Memorandum submitted by Littlewoods Leisure
On behalf of Littlewoods Leisure I would like to submit the following evidence to the Culture, Media and Sport Committee's inquiry into gambling.
Littlewoods Leisure generally welcomes the Government's proposals. Many of the ideas included in the evidence which we submitted to Sir Alan Budd's Review Body were accepted by it, and subsequently also by the Government.
As we are not involved in gaming machine or land-based casino operation, we will confine our responses to the following terms of reference:
the prevention of criminal infiltration of gambling;
the social impact of the changes proposed and the safeguarding of the young and otherwise vulnerable; and
the potential impact on National Lottery of increased competition following the deregulation of casinos, bingo, pool competitions and society lotteries.
Both the Review Body and the Government have been highly conscious of the risk of criminal infiltration of gambling. One of the great and abiding successes of the regime introduced by the 1968 Act in particular is a "clean" environment, which is the envy of jurisdictions across the globe. The Government's response succeeds in retaining the safeguards which currently exist whilst encouraging a more obviously commercial environment to flourish.
The only, but significant, point of concern is the lack of clear proposals at this stage regarding the Internet. The overall safeguards will be as strong as their weakest link. We note that the DCMS and the Gaming Board for Great Britain have been examining methods of controlling Internet gambling, and the Gaming Board is to publish them this month. It is essential that legislation in this area, which has proved thorny for many jurisdictions, is well-thought-out, but also that it is introduced speedily. As it closes a loophole it will introduce an opportunity to tax!
Social Impact and Safeguards
The social impact of the changes will be positive. They provide a classic example of legislation's tendency to move to reflect the mores of the day. Many have quoted statistics, quantitative and qualitative, on prevalence and attitudes which support this. Again, both the Review Body and the Government have taken great care to ensure that the young and vulnerable are protected.
As regards the former, the principal area of concern for the Government is that of Gaming Machines. Their proposals appear inconsistent in attempting to distinguish between members' clubs and licensed premises such as pubs, and imposing significantly stricter restrictions on the latter as opposed to the former. In most people's experience, minors are no more prevalent in one than the other. At the same time, gaming machines will be allowed in cafe«s and take-away food outlets, Local Authorities permitting, where minors can congregate. A clearer and more consistent approach should be found.
The Government has rightly been at pains to protect those for whom gambling is or can become a problem. We believe that those involved in the industry have an obligation to help individuals adversely affected in this way. To that end, we were one of the original contributors to the Gambling Industry Charitable Trust. Should the Government choose legally to require such contributions to be made, it would be essential, albeit not easy, to ensure that the activities which cause more problems contribute accordingly.
Impact on the National Lottery
Camelot made much of the adverse impact on National Lottery proceeds which the Review Body's recommendations would have, in their view. In company with the rest of the gambling industry, we thought that they had grossly overstated that impact, and told the Government so. It was refreshing, therefore, to see that most of the recommendations Camelot objected to were retained by the Government.
Taking bets on the outcome of the lottery was not retained, although the Government was presumably aware of the advent of Hot Picks, Camelot's equivalent of a fixed odds bet on their own main draw. It is disappointing, but not unexpected, that the Government has chosen to deny the private sector an opportunity which Camelot is then allowed to grasp. We note that the CMS Select Committee itself recommended that betting on the outcome of the lottery should be permitted, in its report on the Operation of the National Lottery.
It is difficult to see how any of the recommendations on pools could lead to a migration back to that product from the National Lottery. The horrendously adverse impact was suffered too long ago. The proposals will ease certain operational issues, however, and allow more flexibility in the type of games offered.
It is a disappointment that the Government did not think it appropriate to accept the Review Body's recommendation to remove the limits on the size of and prizes available from Society Lotteries. For Camelot to claim that the recommendation would significantly damage its sales was disingenuous and mischievous. Society Lottery sales in 2000-01 equated to just over 2 per cent of National Lottery turnover. Any growth resulting from the removal of the limits wouldn't alter the immaterial nature of the impact on Camelot's sales.
We are very grateful however, to the Government for their proposal to raise those limits, hopefully quickly via statutory instrument. Such a move would be greatly welcomed.
Should the Committee require any further evidence, or clarification of that submitted, we would be delighted to provide it.
3 May 2002