House of Commons - Culture, Media and Sport

Select Committee on Culture, Media and Sport Fifth Report

4 LICENSING AND REGULATION

The National Lottery Commission (NLC)

48. In April 1999 Oflot was replaced by the National Lottery Commission (NLC). The Commission is made up of five Commissioners: Ms Moira Black CBE, Mr Brian Pomeroy, Ms Harriet Spicer, Mr Timothy Hornsby, Ms Jo Valentine. The Commissioners, at present, appoint their own Chair, currently Ms Moira Black CBE, for a period of 12 months at a time, they also appoint a Chief Executive, currently Mr Mark Harris. The Commissioners have all been selected by the Secretary of State for Culture, Media and Sport, who is also responsible for directing the Commission in the exercise of its functions under the powers of the 1993 Act.

49. The formal statutory duties of the Commission are to protect players of the National Lottery, to ensure the Lottery is run and promoted with due propriety, and, with that in mind, also to maximise returns to good causes. The Commission, at present, must also: award one Section 5 licence to the chosen private sector operator and any accompanying Section 6 licences required for individual games; enforce the conditions of licences that have been granted; and impose fines where serious breaches occur or revoke a licence if it sees fit. The Commission is accountable to Parliament through the publication of its annual report.[45]

50. The NLC also is responsible for ensuring that the National Lottery has the best possible private sector operator. In order to do this the NLC must ensure that there is sufficient competition for the licence so that favourable licence conditions can be negotiated and the chosen operator will maximise returns to good causes without taking excessive risks.

51. As the regulator of the Lottery, the NLC is responsible for ensuring that the operator adheres to all the licence conditions and the obligations it has signed up to. In order to police this, the NLC has a compliance division which carries out checks on Camelot's everyday work: the transfer of funds to winners and the NLDF; the Lottery draws; the performance, reliability, efficiency and security of Lottery equipment and technology; and compliance with marketing and advertising agreements. The Commission also monitors breaches of the code and performance against 'regulatory imperatives' that the NLC has developed.

52. The NLC has responsibility for making sure that the operator is doing everything in its power to maximise sales of National Lottery tickets and running the Lottery in a way that maximises returns to good causes (without jeopardising player protection or the propriety of the game). This is the critical feature and the reason National Lottery regulation is separate from the rest of the gambling sector. Sales of National Lottery products peaked in 1998-99, with total revenue of £5,228 million. But from that point until very recently sales have steadily fallen, with total revenue in 2002-03 of £4,574.5 million. However, Camelot announced on 13 February 2004 that headline sales for the third quarter of the financial year were £1.1 billion, equalling figures for the last two quarters, suggesting that the long term decline in sales had been halted.[46] Some research has been done across international lotteries and it indicates that the National Lottery is experiencing natural player fatigue.[47] However, the NLC told the Committee that it believed that not only could sales be stabilised but they could also be grown.[48] Mr Mark Harris, Chief Executive of the NLC, told us that growth could be achieved through a number of routes:

53. This is the case both now and looking into the future of the National Lottery. There is a clear distinction between the role of the operator (responsible for the management of the games and with incentives to maximise sales) and the role of the NLC (tasked with making sure that it selects the best operator and that the operator properly carries out its responsibilities and meets its obligations).

Camelot

54. Camelot is the current private sector operator of the National Lottery and has been since it was awarded the first seven year Section 5 licence in 1994. This is accompanied by a number of Section 6 licences which are necessary to run each individual games of which include: the National Lottery Game (Lotto), Thunderball, Lottery Extra, Christmas Millionaire Maker, Scratchcards, Hotpicks, Easyplay, Euromillions. Other companies are able to hold Section 6 licences but only with the assent of the main licence holder. Camelot currently hold all 50 Section 6 licences.

55. Camelot has more specific roles and responsibilities as the main licence holder and these include: managing game design; stopping underage and illegal play; discouraging excessive play; providing player services and information; providing winner services; providing security; protecting the integrity of the games; and social reporting on a yearly basis.[50] As discussed above, the NLC is responsible for regulating the licence conditions and ensuring that standards are maintained in all these areas.

