Select Committee on Culture, Media and Sport Memoranda


Memorandum submitted by Six Continents Retail Limited


  Six Continents Retail Limited interests include 2,000 managed pubs and bars and 22 ten-pin bowling sites in the UK. The company has 4,000 all-cash AWP machines sited plus a further 200 other gaming machine products such as cranes and pushers.

  Gaming machines are important to us in terms of the entertainment they provide to customers and in their valuable contribution to company profits.

  We are aware of numerous demands for wide-ranging change in the UK gambling laws from industry, the Gaming Board of Great Britain and others. We believe the main impact of the proposals on the leisure industry in the UK will arise from the changes to machine legislation.

  The proposals, as currently written, would enable a proliferation of gaming machines in casinos, betting offices and bingo; whilst being unduly and unfairly restrictive on pubs. We believe that casinos would become essentially arcades with gaming tables merely being used to legitimise such arcades. Furthermore we are concerned that there could be a proliferation of casinos and bingo in the UK, not because of table games and bingo but because of the opportunity to site machines; a case of primary purpose being pushed to breaking point. It is likely that the UK casino model will rely on machines for between 50 per cent and 97 per cent of income, as is the case in Las Vegas and France. Bingo would benefit not only from £500 and £25 jackpot machines and liberalisation of bingo prizes, but also from an elimination of the 24 hour membership rule. This means that bingo will no longer be a "club", other than by name, and will be able to offer everything that a pub can offer to the general public and more. Clubs will have the same offer as pubs, except for an advantage in respect of machines with £250 jackpot machines.

  We are not objecting to the liberalisation in other retailing sectors and the likely proliferation of machines per se that this will cause, however, we do believe pubs under the current proposals are being handed an unfair position.

  Machines have been in most of the 60,000 pubs in the UK for over 30 years without issue or public concern, a remarkable achievement in our opinion and a tribute to the well controlled, essentially adult, environment. Pubs employ 650,000 people and our own organisation in excess of 40,000 people. Machines throughout the UK are an important contributor to profit and pubs also provide the third largest proceeds from gaming to the Treasury.

  Of the 0.6 per cent to 0.8 per cent of the UK adult population that are problem gamblers approximately 2.5 per cent relate to fruit machines in pubs, hardly cause for the harsh treatment of pubs relative to other sectors.

  We believe that the above facts serve to briefly highlight the issues arising from the proposals in respect of pubs.


  We are grateful to the DCMS for the decision to allow reviews of stakes and prizes in the future based on all the available information, rather than solely inflationary increases; as well as the proposal that Local Authorities would have discretion to allow more machines in appropriate cases.

  However, we have serious concerns with the current proposals which are covered below.

Protecting the Young and Vulnerable

  It is proposed that machines be sited in "effectively controlled and clearly identified areas" in both pubs and clubs. We agree with the essence of this proposal, but have the considered view that it would be best delivered by good management control and appropriate notices. We would definitely not want to have to introduce physical barriers in the form of walls, screens, ropes or lines on carpets that would introduce needless cost and lead to the removal of machines for no good reason and ultimately not assist in controlling risk. A pub or club would have to control the risk to the young and vulnerable to maintain the siting of these machines by law, and that in itself provides sufficient deterrent without the introduction of inappropriate measures in an already well controlled environment. Gamcare indicated in a recent Gambling Conference that it agrees with the approach advocated by pubs. There would also need to be firm national guidance to ensure consistency of approach by Local Authorities and to avoid making an industry of this matter through red-tape as well as the removal of machines for no good reason.

  We believe the good liaison work being carried out by the officials of the DCMS should be able to produce a workable solution, but we wish to emphasise the importance of achieving progress in this area of concern.

Machine Numbers in Pubs and other Licensed Premises

  It is proposed that pubs be allowed 2 x £25 machines with Local Authority discretion to allow more in appropriate cases. This is compared to 3 x £250 machines for clubs, 4 x £500 machines, plus numerous £25 machines in bingo halls. This proposal would mean removing existing rights in 11,000 pubs, all of which have already been approved by Licensing Magistrates, as well as providing no cause for concern. The industry seeks 4 machines as of right with more on application. In recent years Magistrates have taken a more consistent attitude to the numbers of machines they will Permit and allowed additional without this leading to a proliferation of machines. We believe that applications for more than 2 x £25 machines as proposed should not be unduly onerous, and certainly be no more difficult than the current process. In essence we wish to reduce bureaucracy with our proposal, and seek something that we believe already exists in practice. We have considered using size of premises related to numbers of machines to produce a simple formula, however we have rejected this as inappropriate since it would not take account of the nature of a particular pub. Our analysis indicates there is not a direct correlation between size of premises and numbers of machines because of the varied trading styles between different pubs. The common factor is that all these pubs are well controlled environments with permission from Magistrates to carry on their lawful business.

Machine Maximum Stakes and Prizes

  Pubs welcomed the introduction of a new £25 prize level on 1st January 2002. It should also be noted that this level, which is very low compared to the proposals for other sectors, was sought by the pub industry as part of a longer term vision of £50 in January 2004. In the last 10 years there has been an increase in the maximum prize from £4.80 tokens to £25 cash, whilst a low level of gambling prevalence was assessed in 2000 by the Gambling Prevalence Study when the prize was £15 (since then we have nothing to suggest an increase in problems). The £25 prize level is very modest compared to clubs and bingo halls which will under the current proposals be offering virtually the same, if not the same, products as pubs.

  Pubs seek a level playing field in any new legislation, not competitive advantage.

"Cranes" and "Pushers"

  Six Continents has 22 ten-pin bowling sites that trade under the brand name Hollywood Bowl ,with two more sites scheduled to open later this year. "Cranes" and "pushers" in these sites have provided entertainment for many years along with all-cash AWP machines and AWP machines. All these machine types are very well managed in Hollywood Bowl and we choose to operate "controlled" areas through various good management methods.

  In "A Safe Bet for Success" it is implied that if "pushers" have more than one coin-slot for play (eg a hexagonal machine with separate play positions around it) then each play position will be a separate machine; which clearly it is not and never has been. We would request that DCMS re-consider this proposal.

  Furthermore "cranes" are proposed to be restricted to 10p stake and £5 prize which fails to reflect the nature of the product and the fact that a prize, as opposed to cash, can be won. "Cranes", which we currently operate on a 25p stake and maximum £5 prize, may to many be a detail, but are nevertheless an important aspect of our Hollywood Bowl business. We propose that this machine type, which the Gambling Review proposed to take out of the control net altogether, be controlled with a maximum 25p stake and £5 prize with reviews from time to time.

  These seemingly minor changes in respect of the proposals for "pushers" and "cranes" are important to our business.


  Six Continents Retail believes that very careful consideration of the impacts of the proposals needs to occur, along with subsequent detailed implementation plans, so as to avoid adverse unforeseen consequences.

  We believe the DCMS is engaged in a professional process that we hope will resolve the legitimate concerns expressed on behalf of pubs.

  We would be very pleased to assist in providing further evidence to the Committee.

3 May 2002

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