Select Committee on Treasury Written Evidence


Memorandum submitted by Association of Convenience Stores (ACS)

  The Association of Convenience Stores (ACS) represents 32,000 retail outlets throughout the United Kingdom. Its primary function is to represent these shops to Government. Members include SPAR, Budgens, the Co-op and Premier.

  ACS members play a vital community role. They serve local people from a location either in the heart of villages or suburbs, from town centre sites, or on petrol forecourts.

The Convenience Retailing Sector

  There are 53,653 convenience stores in the UK. The breakdown of the stores operating in the sector is shown below:

SegmentNumbers 2001 Numbers 2002Numbers 2003 Numbers 2004
Non-affiliated independents34,250 33,78732,90032,576
Total symbols7,1757,371 7,7948,424
Total forecourts9,766 10,2829,9079,401
Convenience multiples2,756 2,8042,1862,213
Co-operatives1,2971,381 1,9772,065
Total55,24455,625 54,76454,679
Joint Ventures662845 9021,026
Total exc. Joint ventures54,582 54,78053,86253,653

Fig 1:  Convenience Store numbers 2001-04

  Non-affiliated independents are those which are not part of a recognised symbol group or other brand. Symbol groups are fascia brands supported by a wholesale distribution arrangement with the independent retailer. Multiples are wholly-owned and managed from a central office, and co-operatives may be part of any of the dozens of co-operative societies which operate retail outlets.

  These figures show unaffiliated independents and forecourts in decline, and symbol groups, convenience multiples and co-operatives enjoying a growth in store numbers.

  Overall store numbers in the sector are in decline. These stores run on tight profit margins, typically around 2%. This puts in jeopardy the survival of stores who lose income streams and profit. Any reduction in the profitability of these retail businesses may lead to the community losing that outlet and the vital service it provides to local people.

  Convenience stores are faced with growing competitive and regulatory pressures. Superstore companies are increasingly moving into the neighbourhood retailing sector, and this places smaller retailers with reduced buying power and ability to invest in an unenviable competitive position.

  While the Government seeks to address the regulatory burden through various initiatives and bodies like the Better Regulation Task Force, the reality facing retailers is more bad regulation impacting on their business. At present, retailers are facing increased costs under the new Licensing Act: typically £475 for three years as opposed to £30 under the current system. Similarly, legislation such as the Animal By-Products Regulation places additional cost and operational pressure on convenience store operators.

  The overall picture of the convenience store sector is of a declining number of businesses battling to survive against growing competitive and regulatory pressures. For these retailers, the denial of opportunities to maximise their return from limited retail space would seriously threaten their viability.

Cash machines in convenience stores

  IGD's Convenience Retailing 2004 report discusses the value of ATMs to convenience stores. It notes that:

    "ATMs are fast becoming an expected facility in certain segments, forecourts being a prime example."

  This is reflected in the growth of ATMs in convenience stores as shown below in the same report.

Symbol Stores Convenience Multiples Co-op Stores
Company managed forecourts
0102 03010203 010203 010203
% offering ATMs2425 274236 56283750 301533

Fig 2:  Penetration of ATMs in convenience stores

  These cash machines may be owned and operated by the bank and situated externally. Such machines are generally funded by interchange fees between banks.

  Alternatively, ATMs may be sited inside the store. Many of these cash machines are "self-fill", where the retailer replenishes the machine from his own cash. There is usually a charge applied to internal ATMs. These machines are usually operated through an independent ATM provider (IAD).

  IGD explain the reasons for the development of cash machines in convenience stores thus:

    —  Income generation: banks and cash machine providers will pay either a fixed rental fee for the space used, or will make a payment related to the number of transactions the machine is used for. Internal ATMs will generally make a surcharge, a proportion of which is given to the retailer through an agreed contract with the machine provider.

    —  Footfall driver: Harris International Marketing (HIM) research shows that ATM users visit forecourt stores an average of four times per week, compared with 3.7 times per week for non-users.

    —  Increased basket spend: the same HIM research shows that ATM users spend on average £5.11 per trip to a forecourt shop, compared to £3.38 for non-users.

  The last of these three reasons identified by IGD suggests that ATM users spend some of the money they withdraw inside or immediately outside the store in that shop. HIM research shows that 67% of the funds withdrawn from cash machines in convenience stores are spent in that store.

  HIM add a fourth point of value of the in-store ATM:

    —  ATMs increase the catchment area for shoppers to that store.

  Customers value the safety they feel when using a cash machine inside a convenience store. Many customers, especially women, do not feel comfortable using cash machines situated on the street—most notably when beggars loiter close to the ATM. These customers prefer using a cash machine surrounded by other customers and staff in a well-lit and hospitable environment.

