APPENDIX 13
Supplementary memorandum submitted by the British Casino Association
Thank you for your letter inviting further comments. I will, if I may, take questions 3 and 5 at the end of this letter as they are actually directed to me as Chairman of the Gambling Industry Charitable Trust.
1. In your evidence to the Committee, you stated that the changes to the industry will be "customer led". On what evidence does the British Casino Association base its statement that its customers wish to play what you describe as modern gaming machines ie casino slots? If the Casino Association knows of a survey showing customer expectations, please could you give the Committee details?
2. The evidence from elsewhere suggests that the introduction of casino slots create a new player base separate from those who play table games. Surely what you are really saying is that you want to introduce slots because worldwide these are found to be extremely profitable from the operators' point of view, rather than a response to customers' wishes?
1 & 2 together As you rightly point out, there will be a new audience for the casino offerings as well as a widening of choice for the existing customers.
Operators speak to customers on a daily basis who complain that UK machines lack the features of machines readily available elsewhere in the world. Of course, people still play the machines, in the same way that people will watch black and white television if nothing else is available. The fact that only 1 per cent of our business comes from slot machines when the percentage in France is 85 per cent is revealing and is an indicator of just how archaic is the UK gaming industry.
We do not believe that the experience elsewhere in the world is transferable as an un-amended model to the UK market. We believe that the kind of slot machines casino customers want should only be available in controlled adult environments, like casinos. No doubt some new customers will be attracted to the machines. Some table games customers, who do not enjoy the current machines, would be interested in playing the new style machines.
3. Does the British Casino Association consider that Camelot should contribute towards the Industry Trust?
As one of many members of the Gambling Industry Charitable Trust, the BCA hopes as many organisations will contribute to the Trust as possible. The BCA understands Camelot's view that as long as it is controlled by its own regulator, it will inevitably continue to give to GamCare and others along the lines directed by the Lottery Commission. For information "the age profile of GamCare's clients (through the Breakeven Project) includes 10 per cent of people aged under 18 and a further 23 per cent aged 18-25 and 36 per cent of callers to the Helpline were under 25".
4. The British Casino Association mentions the measures they insist on their members operating, such as leaflets and assistance for problem gamblers, and promoting self-barring schemes. In reality, how successful are these measures in helping problem gamblers, and how visible are they to the public? In a UK casino visited recently by the Committee, whilst on display, the leaflets were placed in corners of the casino rather than prominent places—is this usual practice? How many casinos have customers who have requested to be self-barred?
About eight per cent of all callers to the GamCare Helpline received information about GamCare's facilities through either leaflets or advice provided by casino staff. People who attend casinos regularly, rather than on the kind of one off visit the Committee members of necessity would have conducted, would be repeatedly exposed to the material. Given the relative prevalence of casinos as the cause of problems, the provision of leaflets and information is reasonably effective. That said, we believe the extensive use of usual channels of information, eg the Yellow Pages and the telephone directory, is to a degree indicative that additional people have been made aware of what to look for by the information provided in casinos and elsewhere, but who have not picked up leaflets. Admitting to oneself that you have a problem with gambling is difficult. Picking up a leaflet, perhaps when you have just lost more than you can afford, from a prominent public position in a casino may be a step too far for most people. That said, we are happy to continue to promote the help agencies in the way they and we jointly believe to be the most effective. Self-barring is effective for some of those who are very severely affected and who want help to avoid temptation. Others, who do not feel this strength of compulsion, can take advantage of our status as members clubs and cancel their membership or simply stop coming. Accurate numbers involved in self-barring are not available within the time scale of this response.
5. How many BCA members train their staff to recognise, and offer help to problem gamblers?
This varies between members and is currently the subject of a substantial piece of work by the BCA, in defining a policy statement and some practical supporting material, which is the subject of consultation with agencies, including GamCare. However, again as clubs, we do have strong relationships with our client base, relationships which grow stronger at the higher end of the market. It is therefore possible for managers to speak to customers whom they come to know and whose behaviour changes or otherwise gives cause for concern. This is the usual way advice is proffered. Identifying problem gamblers is difficult; not impossible but difficult. Research and experience indicate that often a degree of co-morbidity exists, in that problem gambling is one symptom, often found alongside others, like excessive drinking or drug abuse, which are together indicative of some complex underlying condition for which an individual may or may not want help.
6. Does the BCA see the Government's proposals resulting in a large number of small casinos or a small number of large resort style casinos? Should there be a minimum size of casino enforced by legislation?