56. Under the current licence Camelot also has a number of more specific conditions to adhere to and Ms Diane Thompson, Chief Executive of Camelot, told us that Camelot shareholders have committed to invest £1 billion in the National Lottery over the present licence period, as well as a specific minimum marketing spend for each of the seven years from 2002 to 2009.[51]

Regulation

57. The NLC is currently responsible for carrying out the regulation of the National Lottery. As outlined above, the role of the NLC as the regulator of the National Lottery is to check the performance of the operator and to enforce the conditions of the licence under its statutory duties (protecting players, ensuring propriety and maximising returns to good causes).

58. The Government's proposals to keep the regulation of the National Lottery under the NLC are likely to come under pressure from two angles. Firstly, the deregulation of the gambling sector has led to calls for the Lottery to be regulated with the rest of the sector by the Gambling Commission (proposed under the draft Gambling Bill). The Gaming Board argue:

"the Gambling Commission could police and monitor all gambling operations, including the National Lottery. The Commission could also play a major part in the periodic competitions for licence(s) by investigating and vetting the competing bidders. But the NLC's current duty to maximise returns for good causes would need to be modified to bring it into line with Clause 14(b) of the draft Gambling Bill. And there is a case for a separate, time limited, body or committee to be established when necessary to invite bids, decide between them and appoint the operator(s) of the National Lottery."[

59. However, the NLC and others (including the National Council for Voluntary Organisations (NCVO), Camelot and The People's Lottery) recognise a potential conflict of interests due to the statutory duty of the regulator of the National Lottery to maximise the returns to good causes and they agree with the Government that the regulation of the National Lottery should be separate from the rest of the gambling industry.[53] The Lotteries Council agrees in principle but also argue that other society lotteries (such as those they represent) should also be regulated by the NLC in recognition of the fact that they also generate returns for good causes.[54]

60. The Government told the Committee that it appreciates the argument for amalgamation of all gambling activities under one regulator but has decided to keep separate the regulation of the National Lottery from the rest of the gambling sector. Responsibility for regulation will remain part of the role of the NLC rather than being transferred to the proposed Gambling Commission. This is because regulation of a "very different nature" is required for the National Lottery as the NLC is under statutory duty to maximise return to good causes.[55]

61. However, DCMS does envisage a role for NLC within the Gambling Commission, with a NLC holding a seat on the Commission so that it takes proper account of the effects on the National Lottery of any regulatory developments in the gambling sector.[56]

62. We believe that due to the unique and proper responsibility of the National Lottery Commission (NLC) to maximise returns to good causes, the regulation of the National Lottery should remain the responsibility of the NLC.

63. We agree that a representative from the NLC should have a seat on the proposed Gambling Commission proposed within the draft Gambling Bill.

Licensing at present: single licence system

64. The present single licence system is made up of one Section 5 licence to run the Lottery with additional Section 6 licences for each game under that main licence. After experience had been gained from the first licence period and the difficulties of the second licence competition, many additions and changes were made to the second licence and to the conditions the operator had to adhere to. In light of this, the key characteristics of the present licence are:

About 28% of sales are expected to go to the NLDF (National Lottery Distribution Fund). At sales of £5 billion per year over seven years, good causes would receive around £10bn (around 28% of revenue), plus interest. This is much the same as under the first licence (1994-2001), despite the challenges posed by player familiarity, increasing competition and the impact of new technology.

A new incentive system links Camelot's return from the Lottery to the amount it raises for good causes. If the operator's profits exceed the level it forecast in its bid, half of the balance above this will go to good causes as a "secondary contribution".

An extended minimum marketing commitment now applies to every year of the licence, instead of just the last 2¹/₂ years, helping to keep the Lottery attractive and properly promoted. Marketing expenditure planned for the second licence period is significantly greater than the amount spent in the first.

There are financial penalties if Lottery IT systems fail on start-up, and these are intended to act as a safety net to compensate good causes for any resulting loss.

For 2002-2009, the share of prizes is expected to be closer to 50% than for 1994-2001 (48%). International experience suggests this helps to sustain sales. The Commission has required Camelot to consult players regularly and take account of their views in developing player information and other services.

The Commission has powers to set performance targets on which Camelot must report monthly, as well as performance standards which it must meet. Camelot is required to develop and implement strategies - to be approved by the Commission - to prevent under-age and excessive play.

