On the 4th of October, the "Embracing ESG – An ongoing commitment for the gaming industry" business seminar, hosted by GTG in collaboration with Zampa Debattista, brought together industry leaders, experts, and stakeholders to discuss the evolving landscape of ESG in gaming.


Dr Ian Gauci, Managing Partner at GTG, set the tone for the seminar with an insightful short speech. Dr Gauci stressed the importance of imbuing the correct mindset when considering ESG. He emphasized that effective implementation of ESG reporting and standards requires collaboration between industries and public authorities to create measures that are proportional, sustainable, and effective. Dr Gauci added that ESG standards should transcend the realm of a mere marketing tool and be seen as a genuine commitment rather than an obligatory burden.

Keynote Speech

Dr Carl Brincat, CEO of the Malta Gaming Authority (MGA), delivered his  keynote speech describing the strategic objectives it set itself as a regulator and for its licensees on ESG takeup. Dr Brincat underlined the idea that MGA licensees should embrace ESG not only because it is the right thing to do but because it also makes good business sense. He expressed his belief that the gaming industry has the potential to lead in ESG reporting and described the motivation and principles of MGA’s forthcoming voluntary ESG code of good practice that it intends to publish in the coming months, highlighting the regulator's commitment to ESG principles, and the regulator’s commitment to continue strengthening Malta’s reputation.  The MGA will be the first gaming regulator in Europe to establish a code of good practice in relation to ESG.

The seminar then featured three informative panels, each addressing different aspects of ESG in the gaming industry.

Panel One

The first panel, moderated by Mr Mark Wirth, Partner at Zampa Debattista, consisted of industry experts: Mr Reuben Portanier, Advisory & Compliance Partner at GTG, Ms Kinga Warda, Chief Officer of International Affairs at the Malta Gaming Authority, and Ms Jonna Danlund, Head of Sustainability at Betsson Group.

This panel delved into the "Applicability of Corporate Sustainability Reporting Directive and Non-Financial Reporting Directive" exploring parallels with the financial services industry and emphasizing that the gaming sector may be better prepared for ESG than it realises.  Ms Warda provided the floor with a comprehensive account of how the concept of a voluntary code came into being and what the code would possibly include following the conclusion of the assessment of the recent public consultation process.  Ms Warda also gave some examples how the MGA could encourage take-up of voluntary ESG reporting, whereby the full details will be published in the coming months.

Mr Portanier provided an insightful parallelism between the financial services industry and the online gambling industry in terms of ESG readiness, highlighting that in certain aspects, such as responsible gaming, the gambling sector may be more prepared for the ‘S’ (Social) in ESG, whilst he also described how both sectors are heavily regulated even on a governance side, meaning that MGA licensees may already have strong foundations to adopt ESG, even if not all types of gambling operators will be not mandated at law to have an ESG framework.

Ms Danlund gave an insightful account of how Betsson prepared itself for ESG reporting, and the journey they adopted in order to have a robust ESG framework in place, as given their size and listing status, they already had to produce certain ESG metrics, but with the first reporting cycles under new CSRD, the ESG reporting and auditing will step up, and Betsson have prepared well for this.  She remarked that CSRD, will bring along a paradigm shift whereby non-financial disclosure is not only for shareholders and creditors, but is directed to a wider audience where we will now talk of stakeholders rather than shareholders.

Panel Two

The second Panel, titled "How can the gaming Sector address the ‘E’ in ESG" was moderated by Mr Enrico Bradamente, Chairperson of iGen Malta, and featured Perit David Xuereb, Chairperson of the Malta ESG Alliance, and Ing. Christian Sammut, CEO of BMIT Ltd. This thought leadership panel discussed the environmental aspects of ESG and ways in which the gaming sector can contribute to sustainability efforts.  Mr Sammut provided some interesting statistics on the carbon emissions generated by technology companies and the gaming sector in particular through the extensive use of technology, and described how BMIT as a colocation and technology services listed company has implemented measures in order to reduce the carbon footprint generated by the sector. He also emphasized how CSRD will bring about a change in supply chain relationships as companies serving other companies captured by the CSRD, will still need to equip themselves with a sufficient ESG framework in order to provide ESG related data requested firms in-scope of the CSRD. 

David Xuereb illustrated some parallels with other sectors when it comes to the ‘E’ (environmental) in ESG, and what other sectors are doing or planning to do to reduce their carbon footprint, which could be replicated in the gaming sector.  Mr Xuereb also gave an account of what the Malta ESG Alliance is trying to achieve and welcomed MGA’s voluntary code on ESG. 

Mr Bradamente moderated the panel, but also described iGen’s initiatives in relation to safeguarding and regenerating the environment, and the gaming operators’ concrete will to make a positive difference.

Panel Three

The third panel, moderated by  Mr Reuben Portanier focused on "Modelling an ESG compliance program for a gaming operator and how to construct measurable reporting outcomes that can be audited" and included Ms Liesbeth Oost, Head of Global Sustainability and IR Manager at Neogames, and Mr Mark Wirth. The discussion revolved around practical steps and strategies for implementing ESG compliance programs within gaming companies, but also addressed technical elements such as the role of auditors in ESG reporting and the new concept of double materiality. 

Ms Oost provided a practical step by step guide how a gambling operator can design its ESG framework, but she also emphasised on the need to design ESG metrics that truly provide value to stakeholders.  Ms Oost described how certain generic benchmarks are available through the CSRD framework, however, industry specific benchmarks for niche industries such as the gaming sector, are lacking, such as there are no agreed upon benchmarks yet on responsible gaming metrics, whereby Neogames invested a lot of effort in researching how to what to report about responsible gaming that would be meaningful for the business and the stakeholders in general, citing as well the double materiality concept.

Mr Wirth continued on amplifying the concept of double materiality and how an operator needed to report on outcomes rather than on outputs, on the effect of outcomes generated by the company, and on ESG outcomes that affect the company. Mr Wirth also described how although the first reporting cycle under CSRD will be in 2024, however the CSRD itself provides for a learning curve of a few years, especially for ESG auditors to validate which data feeding into the ESG benchmarks.  Mr Wirth also described how through CSRD, suppliers who are not necessarily large and are not captured by the CSRD, will indirectly still need to have an ESG framework in place in order to continue forming part of the supply chain of a CSRD captured firm.

Closing Remarks

Mr Matthew Zampa, Co-founding Partner of Zampa Debattista, delivered the closing remarks, expressing optimism about the future of ESG in the gaming industry and highly commending the MGA for the initiative they are taking in again being amongst the most innovative gaming regulators through its imminent launch of the voluntary ESG Code for licensees.  


The ‘Embracing ESG – An ongoing commitment for the gaming industry’ seminar was a resounding success, drawing a full house and igniting important conversations about ESG in the gaming sector. The event showcased the industry's commitment to embracing ESG principles and opened the door for further discussions, collaboration, and work in the realm of ESG within the gaming space. It is clear that ESG is not just a buzzword but a genuine commitment for the gaming industry,

For help or assistance with ESG, please do not hesitate to reach out to our team of ESG and Gaming experts at info@gtg.com.mt

Disclaimer This article is not intended to impart legal advice and readers are asked to seek verification of statements made before acting on them.
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