The BCA does not believe that it would be desirable for a very large number of small casinos to result from the new Act. The proliferation of literally hundreds of small casinos offering few, if any, non gaming facilities was clearly not what Budd intended to be the result of the review. Our view is that the regulation of an industry of this nature would be inherently difficult and therefore dangerous to the overall excellent reputation of the casino gaming industry. It is equally clear to us that there is not the capacity in the UK for more than a very limited number of "resort-style" casinos of the style proposed for Blackpool. And here there may be an issue of perception and definition, because our view is that there should and will be growth in the number of casinos but they will comply with a minimum size and offer a mixture of facilities, including all forms of adult gambling products, machines and table games, as well as other facilities like perhaps entertainment and restaurants. These new casinos will be mainstream adult leisure venues.
7. How should the Government decide on the maximum number of slot machines per casino?
The BCA takes the view that the Government should limit the number of slot machines but setting a formula for the minimum ratio could be, as Budd proposed, eight machines per table, but allowing a local authority to increase but not decrease the ratio if so desired.
The exact numbers within the formula will need to depend on a number of factors eg whether electronic games which are currently regulated as table games under Bankers rules, will continue to be treated as such or as machines.
8. You state in your memorandum that the minimum age limit for entry into casinos should remain at 18. Does the BCA have a view on the gambling of children on AWP machines? Is gambling an activity that ought to be restricted to adults only?
The BCA strongly feel that access to adult gaming machines should be tightly restricted to over 18s as in casinos.
9. Casino slots and poker machines found in casinos in other jurisdictions have a much more rapid play sequence and shorter game period than the style of gaming machine that has developed and evolved for the UK market. Please explain how your "modern machines" can uniquely incorporate programmes to reduce the risk of problem gambling and provide "abundant" information upon which research can be based into the social impact of increased numbers of gaming machine, which cannot be introduced into all gaming machines?
We only partially agree with the statement that casino slots and poker machines found in casinos in other jurisdictions have a much more rapid play sequence and shorter game period. Certainly many machines in other jurisdictions do, but not all of them. That said, we accept the underlying point and understand the concerns that the committee identifies. With modern electronic machines, like the win percentage, the rate of play can be adjusted and controlled by the operator within regulatory constraints. However, if someone wants to play faster, they will play more than one machine at a time, so controls beyond a sensible limit are frustrating and self-defeating. Modern machines (of the kind available outside the UK) are all based on powerful microprocessors that are designed to provide the operator with marketing information. This information can just as well be used to research the amount of time spent playing by individuals and playing patterns. If linked to player tracking technology, it can even be used to research the age, gender, ethnicity and demographic distribution of the players. Machines can also be programmed to remind players how long they have been playing, encourage players to take a break or give advice on problem gambling. This technology is not available on the converted AWP machines that currently form the basis of the majority of machines available to the UK market.
GAMBLING INDUSTRY CHARITABLE TRUST
10. Although the British Casino Association appears to have a good record so far in ensuring that each of its members contribute to the Industry Charitable Trust, the Committee heard evidence from BACTA that only 25 out of 690 of its members contributed. Will the voluntary contributions to the trust be equitable, fair and will they reach the target set by the Government of £3 million?
The Trust is currently in the process of a major piece of research work, wholly independent of the Trust, which will, inter alia, look at the target of £3 million and examine the current and future needs. The required sum could be more or it could be less.
It is impossible to give guarantees on sums to be raised but encouragement should come from the existing sum raised in a very short time. The trustees and contributors are currently looking at different formulas for contributions from the industry for the future.
Establishing equity and fairness is never going to be as easy in a completely voluntary system as compared with a mechanism that has some statutory power. However, the Government has the ability to ensure that the continuing licence of any gaming establishment/operator is in part dependent on the adherence by the operator to some agreed form of social responsibility package. That package could include an assessment/declaration of the contributions made by an operator to the independent charitable trust. So far BCA members have provided 48 per cent funding to the Trust when its contribution to the problem could, on GamCare's latest statistics, be said to be about eight per cent of all gambling activities. One hundred per cent of the membership of the BCA contribute to the Trust.
11. How much is the industry willing to contribute towards research and treatment? What should the figure be per problem gambler—eg in New Zealand the figure is £44, Canada £40, Australia £26?
The industry should contribute appropriately to the problem. Simply superimposing a model in its entirety is not the answer. Indeed experiences from other jurisdictions should continue to inform debate. The services provided around the world vary substantially. We believe that the right way forward is for the GICT to listen and assess bids, with expert advice, from the service providers and ensure that it has sufficient funds to meet those needs. Simply picking a figure and multiplying it by some assessment of the number of "problem gamblers" based on extrapolated figures is unhelpful.
The consultancy mentioned above in 3, will be looking at figures from overseas but will also be examining the effectiveness of treatments offered as a consequence of the money spent.
25 June 2002
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