Memorandum submitted by the Association
of British Bookmakers and the Remote Gambling Association
1. With 230 members operating 7,360 of Britain's
8,700 licensed betting offices, the Association of British Bookmakers
(ABB) is the betting industry's main trade body. Membership ranges
from all of the largest chains to one shop businesses, plus a
number of telephone only and racecourse bookmakers. The online
sector is represented by the Remote Gambling Association (RGA),
which has some members in common with the ABB and represents most
of the world's largest remote gambling operators. These companies
all operate in the international market place and their interests
extend to sports throughout the European Union.
2. In general, both of our associations
are supportive of the European Commission's White Paper on Sport
and of the British Government's initial response to it, as outlined
in the explanatory memorandum issued by the Minister for Sport.
3. There are two matters raised in the White
Paper that are of particular importance to members of the ABB
and the RGA and this short submission focuses on those issues.
We address them in the order they appear in the explanatory memorandum.
PARAGRAPHS 17.4,
17.5
4. In the White Paper, the Commission discusses
the funding of sport through the sale of media rights and "acknowledges
the role of collective selling of media rights in this regard".
While welcoming the Commission's intention to look further at
modes of funding, the Minister notes that the UK's approach to
the betting market is notably different from that of other Member
States who rely predominantly on a monopoly state owned or state-run
operator.
5. Observing that the UK betting market
is healthy, well-regulated and growing, the Minister notes that
imposing a sport levy on betting companies (other than the long-established
horserace levy) could negatively impact on the domestic situation
by encouraging betting companies to move offshore, to the detriment
of good regulation and tax revenue. Accordingly, the UK Government
rejects this approach and considers it is for sports to make commercial
arrangements, or to come to other voluntary agreements, with those
who conduct betting on sports.
6. The ABB and the RGA believe that the
Government's approach is correct. Indeed, we support the growing
move towards dismantling monopolies in some Member States and
opening up the market to competition. We would add that while
the Commission has acknowledged the role of collective selling
of media rights and recommends that sports organisations "pay
due attention to the creation and maintenance of solidarity mechanisms"
(paragraph 4.13) that the collective sale of rights can offend
UK and European competition law and is highly susceptible to legal
challenge. Thus we urge the Government and the Select Committee
not to endorse an approach to selling rights designed to reduce
competition and artificially inflate rights payments.
7. While we endorse most of the White Paper
on Sport, we are not persuaded that joint-selling has "solidarity"
benefits. Such advantages clearly have not occurred in football
in this country, with the Premiership having retained virtually
all of the revenue generated by jointly-sold rights to the detriment
of the lower leagues and grass roots football. We also contest
the notion of solidarity within other sports; an example being
horseracing where, in spite of the protestations of those with
a vested interest, there has been no "grand narrative"
or "whole show".
PARAGRAPHS 18.7-18.10
8. We welcome the Government's view that
it is not necessary to introduce a new offence to cover corruption
in sport. The recently appointed Gambling Commission has strong
powers to deal with corrupt activity associated with betting,
including the introduction of a new offence of "cheating"
that can be used alongside existing law to combat corrupt activity.
9. As the explanatory memorandum states,
the UK has well-established and robust anti-money laundering legislation,
added to which the Gambling Commission has agreed with the ABB
and endorsed for use by ABB members guidelines on how to deal
with proceeds of crime issues. In addition, the ABB and the RGA
have established a good relationship with the Serious Organised
Crime Agency (SOCA) and will work with that organisation to combat
those offences that are within its remit. The Gambling Commission
has already issued draft guidance about anti-money laundering
in the casino sector and is currently working on a further paper
to address good practice in the betting sector.
10. The ABB and the RGA fully support the
DCMS ten-point plan on integrity in sports betting and is committed
to co-operating with sports governing bodies to achieve its successful
implementation. The Gambling Commission recently published a policy
statement on integrity in sport and, for the convenience of the
Committee, we attach a copy of that statement. The Committee may
be interested to know that the seminar referred to in the policy
document is scheduled to take place in early March.
11. The betting industry completely supports
high levels of integrity in every sport on which it offers betting
markets. If there are failures in that area it is typically betting
operators who suffer financially and they can and do take necessary
measures to protect themselves against that risk.
12. In such circumstances, the sports and
betting sectors also both suffer damage to their reputations.
As a consequence there is a shared interest in promoting high
standards of integrity, but each sector should be responsible
for its own procedures. The betting sector does not believe it
is appropriate that sporting bodies should be involved in betting
sector processes or vice versa.
13. When this issue has been considered
independently (see British Gambling Commission report of October
2007 which states that "such incidents are very infrequent")
the conclusion has been that there is no need for any direct governmental
intervention because the scale of the problem does not warrant
it and, apart from a need for them to improve liaison arrangements,
both betting operators and sporting regulators were already dealing
with the problem in a proportionate and adequate manner.
December 2007
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