Camelot must conduct not less than 10,000 under-16 tests a year (roughly two per retailer during the licence), with the Commission able to increase that number if it can show grounds. This doubles the previous number of tests.[57]

65. There are extended provisions for propriety, and tougher powers for the regulator, such as:

ii) requiring independent testing of any software process at the contractor's expense;

iii) requiring Camelot to have code of conduct and whistle-blowing procedures approved by the Commission, with requirement to make employees and contractors aware of licence obligations;

iv) a new explicit requirement for Camelot to provide immediate reports on incidents that might reasonably be expected adversely to affect the proper running, regulation or image of the National Lottery;

v) reporting requirements widened to include any fraud affecting the licensee, whether or not the National Lottery is involved.

66. The Commission does not have a day-to-day role in respect of retailers, but the new licence includes provisions ensuring that:

ii) retailers' commission cannot be reduced without NLC permission;

iii) in order to deliver a reasonable geographic spread of Lottery terminals across the country, Camelot must install at least one online outlet in each postcode district with 2000 or more residents (instead of one in each local authority area as before);

iv) the minimum number of retailers with terminals during the term of the licence is similar to the numbers required previously, despite the expected introduction of new technology;

v) penalties will apply if numbers of terminals fall below the specified licence commitments.

67. The Commission has taken steps within the current legislative framework, to facilitate competition for the next licence and encourage independent games under the present one:

ii) Camelot must for up to two years prior to the end of its licence co-operate with an incoming licensee;

iii) The Commission has acquired rights over Camelot's database of retailers and can in future make this available to bidders;

iv) The Commission can require the transfer of certain property or rights where this is necessary to the running of the National Lottery, e.g. terminals; and

v) Camelot must provide an incoming licensee with the information necessary for it to pay outstanding prizes.

ADVANTAGES AND DISADVANTAGES

68. The advantages of a single operator holding a single licence were argued by Camelot to include: strategic overview of the overall National Lottery portfolio; consistency in game design and the ability to cross-subsidise between elements of the portfolio if needed; the increased ability to limit the effect of the cannibalisation between individual games; economies of scale; and increased receptiveness to a heavy regulatory focus.

69. One possible reason that organisations were deterred from bidding for the second licence was the incumbency advantage that Camelot was perceived to enjoy at the time of the licence competition. Camelot claims that this issue has been dealt with by "the changes that were made in the second licence by the NLC … in areas such as ownership of intellectual property rights (IPR), exclusive contracts and technology."[58]

70. However, the big disadvantage (and thought to be the main deterrent to bidders) of the single licence system is that only one of the bidding organisations is able to win the Section 5 licence and the others waste a large amount of money in a "winner takes all" process. We believe this deters organisations and may have reduced the number of bidding organisations between the first and second licence competitions from seven to two. It may also further decrease the number of bids for the next licence if the system remains. It is the fear of having no competition for the third licence that has stimulated many of the proposed changes to the licensing system.

71. Camelot believes that there would be a number of other bids for the third licence if the system were to remain. They claim that The People's Lottery (TPL) and Lord Mancroft have expressed interest in bidding for a single licence.[59] They also believe that the introduction of a multiple licence system would deter possible bidders.[60] However, the Government and the NLC assert, supported by reports by the previous Committee, the PAC and the NAO, that there is a danger of no other organisation bidding for another single licence. This is the primary justification that the Department cites for reforming the licensing system of the National Lottery. The introduction of a multiple licence system is proposed by the Government as a mechanism to increase the number of bidding organisations in competition for the operating period after 2009. It would therefore be a serious problem if these changes have the opposite effect and deter possible bidders.

New proposal: multiple licence system

72. The Government proposes to supersede the present system of licensing the National Lottery by giving the NLC the option of awarding multiple licences in the next licence period. The reforms aim to make sure that more than one company will have the ability to bid for the third licence.[61] In theory, the multiple licence system will empower the NLC to obtain increased flexibility by splitting up the Section 5 licence into a number of packages that would then be awarded to a single or multiple operators. This is argued to make the licence(s) more accessible to a larger number of companies and encourage bidders by the number and variety of available licences and the increased likelihood of more companies getting a return on their investment in a bid.[62] Such a system would most probably be divided by game type.[63] The NLC will be the body to decide if, and how, the licence should be split up and would be responsible for deciding which operator or operators would run each part of the new arrangements.

