APPENDIX 2
LITTLEWOODS SUBMISSION TO THE GAMBLING REVIEW
BODY
EXECUTIVE SUMMARY
Key Issues
The UK gambling industry is economically and
socially important with 170,000 people employed, directly or indirectly,
paying income tax and national insurance contributions. In 1998
£1.4 billion was generated in betting duty, excluding substantial
amounts of corporation tax. It provides harmless enjoyment to
millions with minimal problems. Within sensible bounds it should
be facilitated.
Sports such as football and horse racing have
benefited greatly from levies, donations and sponsorship from
the gambling industry.
The industry is the envy of the world with well-regulated
and competitive companies, recognised for their probity.
Although the regulatory environment has proved
highly successful in creating a crime-free environment, the body
of related law has developed in a piece-meal way. As a consequence,
gambling is now governed by a series of separate and inconsistent
Acts, which results in the various products offered competing
unequally.
The gambling industry is well placed to capitalise
on the development of e-commerce, as encouraged by the Government,
but only if it is allowed to compete fairly with off-shore operators
enjoying environments with low or no taxation. If this happens,
the UK will benefit from increased exports and inward investment,
being seen as a world leader in an evolving medium.
It is impossible to consider gambling in the
UK without reference to and comparison with the National Lottery.
It dominates the market and has significantly and permanently
changed the public's attitude to gambling.
Key Proposals
There should be one regulatory body to oversee
the industry in a fair and consistent manner. This will protect
the consumer, keep crime away from gambling and provide the conditions
for a truly competitive market.
Legislation, which in the main is 30 years old,
should be brought up-to-date and consolidated into a single Act
of Parliament, thus standardising the industry to the benefit
of consumers and operators. The law should concentrate on product
categories rather than sales channels.
It is now appropriate that the varying rates
of betting duty should be harmonised. This will enable the consumer
to have genuine choice of product and remove inconsistencies in
the current system.
All sport should benefit from gambling activity
based on it, whether that benefit is defined as a levy, copyright
or "grass-roots" funding. A single rate should apply
across the board, internationally. That rate cannot exceed 1 per
cent of turnover if UK operators are to compete with offshore
operators paying little or no tax or levies.
All forms of legal and licensed gambling should
have access to all advertising media, within appropriately modified
guidelines concerning product depiction.
A hierarchy of graded licences is desirable,
provided all levels of application involve the same criteria on
probity. Gaming products should be approved for operation in specific
types of outlet. For example, the highest grade of licence should
allow an operator to run a "one stop" outlet, offering
all forms of gambling.
Football pools should be allowed the same unlimited
rollover facility as the Tote and be given the same retail conditions
as the National Lottery, which would allow it to pay-out small
winnings in the outlet and operate online.
Society lottery scratchcards, both paper and
screen based, should not be limited as to prize fund percentage
or purchase price. They should not be subject to rules on method
of sales, provided age restrictions are rigorously enforced. It
should be left to the charity or lottery manager, who are both
checked for probity, to establish whatever allocation of stake
they deem appropriate.
Prizes and stakes on gaming machines should
be determined by market demand. For the benefit of consumer convenience,
payment to play would be de-restricted, and the direct replaying
of winnings permitted.
Bookmaking products should be available in pubs
and other adult orientated leisure outlets. In practical terms,
such activity will probably extend only to pari-mutuel or limited
stake fixed odds wagering.
Competitions requiring an entry fee should be
re-categorised as gambling and be controlled as such.
Littlewoods Leisure's vision for the UK gambling
market is based on government control which establishes from time
to time the products which are permitted and through which premises
or channels they can be delivered. Market forces should then be
left to determine the operational detail of the product offer.
A truly competitive environment will only be created when inconsistent
restrictions are replaced by a robust and uniformly applied framework
within which the industry can meet public demand.
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