Memorandum submitted by Coral Eurobet
Coral Eurobet are pleased to provide written
evidence to the Culture, Media and Sport Committee of the House
of Commons, relating to the proposed changes to gambling legislation"A
safe bet for success".
Coral Eurobet support the principles of the
To simplify the regulation of gambling.
To extend choice for adult gamblers.
To ensure that gambling is conducted
honestly and the Industry is crime free.
To ensure that consumers are protected.
To ensure that there is protection
for children and the vulnerable.
Our response will cover the issues which specifically
concern the changes to regulation of gaming machines, the casino
industry and the potential impact of the Government's proposals
on the National Lottery. In addition we would wish to take the
opportunity to comment on certain areas that impact, in a broader
sense, beyond the Committee's initial terms of reference.
You will have received a detailed response from
the Betting Office Licensees Association (BOLA). Coral Eurobet
endorse the comments contained within BOLA's submission.
Coral Eurobet welcomes the Government's proposal
to permit betting shops to site a mixture of four all-cash and
We support BOLA's comments in that the introduction
of jackpot machines into betting shops is long overdue. Given
that recent deregulation has allowed bingo clubs to mix all cash
and jackpot machines, Coral Eurobet believe that the proposed
jackpot machines should be introduced through secondary legislation
as soon as possible.
In our view the above action would not disturb
the balance of the gaming machine regime outlined in the Government's
Coral Eurobet welcomes the Government's confirmation
that the "Gaming MachinesMethods of Payment"
proposals contained in the Home Office Consultation Paper (published
March, 2001), is to be progressed over the coming months. Clarification
of the exact timetable would be most welcome.
However, there is one element of the gaming
machine proposals that gives us cause for major concern. Paragraph
4.22, referring to Fixed Odds Betting Terminals, states an intention
to draft new legislation in such a way that betting terminals
are controlled in the same way as gaming machines, eg outside
of casinos, the prize limit for gaming machines will be £500.
In our case the Fixed Odds Betting Terminal is simply an alternative
to the manual process of placing a bet with a cashier. Our current
limit on winnings ranges up to £500k, dependent on the product.
If the proposal is implemented as drawn this
will result in a significant reduction in consumer choice, whilst
the impact on innovation and development within the Industry would
be stultifying with a "ripple" effect on manufacturers,suppliers
and software designers.
Coral Eurobet views the proposal as a retrograde
step for betting shops.
Betting shops have been legally accepting bets
on the outcome of random numbers events since 1996.
Automated betting terminals (often described
as fixed odds betting terminals) were introduced into Coral shops
Significant investment from bookmakers and suppliers
has been made after having taken legal advice and having consulted
with the Gaming Board in 1999.
There are now some 2,500 of these terminals
sited in betting shops throughout the UK.
This product range is now an integral part of
our business and is responsible for a significant portion of bookmakers
profits, as well as providing income streams and employment for
terminal suppliers and software developers.
The Government, in October 2001, introduced
a new tax regime for betting (Gross Profit Tax). The new regime
was introduced in order to give UK business the ability to compete
globally, thereby "growing the cake"of which
the Government has a 15 per cent take. Paragraph 4.22 is a threat
to the Government's future income, as well as the industry's future
The above are matters that we expect to discuss
further with DCMS in the near future and one upon which we would
want to make further representations as things become clearer.
This is not a specialist area for Coral Eurobet,
therefore we have not commented beyond the fact that we support
the Government's principle of extending choice to adult gamblers
in well regulated environments.
Coral Eurobet support the measures outlined
in the Government's proposals.
Coral Eurobet have made a significant, voluntary
contribution to the Gambling Trust and will continue to support
the efforts of organisations such as Gamcare and Gordon House.
Coral Eurobet support the comments made in BOLA's
submission in that there is little or no evidence to suppose that
the proposed deregulation will adversely affect the National Lottery.
However, evidence is available regarding the
impact on the Irish Lottery following the introduction of side
betting in Irish betting shops.
This evidence, conducted by Mori and Europe
Economics, has been supplied to the Committee by BOLA and demonstrates
that National Lotteries and side betting can compliment one another,
rather than pose a threat to each other.
Given the original terms of reference of the
Gambling Review Body, namely:
Extending adult choice.
Keeping gambling crime free.
Protection for children/vulnerable
Coral Eurobet is disappointed and surprised
that side betting on the National Lottery was rejected by the
Side betting on the National Lottery already
takes place in offices, factories and other venues. This activity
is currently relatively harmless, (eg the school fund raising
event having a sweep on the outcome of the bonus ball).
In our view, it is absurd that well regulated,
licensed betting shops are not allowed to take side bets when
there is such an obvious demand and that demand is currently being
met illegally, and with no gross profit tax payments going to
Gambling Commissiona single regulatory
body has appeal on the grounds of neatness. However, we feel that
the diversity of gambling is such that there would be a danger
of the Commission becoming unwieldy, resulting in an expensive,
The range of powers afforded to the Commission
appear limitless, therefore we would wish to seek further clarification
on this issue as the proposals are progressed.
Licensing of Individualswe strongly
support rigorous licensing procedures. We support a more demanding
"fit and proper" criteria which might include criminal
record checks, financial checks and testing for knowledge and
competence at Senior Executive level.
We do believe that individual licensing should
not extend to the industry's 15,000 Shop Managers, who are essentially
processors or retailers of betting transactions and we are pleased
that the issue is to be further reviewed.
Licensing of Premiseswe are unable
to see the advantages of the proposal over that which currently
exists. The existing system, operating through the Magistrates
Courts, functions effectively and is conducted in an environment
where all interested parties, including the public can attend
and make their views known.
The proposal that it be dealt with by the Local
Authorities as an administrative process, in circumstances where
they are already hard pressed to meet all their current statutory
requirements, seems to add little to efficiency or local democracy.
Demand Criteriawe understand that
it is the Government's intention to produce national criteria
to provide clear guidelines for Local Authorities.
We remain of the view that those criteria should
have some regard to current provision.
We also believe that the process should be more
rigorous, in as much as applications should be supported by:
Evidence of some holding interest
in the property.
Evidence of resource to complete
Applicant should already be Licensed
as "fit and proper."
Coral would be pleased to assist in helping
to establish the new national criteria.
Opening Hoursthe Gambling Review
provides an opportunity to remove a current anomaly with regards
to betting shop opening hours.
Betting shops are able to open from 7.30 am
until 10.00 pm in the summer months6.30 pm closing is compulsory
in the winter months.
Given the continuing globalisation of sport
and the increase in winter televised sport, including horseracing
after 6.30 pm, it seems appropriate to allow the opening hours
to be extended, during the winter months, where there is demand
for the facility.
StadiaCoral Eurobet own two greyhound
stadia (Romford and Hove) and would welcome the opportunity to
assist in the development of guidelines for gaming machine licensing
Operating as a gambling venue, our view is that
greyhound stadia should be afforded the same entitlement as other
gambling venues,(eg bingo where a mixture of all cash machines
and four jackpot machines can be sited).
Coral also welcomes the Government's suggestion
that greyhound stadia should be considered as appropriate venues
for casinos. In addition, we are pleased that further consultation
is to take place as to how future licensing arrangements can allow
operators of greyhound tracks to make more efficient use of their
facilities on non-race days.
Coral similarly supports off-course access to
greyhound totalisators and the removal of the rules restricting
charges for the entry of bookmakers to greyhound tracks.
3 May 2002