ADVANTAGES

73. The potential advantages of a multiple licence system have been explained to us in detail by DCMS and the NLC. The main advantage is the flexibility of the system which gives the NLC the option to break up the licence if it sees fit to ensure that there is sufficient competition for the next licence round.[64] DCMS said:

74. This flexibility will, it is hoped, lead to the possibility that there will be more than one bidder for the next licence, increasing competition for it. In allowing for a number of different sized companies to bid to run different sections of the licence the reforms are expected to increase innovation within the National Lottery and stimulate a rethink about how best to run and promote Lottery products. The Government believes that the multiple licence approach solves "more of the problems that have come to the forefront that have stopped people bidding for the licence"[66] and that the reforms are what is needed to revive the UK Lottery in light of declining sales.[67]

DISADVANTAGES

75. Mr Michael Grade, Chairman of Camelot, told the Committee that he believed the multiple licence system posed a serious threat to future returns to good causes.[68] Camelot commissioned an independent economic assessment of the DCMS proposals by consultants, Frontier Economics, which focuses on the likely impact on money raised for good causes and identifies a number of potential problems likely to arise with the use of a multiple licence system for the National Lottery.

Frontier Economics report

76. The key conclusions of Camelot's commissioned report, which is appended to this Report, are set out below:

Multiple licence holders competing "within the market" could reduce funds for good causes due to: the possibility of unmanaged cannibalisation between games; uncoordinated product launches being undermined by lack of coordination between licences; under-investment in the Lottery brand and infrastructure (free-riding); and the potential loss of economies of scale and scope.
The total economic value of the Lottery would fall meaning that the multiple licence model would only increase funds for good causes if competition "for the licence" was increased significantly, and the share of the revenues given to the good causes was raised substantially.
Moving from a single to a multiple licence model might not increase competition "for the market" due to increased uncertainty and a more complex strategic environment for bidders to contend with because of the flexibility given to the NLC.
Competition "for the licence" can be increased within the single licence model by modifying the system and allowing: gambling and gaming firms to operate the Lottery through a subsidiary; the operator to select different suppliers during the licence period; the costs of bidding to be underwritten. The incumbent might also be required to submit a final bid before other bidders.
Offering multiple licences would be a complex option with significant risks and no clear benefits to good causes.[69]

77. The report recommends a number of actions to be taken before the competition for the next licence:

a risk assessment into the likelihood of weak bidding in the next round;
an investigation into a number of options, other than multiple licences;
an investigation into the possibility of increasing contributions to good causes under the single licence model, by modifying the shape of the retention schedule;
the Government should ensure that all licences could be won by one operator, should design any division of the licence to minimise competition between operators and should ensure that the NLC is properly resourced to carry out its increased role and extra responsibilities.[70]

NERA report

78. The NLC responded to Camelot's report by commissioning its own study from NERA (its economic advisers) into the conclusions of Frontier Economics.[71] NERA highlighted three major concerns:

The report is not clear enough about the form of multiple licence model that is being assessed. It does not distinguish between the awarding of only one licence for each different types of Lottery product and more than one licence being awarded for each type of product. The NLC envisages reducing cannibalisation, free riding and the problems of uncoordinated launches by splitting the licence by game type and awarding distinct non-competitive areas to different operators.
The report ignores the benefits of dynamic competition, namely, innovation of game design and marketing and cost reduction, all of which could lead to increased returns to good causes.

79. Other criticisms of the report included:

The fact that it assesses the risk of the proposals but does not do so against the costs of not changing the system in the context of declining sales.
It undervalues the role that the NLC regulation can effectively play to avoid undesirable outcomes and does not take into account the Commission's ability to rely on expert advice when complex issues arise.

Role of the NLC

80. Camelot and Mr Simon Burridge, Chief Executive of The People's Lottery were also concerned that the increased role of NLC within the new system would lead to it effectively becoming the de facto operator of the National Lottery without the expertise or incentives of a private sector operator.[72] They argue that this radical change will create a conflict of interests between the licensing and regulatory roles of the NLC.[73] The NLC would have to manage the game portfolios (including the number of each type of game) and the marketing of the brand and the timing of game launches (in order to minimise cannibalisation). All this has previously been the responsibility of the licence holder. Mr Grade, Chairman of Camelot, summarised the position in oral evidence:

de facto

81. Concerns have been expressed to us by Camelot and The People's Lottery that the NLC may not be the correct body to take on this role.[75] This is because they believe that the NLC would be responsible for making commercially sensitive decisions about game design, the make up of the game portfolio, timings of game launches and management of the overall brand, and, as the regulator, it is not well enough skilled or commercially aware to do.[76] Camelot have also identified the potential for conflict between operators, such as the current legal battle between two Italian operators, as something the NLC would have the responsibility to resolve without necessarily having the right skills.[77] The NLC and the Government, however, are both confident that the Commission, with a few small changes (detailed in the decision document and outlined above) will be able to take on this new role if it proves necessary to do so.[78]

