Commercial gaming


In most cases, gambling is a harmless activity that can serve a purpose as entertainment or a pastime. However, some individuals find it difficult to set limits to their gambling, which can lead to gambling addiction and dependency, causing great harm to themselves and society. This can take the form of financial losses or that the time and energy that the individual devotes to gambling makes it difficult to maintain normal social relations and keep personal finances in order. Other sustainability aspects regarding gaming include prevention and counteraction of corruption and money laundering.

The digital market for gaming is undergoing rapid development and change. Companies that produce and market digital gaming services must handle the complexity caused by regulations on different markets, and interpretation of these regulations, in a responsible way.

A number of conventions and guidelines have influenced the Council on Ethics’ position on commercial gaming, including:

• CEN Workshop Agreement on Responsible Remote Gambling Measures (CWA 16259:2014).
• The United Nations Convention against Corruption.

Purpose and objectives

The First (AP1), Second (AP2), Third (AP3) and Fourth (AP4) Swedish National Pension Funds can invest in companies that produce and market betting games. For the AP-funds, it is important that the companies carry out their production, marketing and sales of gaming products in a responsible manner. The companies must take responsibility for self-regulation, in order to prevent negative social, health-related and financial effects of their gaming products and services.


In dialogue with gaming companies, the AP-funds work to ensure that the companies

• comply with applicable laws in the countries in which they operate
• comply with applicable sector standards or apply their own rules for responsible marketing and sales
• actively influence suppliers and commercial customers to ensure compliance with applicable laws
• manage and prevent sustainability risks and gambling addiction, and
• work actively to prevent and counteract corruption and money laundering.