  There have been significant security concerns over the placement of cash machines in convenience stores. Incidents of ram-raiding, in which the thief would drive through the front of the store to get access to the cash machine, were frequently reported by ACS members. However, in recent years industry security initiatives and better security management of ATMs on site have helped to reduce instances of cash machine ram-raiding.

  Internal cash machines are generally installed where banks have decided that there are insufficient transactions to warrant doing so. Bank ATMs generally require around 200 transactions per day to be economically viable. Internal ATMs can operate with transaction levels as low as 15 to 20 per day. These machines are therefore additional to the network of bank-run and free-to-use ATMs.

  This low level of usage is demonstrated by the fact that while 40% of cash machines are managed by IADs, only 3% of transaction value is conducted through these machines. They are therefore characterised by being lower-usage sites.

The principle of charging

  When a customer uses a cash machine, they are in effect arranging a loan of another party's (the retailer, IAD or bank) cash. For machines where this loan is not arranged between two banks, the costs of this transaction fall upon the customer.

  Retail space is at a premium. Space dedicated to a cash machine could be used for other products or services. That space attracts rent and rates, as well as the costs of maintaining it to required levels of lighting and cleanliness. Security measures are further fixed costs associated with including an ATM in store. Furthermore, there are costs and inconvenience involved in fitting an ATM.

  Therefore, the provision of an ATM attracts costs to the retailer. Financial reward is therefore a necessity for them. In some cases, banks decide that the gain involved in providing a cash machine allows them to make a payment to the retailer without making a charge to the customer. This is due to interchange payments agreed between banks for one another's customers using cash machines.

  Where ATMs are self-fill and/or are obtained through a third party cash machine supplier, the levy of a charge to the customer is likely to the only way in which revenues can be generated to give retailers compensation for the costs of offering this service.

Transparency

  The principle of charging for cash machine transactions rests on sound information being provided to the customer, ensuring that they are aware of charges being applied to them, and are able to make an informed choice over how to obtain cash.

  LINK has a mandatory rule that customers are warned before commencing their transaction that a charge will be applied to them. Under the LINK system, this information is given to the customer once the relevant bank has informed the machine of its charge.

  Individual operators use policies of displaying charges through stickers or other means. This policy is sometimes hard to implement due to the varying charges applied by different banks and machines.

  ACS is satisfied that information provided to customers is sufficient to allow the customer to make a free choice of where to obtain cash. This choice is analogous to a customer buying a drink in a pub compared to a supermarket. The pub is likely to be more expensive because the customer has been provided with a convenient and pleasant environment, which brings with it a different cost structure. Just as it would be unfair to expect a pub to match supermarket prices on alcoholic drinks, the value of using cash machines in different contexts cannot be compared like for like.

Financial exclusion and location

  ACS strongly believes that the provision through convenience stores of cash machines and other services such as cashback and the Post Office makes a significant contribution to promoting financial services to a wide variety of households.

Symbol Stores Convenience Multiples Co-op Stores
Company managed forecourts
0102 03010203 010203 010203
% offering ATMs2425 274236 56283750 301533
% offering cashback 13 10 149674 3810099 97100
Post Office1517 162514 266912 000


  Fig 3: Comparison of availability of ATMs and cashback facility

  Fig 3 shows that cashback is also widely available and offered in many stores. The Post Office is available in a number of outlets.

  Some retailers are wary about offering a cashback facility due to the security risk involved in maintaining large quantities of cash in tills. Most retailers try to keep cash levels in tills down to a minimum to ensure that those committing robberies and till snatches will gain poor rewards for doing so.

  Many convenience stores operate In low income areas. It is important to acknowledge that the provision of ATMs inside and outside convenience stores is an additional service to customers, and does not replace other opportunities for customers to gain access to cash and other services.

  Given the closure of many local bank branches, the provision of ATMs in convenience stores in by far the most cost-efficient way for many customers to access cash.

  If these services, funded by a charge of some sort, were removed, two socially-undesirable outcomes would accrue:

    —  there would be fewer ATM facilities available to customers, as banks would be unlikely to replace these services where transaction rates were so low;

    —  retailers would come under increasing financial pressures, and their own viability may be threatened.

  ACS does not have access to any further information on the demographic distribution of cash machines.

Post Offices

  Retailers' ability to choose the right cash machine offer to their customers is inhibited in cases where the Post Office is sited at a store. Post Office Ltd apply restrictions in their contract with subpostmasters that requires them not to take up any ATM deal other than that offered by the Post Office. ACS believes this is an unjustifiable restriction of retailer choice.

Conclusion

  ACS is satisfied that at present cash machines offered in or outside of its members' stores are:

    —  of additional benefit to the customer;

    —  important to the future health of the convenience store sector; and

    —  transparent in their charging, offering the customer choice of where to obtain cash.

  ACS is happy to provide further views and information to the Committee, and is committed to supporting this examination.

2 December 2004





 
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