82. It was of concern to us that the NLC did not seem sure of the exact implications of these reforms for the role they may have to take on and that it has not, so far, carried out much (if any) research into the detail of the proposals. Representatives from the NLC told us in oral evidence that they did not propose to do any detailed research until nearer the end of the current licence period so that any such work was up to date and relevant to the circumstances pertaining at the time of the third licence competition. The Commission argued that, by then, the resources will be available to carry out research, more details of the system to be used and the role of the NLC within that, will be known and it will be possible to examine the proposals properly.[79] We agree that public resources should be used to gather relevant and timely information but we think that it is critical, at this time, for the Department and the NLC to have a clearer idea of how the proposals to establish a multiple licence system will affect the amount of competition for the licence and the role of the NLC. We therefore recommend that resources are made available for research to be carried out into the effects of the proposals so that the Department can judge adequately the likely effects of its decisions. The Department and the NLC must also consider examples of use of the multiple licence system by overseas lotteries and aim to learn from the experiences abroad.

83. The proposed reforms have been developed because there is a need to ensure that there is adequate competition for the third licence. DCMS believes that the NLC must be given the flexibility in this way to get maximum returns for good causes in the third licence period. Ms Moira Black CBE, Chairman of the NLC, told us that they would

84. The NLC believes, as do the Government, that the continuation of a single monopoly operator would seriously disadvantage good causes in the next licence period. It made clear that the introduction of flexibility would not stop the licence being awarded to one operator if it put forward the best bid. But, it does give the NLC the power to increase competition if only the incumbent operator seems likely to bid for the next licence.[81] It appears to us that the reforms are being put in place before research has been carried out properly into the implications, because the Government wishes to give itself a 'get out clause' if there appears to be a lack of competition for the third licence when it comes up for renewal. This is all well and good, but due to the lack of research done, the Department has not taken into account the potential risks of the multiple licence system (or just the prospects of having such a system) which could in fact reduce competition for the third licence. We therefore urge the Department to consider fully all of the implications of introducing (or giving the NLC the flexibility to introduce) a multiple licence system, at the same time weighing up the multiple licence system against alternative solutions available .

85. We have heard from two prospective bidders that the introduction of a multiple licence system would in fact stop them from bidding for the third licence. Mr Simon Burridge told us that that TPL had so far found no-one with any interest in bidding for the next licence and that, under the current proposals, TPL would not do so themselves.[82] The Committee has also received a letter from Lord Mancroft, Chairman of Inter Lotto (UK), which states that he agrees with Mr Burridge and Sir Michael Grade that the "current proposal (for multiple licences) is unworkable" and goes on to say, "if I was interested in making a bid, I would not do so under these circumstances" and even, "I believe it unlikely that any competitive bids will emerge if this position is pursued."[83] We recognise that there is a need to stimulate more competition for the third National Lottery licence. However we note that the proposed reforms, as they stand, do not have the support of obvious potential bidders and we believe the Department must look again at how it can attract more competition for the third licence.

86. We are concerned that the Department is planning to pioneer this system without sufficient evidence that it will not be putting the National Lottery, and returns to good causes, at risk. In oral evidence Rt Hon Estelle Morris MP, Minister for the Arts, stressed to us:

87. We agree that a solution should be found that is tailored to the needs of the UK's National Lottery but we do not think that the current proposals will create the competition for the licence that the Government aims to obtain nor, therefore, the increased returns to good causes that it seeks to achieve. We do not agree with the statement by DCMS that "this is the right way forward".[85]

88. When considering the advantages and disadvantages involved with the retention of the present system or evolution to a multiple licence system, Mr Simon Burridge representing TPL made a clear and bold statement to the Committee that "faced between the choice of Camelot in perpetuity and the Government's new proposals, with the greatest reluctance I think I would volunteer for Camelot in perpetuity as the lesser of two evils."[86] Looking at the evidence presented to us in this inquiry, including on the limitations of the NLC, we have to agree.

