discovered deceased at Carnegie House, Swinton, on 22 April 2021, and his death was confirmed at the scene. The inquest found that he had a longstanding gambling disorder and that his gambling activity, deposits and losses were most intensive in the 10 weeks before his death. Concerns included the adequacy of player protection tools, Betfair’s failure to identify his worsening gambling through its monitoring algorithm, and the lack of meaningful intervention or interaction.
Read the report on judiciary.uk
× Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Flutter UK & Ireland; that does not assign responsibility.
PFD Monitor interpretation Reliance on industry regulatory standards rather than current good or best practice for gambling-customer protection
Wider context from the report “3) I remain concerned that, as was apparent through the evidence of a senior employee witness during the course of the inquest, the operator Betfair appears to judge the extent of its responsibilities to gambling customers solely with regard to industry (regulatory) standards, rather than current good or best practice in order to prevent further harming problem gamblers, or those who, as a result of their changing practices and patterns are likely to become problem gamblers.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Flutter UK & Ireland; that does not assign responsibility.
PFD Monitor interpretation Failure of the gambling-monitoring algorithm to flag problem gamblers
Wider context from the report “2) I remain concerned that the algorithm devised and operated by Betfair, to assist its staff in, amongst other things, observing and monitoring the gambling patterns and practices of its customers, failed to flag up Mr. Ashton as a problem gambler , despite the increases in his time online (gambling) the value of his deposits and the size of his losses, in part because his gambling practices, even in the last 10-12 weeks of his life, were deemed not to be exceptional, when averaged among gambling customers, generally.
” Open source report × Source evidence
How this individual concern was interpreted PFD Monitor created a concise, searchable interpretation from the report wording shown below. The report was sent to Flutter UK & Ireland; that does not assign responsibility.
PFD Monitor interpretation Inadequacy of player protection tools to provide meaningful interaction or intervention for worsening problem gamblers
Wider context from the report “1) I remain concerned that the player protection tools, as mentioned above, were and are inadequate to protect a person such as Mr. Ashton, who was a problem gambler with a worsening problem , specifically that such tools do not amount to any or any meaningful interaction with the gambler, or any intervention into the practices of the gambler .
” Open source report
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Continue strengthening and improving Player Protection Tools and actively encourage customers to use them.
Verbatim wording from the response “20. The use of Player Protection Tools is actively encouraged across Flutter’s entire customer base. The tools are widely promoted in our marketing campaigns (broadcast, display and digital) and on our social media channels. We strongly believe the use of Player Protection Tools is a positive behavioural indicator and that their use can help customers enhance awareness of their gambling activity and stay in control of their gambling. In fact, Flutter has a company-wide goal, linked to employee bonuses, to significantly increase the share of customers using Player Protection Tools. As of 31 July 2023, over 37% of Betfair’s customer base were using a Player Protection Tool, an increase from 21% of the customer base as of 31 July 2021.” Source location Response from Flutter
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Participate in GamProtect to share information about highest-risk customers across major operators.
Verbatim wording from the response “compliance with regulatory standards. For example, we are involved in the industry data sharing project, GamProtect, which is a pilot aimed at sharing details of some of the highest risk customers across major operators. All of our UK-facing brands – Betfair, Paddy Power, Sky Betting & Gaming, and tombola – are rated ‘Advanced level 3’, which is the highest level possible, by GamCare (the leading independent assessor of safer gambling standards).” Source location Response from Flutter
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Review observed betting patterns, including the sawtooth pattern, to inform future safer-gambling model and control changes.
Verbatim wording from the response “b. reviewed the patterns of play evident in Mr Ashton’s betting activity – such as the ‘sawtooth pattern’ identified by Professor Forrest – to incorporate learnings from this into future changes to our safer gambling models and controls.” Source location Response from Flutter
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Strengthen the time-spent-on-site control to identify repeated moderate-duration use and escalate triggered cases for human review.
Verbatim wording from the response “a. updated our “time spent on site” control so that as well as capturing customers who use our products for a significant period of time in any one day, we can identify and escalate cases where customers repeatedly use our products over a longer period; and” Source location Response from Flutter
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Update the predictive safer-gambling model with additional risk factors and greater weighting for customers returning from self-exclusion.