Alternative solutions to the proposed multiple licence system

Improve single licence system

89. One alternative solution to the proposed reform of National Lottery licensing would be to keep the single licence system but improve conditions for the third licence competition so that the Government can be sure that more companies would be able, and willing, to bid for the licence. This could be done by decreasing the cost of bidding for the licence, which has been identified as a significant barrier to applications. Mr Burridge told us that the cost of putting together The People's Lottery bid for the last licence round was over £15 million and took a huge amount of work.[87] It is easy to see why other organisations would be reluctant to spend that amount of money for, potentially, no return.

90. Two ways of decreasing the cost would be to subsidise or underwrite the process (although this would decrease funds going to good causes) or run a two-tier competition for the third licence, with a spending limit for the first round, reducing the burden on bidders. However, in oral evidence, Rt Hon Estelle Morris MP, told us that she believed it was not just the cost that deterred more companies from bidding for the second licence.[88]

91. As highlighted above, another problem with the second licence competition was the incumbency advantage that Camelot was perceived to have held at the end of the first licence. Camelot argued that, since the second licence, steps have been taken to ensure that they no longer have a significant (if any) incumbency advantage as problems with ownership of intellectual property rights, suppliers' contracts and changeover had been resolved:

92. Camelot argues that this means that a single licence competition would be much more likely to attract more bidders. The Government and the NLC dispute this.

COMPETITIVE TENDERING

93. An alternative suggestion to the proposed reforms is the introduction of competition through the provision of services. This could be done by splitting the infrastructure and content of the licence in a similar way to the model used within the utilities sector. Camelot told us that competition could be created, not by splitting the licence, but by not requiring the licence holder to commit to all its suppliers for the entire length of the licence.[90] Instead, the operator could be awarded the Section 5 licence and then have an open-tendering process for the suppliers of advertising, software, scratch card provision, and other supplies in order to create competition whilst maintaining the advantages that are associated with having a single licence holder.[91] The People's Lottery think that competition should be introduced to the process not through multiple licences but through competitive tendering for areas of specialisation which would result in "better services, better marketing, better games, better infrastructure, better retail training and so on."[92] This would introduce the benefits of competition which the Government desires but without the risks associated with a multiple licence system. We feel that competitive tendering would effectively introduce the attractive elements of competition to the National Lottery but would also encourage bids for the overall licence because a better package would be offered to potential operators containing significantly less uncertainty than is associated with the multiple licence system. We recall that the accumulation of risks was a significant factor in the NLC's award of the second licence to Camelot in 2001 rather than TPL which proposed to give a greater proportion of revenues to good causes.[93]

AUCTION

94. Another possibility would be to sell the licence to the highest bidder (modelled on the auction for the 3G mobile phone licence). The NLC told us that the possibility of holding an auction for the next licence will be investigated as part of the preparation for 2009.[94] The advantage of such an auction would be that good causes would have a guaranteed known amount to spend over the licence period. However, the NLC also emphasised the pitfalls of such an auction: the companies involved would have to put forward a large amount of money at the outset of the licence (approximately £10 - £11 billion is raised over a 7 year licence); to borrow that money would increase the costs of bidding (due to the interest paid); and if a fixed sum from the takings was accepted (rather than a percentage) there is the risk that takings would be higher than expected and that the good causes would miss out or, if the company was in difficulty or ultimately failed, the fixed sum might have to be reduced or may be lost altogether.[95]

45 Information from the National Lottery Commission website: www, natlotcomm.gov.uk/Information. Back

46 http://www.camelotgroup.co.uk Back

47 Creigh-Tyte and Farrell, Is the UK National Lottery experiencing lottery fatigue?, in Vaughan Williams, The Economics of Gambling (2002) p 165-181. Back

48 Q 75 Back

49 Q 75 Back

50 Information form Camelot Group plc website: http://www.camelotgroup.co.uk/responsibilities/index.jsp Back

51 Q 111 [Ms Thompson] Back

52 Ev 191 Back

53 Q 70 and Ev 17, 49, 61 Back

54 QQ 6, 8, 71 Back

55 Q 333 Back

56 "National Lottery Licensing and Regulation Decision Document" July 2003 Back