Verbatim wording from the response “c. updated our predictive safer gambling model, which is based on the behaviours demonstrated by customers who later self-exclude, to include more factors (now totalling 370), including a greater weighting attributable to customers returning from self-exclusion;” Source location Response from Flutter
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Analyse reported betting behaviours and deposit-limit changes to assess their suitability for future control-framework iterations.
Verbatim wording from the response “39. Our data science teams are currently analysing the behaviours outlined by ████████ in his report to assess whether any of these should be included in future iterations of our control framework (to the extent that they are not already included). By way of example, we have been looking at the “sawtooth” pattern of play and the deposit limit changes that were seen in Mr Ashton’s case to assess how they can be separated out from similar behaviour present in non-problem gamblers.” Source location Response from Flutter
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Apply mandatory monthly net-deposit limits to customers returning from self-exclusion.
Verbatim wording from the response “a. introduced, in June 2021, a mandatory net deposit limit, of no more than £1,000 per month, for all customers returning from self-exclusion – anyone returning from a period of self-exclusion undergoes a safer gambling interaction and agrees an appropriate net deposit limit;” Source location Response from Flutter
Open published response
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Source evidence
How this respondent action was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Operate a dedicated Customer Safety Tribe of over 300 colleagues to advance safer-gambling controls.
Verbatim wording from the response “50. The safety of our customers is of utmost importance to us. It is a core part of the mission, strategy and values of Flutter, which are communicated to all employees on joining, and discussed and re-committed to on a regular basis in internal communications by our CEO and senior leadership teams. Our safer gambling strategy is something we have consciously challenged all our colleagues to live and breathe on a day to day basis, and is constantly driven forward by over 300 colleagues in our dedicated Customer Safety Tribe. We are committed to operating to the highest standards in the industry and to continuing to improve our safer gambling controls to protect our customers from gambling-related harm.” Source location Response from Flutter
Open published response
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Player Protection Tools are intended to help most customers control gambling and are distinct from risk-triggered safer gambling interactions.
Verbatim wording from the response “22. We note your concern that our Player Protection Tools are not adequate to protect “a problem gambler with a worsening problem” and that “such tools do not amount to any or any meaningful interaction with the gambler, or any intervention into the practice of the gambler”. Player Protection Tools are intended and designed to help customers control their gambling, which is the case for the vast majority of our customers who use these tools. They are, therefore, different from the interactions we carry out with customers.” Source location Response from Flutter
Open published response
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation Betting exchange customers should not be treated as higher risk based on the cited survey data.
Verbatim wording from the response “28. Notably, the 2018 Health Survey shows a problem gambling rate of 0.0% for people whose only form of online gambling was betting exchanges. The data shows¹¹ that it is only when betting exchange customers engage in multiple other forms of gambling, including spread betting, that a minority may then be classified as problem gamblers. We do not therefore believe it is reasonable to conclude that a betting exchange customer is higher risk based on the 2018 Health Survey. In the case of Mr Ashton, who had excluded from gaming products, almost the entirety of his betting activity on Betfair was on the betting exchange. Information on how Betfair’s betting exchange works is set out in the Appendix.” Source location Response from Flutter
Open published response
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Source evidence
How this respondent position was interpreted
PFD Monitor created a concise, searchable interpretation from the published response wording shown below.
PFD Monitor interpretation There is no specific minimum or objectively measurable best-practice standard for gambling operators beyond principle- and outcome-based regulatory requirements.
Verbatim wording from the response “43. As a licensed operator, we are required to meet strict regulatory standards pursuant to our licence from the Gambling Commission. These regulatory standards, and in particular the social responsibility obligations contained in the Gambling Commission’s Licence Conditions and Codes of Practice (“LCCPs”), are principle-based and outcome-based expectations for the protection of individuals. Flutter Entertainment plc holds many gambling licences across the world and engages with over 40 regulators globally. Our consistent experience is that British gambling regulation is one of the most developed frameworks globally, with the Gambling Commission one of the global industry’s most widely-respected regulators.” Source location Response from Flutter
Open published response
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Information checked against published PFD reports and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations