2 The three objectives of gambling
Gambling and crime
|Licensing objective 1
Preventing gambling from becoming a source of crime or disorder, being associated with crime or disorder or being used to support crime.
16. We found no evidence that the 2005 Act has led to any
significant positive or negative change in the levels of crime
and disorder associated with the gambling industry. Many of our
witnesses agreed with the Remote Gambling Association that "the
British gambling industry has an excellent track record in combating
crime and protecting the vulnerable".
There was a general consensus among industry contributors that
the Gaming Act 1968 had already successfully controlled gambling-related
crime and that the 2005 Act made minimal, if any, improvements
in this regard. The casino and bingo operator Praesepe plc said
that the 2005 Act had been "effective in maintaining the
position that was already well established prior to the introduction
of the Act",
while the Rank Group observed that "a 'clean' industry has
been kept clean".
17. Some submissions indicated that the minimal
improvements that there had been regarding the first objective
involved the way illegal activity was dealt with as a result of
the Act. Nikolas Shaw Limited, a small gambling company operating
across the casino, betting shop and arcade sectors, stated that
unlawfully sited gaming machines and illegal poker had been "curbed"
under the 2005 Act, whilst the Remote Gambling Association suggested
that the Act had "brought greater levels of consistency to
how [...] threats [of illegal activity] are addressed".
A fair and open industry
Licensing objective 2
Ensuring that gambling is conducted in a fair and open way.
18. We heard no evidence that the onshore gambling
industry is conducted in a way which is not fair and transparent
to the consumer. Whether or not this is attributable to gambling
legislation or is simply the outcome of a competitive market is
not clear. Betfair held that the high levels of openness and fairness,
which it said predominated in the online, offshore sector, existed
"primarily because companies active on the UK market choose
to operate to the highest standards".
"Multi-licensed companies", it argued, elected to go
beyond the customer protection standards enforced under the 2005
Act. However, Betfair
also pointed to the fact that other jurisdictions required additional
customer protection measures like Know-Your-Customer (KYC) and
anti-money laundering checks across all sectors, whereas in the
UK these were only required for land-based casinos.
Licensing objective 3
Protecting children and other vulnerable persons from being harmed or exploited by gambling.
DEFINING PROBLEM GAMBLING
19. The term "problem gambling" can be defined in
different ways and can include excessive gambling, where an individual
gambles more money than he or she can afford, which is a matter
for subjective assessment, as well as compulsive gambling (where
an individual suffers from an addiction). We use the term to mean
that a person continues to gamble despite harmful negative consequences
or a desire to stop.
20. Evidence from faith and community groups
focused on the harm to individuals and society which they attributed
to problem gambling. They argued that problem gambling was a significant
and growing issue and that it had a negative impact on society
that exceeded the benefits generated by the gambling industry.
Quaker Action on Alcohol and Drugs argued that the "moral
and practical question for legislatorswhich was not squarely
faced when the Gambling Act was passedis whether profit
for the industry, and an increase in gambling opportunities for
the consumer, are worth these human costs".
The 2001 Gambling Review Report cited a number of potential
negative consequences of gambling, including: job loss, absenteeism,
poor work/study performance, stress, depression and anxiety, suicide,
poor health, financial hardship, debts, asset losses, exposure
to loan sharks, bankruptcy, resorting to theft, imprisonment,
neglect of family, impacts on others, relationship breakdown,
domestic or other violence, burdens on charities and burdens on
the public purse. The Gambling Review team recognized that levels
of problem gambling might rise as a consequence of some of their
The then Secretary of State for Culture, Media and Sport, Tessa
Jowell MP, gave assurances that:
If evidence of harm emerges through the research
and monitoring that is undertaken, we will act swiftly to toughen
the controls. We have powers throughout the Bill to withdraw or
move back from the liberalisation if there is evidence of harm.
EXTENT OF PROBLEM GAMBLING
21. Different sectors of the gambling industry
told us that, although they accepted the principle that one problem
gambler was a problem gambler too many, they believed that rates
were low and had not increased significantly since the introduction
of the 2005 Act. A number of submissions suggested that the risks
of problem gambling were over-stated.
22. The most recent British Gambling Prevalence
Survey (BGPS) (sponsored by the Gambling Commission) estimated
the actual number of problem gamblers in the UK in 2010 at between
360,000 and 450,000 adults,
though the accuracy of this figure is by no means certain. To
put this figure in context, the number of adults who said that
they had taken part in some form of gambling in the past year
(in 2009/10) was about 35.5 million, which is 73% of the adult
population. The GREaT
Foundation, which raises money from the gambling industry to fund
research, education and treatment programmes aimed at reducing
problem gambling, compared the number of problem gamblers to the
rates for other public health issues in the UK saying that:
The incidence of problem gambling [...] pales into
social insignificance when compared to smokers (13 million), those
with alcohol or drug problems (6 million) and obesity (16 million).
23. The 2010 BGPS, the third in a series of surveys,
was the first to be carried out after the implementation of the
2005 Act and was meant to provide a benchmark for assessing the
level of participation in gambling in the UK as well as the prevalence
of problem gambling. However, it was not specifically designed
to provide information about why any changes had taken place,
so it can give no firm evidence about the effects of the 2005
Act on the incidence of problem gambling.
24. Some of the figures produced by the BGPS
are set out below and illustrate the broad finding that levels
of participation in gambling activities had increased between
the second BGPS in 2007 and 2010.
- 73% of people aged 16 and over
participated in some form of gambling in the previous yeararound
35.5 million adultsrepresenting a return to the higher
rates observed in 1999 from 68% in 2007.
- 56% of adults participated in a form of gambling
in the previous year, excluding the lottery. Comparable estimates
for 1999 and 2007 were 46% and 48%.
- 4% of adults reported
that their gambling involvement increased in the previous year,
13% that it decreased, and 82% that it had stayed the same.
- Findings suggested that the prevalence of problem
gambling appears to have increased from about 0.6% in 2007 to
0.9% in 2009/10.
25. It is important to note that, whilst the
increase in the number of problem gamblers observed between 2007
and 2010 is most likely to be 0.9% (a 50% rise), the increase
could in fact lie within a range of between 0.7% and 1.2%.
In other words, the percentage increase could be in the order
of between 16% and 100%. Whilst the most likely level of increase
identified by the BGPS is 50%, this result is defined as only
marginally significant due to factors such as the relatively small
26. Whilst it is agreed that the findings of
the BGPS are significant in the sense that they are 'statistically
significant', there is debate as to whether this translates into
'real-world' significance. Gambling industry representatives argue
that little has changed, with the Bingo Association stating that:
"levels of problem gambling remain broadly the same as before
the Act was implemented".
However, Professor Orford, from the University of Birmingham,
argued against this view, saying that the increase was significant
in real terms, and adding:
The best evidence is suggesting that it [the number
of problem gamblers] is far from stable, that it has actually
gone up significantly over the last three years.
Heather Wardle, from the National Centre for Social
Research, said that:
On the balance of probability, the increase is real
27. The imprecise nature of these findings also
results in part from the lack of any significant studies on the
causes of problem gambling. Professor Orford told us that the
increase in problem gambling levels was as a "consequence
of the changes introduced under the Act".
Whilst we recognise that the figures from the BGPS show a likely
increase of 50% in the numbers of problem gamblers, we have seen
no hard evidence to support the view that this increase was the
result of the 2005 Act.
28. The BGPS was criticised by some as being
a tick-box exercise and prone to classifying casual gamblers (who
may place a bet only five or six times in a year) as problem gamblers.
Graham White and Phillip Brear, from the Jersey and Gibraltar
gambling regulators, agreed that BGPS methodology was "suspect"
as "you need to tick only three boxes on the problem gambling
scale and you are a problem gambler by definition".
Mr White gave the example of somebody answering "yes"
to the question "have you ever lied about your gambling habits?"
because they had told their spouse that they had bet £10
rather than £20 at Cheltenham.
A lack of discrimination between enthusiastic and problem gamblers
could therefore lead to a number of false positives. It is worth
noting that the two approaches used in the 2010 survey identified
different sets of respondents as problem gamblers. However, it
is also worth noting that the methodology used remained the same
for all three BGP Surveys. Therefore, although it may be unwise
to extrapolate figures from the BGPS to the population as a whole,
the successive surveys provide comparability across time.
29. On our visit to Australia, we were told that
the most relevant statistic on problem gambling was the total
proportion of gamblers who were problem gamblers, not the proportion
of the total population who were problem gamblers. This was because
the former measure allowed an assessment to be made of the likelihood
of a gambler, or somebody who gambles in a certain way, becoming
a problem gambler. The 2010 BGPS shows thatamongst those
who had gambled in any form at least once in the past yearproblem
gambling prevalence rates were around 1% to 1.3%.
The rate of problem gambling among those who gamble is, of course,
higher than expressed as a percentage of the total population.
However, around 1% remains a low figure, supporting arguments
from the gambling industry that gambling should be seen as a legitimate
leisure activity, though one for which appropriate safeguards
should be in place to protect the vulnerable.
30. Further evidence on problem gambling comes
from overseas studies, in particular those conducted in America
and Australia. However, such studies must be treated
with caution when attempting to draw conclusions about the UK
gambling market. As Professor Griffiths of Nottingham Trent University
commented in a study for the Gambling Commission, "the applicability
of evidence from overseas needs to be assessed further because
regulatory, geographic and venue information as well as machine
characteristics (including the size of stakes and prizes) in other
31. An area of consensus between industry bodies,
faith groups and academics alike was the need for more and better
evidence on problem gambling and specifically about its causes.
The 1978 Rothschild Royal Commission found that there was
a "serious shortage" of information and recommended
that a "Gambling Research Unit" be established by the
Government. The then
Culture, Media and Sport Committee produced a Report in 2002 noting
that "the consensus was clear that not enough objective data
[about problem gambling] had been collected or analysed".
It is now nearly five years since the 2005 Act was fully implemented
in 2007 and this situation has changed remarkably little.
32. In addition to the industry's
voluntary annual contribution of £5 million for Research,
Education and Treatment programmes, the Government previously
provided funding for the British Gambling Prevalence Surveys.
The Government has now withdrawn funding for future British Gambling
Prevalence surveys without giving any indication that it has considered
other options, either for obtaining funding for similar studies
elsewhere or for commissioning other forms of research. We recommend
that the Government works with the Gambling Commission to provide
a clear indication of how it intends to ensure that sufficient
high-quality research on problem gambling is available to policy-makers.
It is particularly important that research is seen to be independent
and comparable over time to show whether or not there is a change
in the levels of problem gambling.
33. An area of understandable concern for groups
interested in the social impact of gambling is under-age gambling.
A 2009 survey carried out by Ipsos MORI for the National Lottery
Commission found that 2% of 12-15 year olds (about 60,000) were
problem gamblers. This is a higher prevalence figure than for
adults, despite being lower than in previous studies.
The Methodist Church of Great Britain argued that research was
needed to establish whether there was a link between "youth
gambling and later problem gambling", stating
that "early exposure to gambling is linked to later patterns
of problem gambling".
Both the 2009 Ipsos MORI survey and a further survey for the National
Lottery Commission concluded that "exposure to gambling generally
is [...] linked with higher rates of gambling".
34. The Rank Group described the level of under-age
gambling as "unacceptably high", but said that the data
on under-age gambling was "frustratingly inconsistent and,
as a consequence, it was difficult to gauge either the extent
or the trend in under-age gambling".
Business in Sport and Leisure (BISL) told us that the 2005 Act
had reduced the risk of those under 18 gambling by restricting
machines to licensed premises. DCMS's position was that protecting
children from gambling-related harm had been a notable success
of the 2005 Act, and that it was now time for the industry itself
to assume responsibility for monitoring and enforcing safeguards
to protect children.
35. The bingo and casino sectors argued that
they performed well in preventing under-age people from gambling
with them. The Rank Group said that "licensed bingo clubs
and casinoswhich provide high levels of supervision, including
regulated entryjointly accounted for just 0.09% of all
recorded incidents of under-age gambling in 2008/9, compared with
adult participation rates of 8% and 5% respectively".
36. In May 2009, the Gambling Commission carried
out a test-purchasing scheme covering about 80% of major betting
shop operators to measure the success rate of industry safeguards
against under-age betting: 98% of the under-18 year-olds involved
in the test were permitted to gamble. The Association of British
Bookmakers responded by signing up to a new Code of Practice and
Action Plan, which entailed introducing a board-level 'champion',
new signage, staff training and commissioning further test-purchasing
exercises. On retesting, the 98% failure figure improved to a
65% failure rate out of 160 shops visited; and in 2010, one test
recorded a failure rate of 26%.
The Gambling Commission stated that it was encouraged by the positive
reaction of the industry to its original poor performance.
37. More recent studies by the Commission focusing
on other gambling sectors including Adult Gaming Centres show
a significantly lower failure rate of about 29%.
The figures from the Adult Gaming Centre sector were described
by the Gambling Commission as "encouraging" but indicating
that there was "still scope for further improvement".
DCMS argued that this was an area where the industry should assume
responsibility for monitoring and enforcing safeguards.
38. We note the wide variation
between sectors in the ease with which 'under-age purchasers'
have been able to evade the safeguards designed to protect them
from gambling. In particular, we are very concerned about the
continuing comparatively high failure rate of betting shops (against
other kinds of gambling premises), whichthanks to the 2005
Actare now able to host casino-style roulette machines.
We recommend that the Gambling Commission continue to monitor
the ability of children to access gambling premises through regular
test-purchasing schemes rather than handing the responsibility
to monitor and enforce age-restrictions to the gambling industry.
The Gambling Commission, working with local authorities, should
also take swift enforcement action where an operator fails to
introduce sufficient access and age-verification controls.
39. There has been insufficient
data collected to establish whether or not the 2005 Act has been
successful in its aim of protecting children from gambling. This
highlights a particular need for more research in this area.
PREVENTING PROBLEM GAMBLING
The regulatory pyramid
40. As already explained, gambling is often broken
down into "hard" and "soft" types.
We received many submissions arguing that some forms of gambling
intrinsically pose a higher risk of causing or exacerbating problem
gambling because of their speed of play and often high stake and
prize levels. While
Professor Orford cautioned that a link between gambling forms
that feature fast, repeated play, including casino games and machine
gambling, had been difficult to establish as "many people
gamble on more than one activity",
Professor Griffiths, a gambling specialist at Nottingham
Trent University, noted in a study for the Gambling Commission
that "compared to non-problem gamblers, problem gamblers
tend to play on gaming machines more frequently and spend more
time and money on them".
41. The 1968 Act put in place a "regulatory
pyramid", meaning that harder forms of gambling were confined
to locations with tighter controls on, for example, access. The
2005 Act, as well as more recent developments, have disrupted
this 'pyramid', as online gamblingmuch of which is not
subject to UK regulationhas developed and some 'harder'
forms of gambling (such as casino-style gaming machines) have
been permitted in traditionally 'softer' locations.
42. We deal with the various issues surrounding
online gambling in the next chapter. We turn now to the issue
of gaming machines.
43. Gaming machines are important to the gambling
industry because of their revenue-producing potential, which is
in part attributable to their low labour costs. The Gaming Act
1968 permitted three types of gaming machines.
- Jackpot machines were allowed
only in casinos, bingo halls and in members' clubs (all of which
had restrictions on entry for non-members and, in particular,
had age restrictions). Jackpot machines had a maximum stake of
50p (£2 in casinos); the maximum prizes varied according
to where machines were located: £4,000 in casinos; £500
in bingo halls and £250 in clubs.
- Amusement With Prizes (AWP) machines were mainly
found in arcades, but could be located in other premises, such
as fish and chip shops, with the consent of the local authority.
They had a maximum stake of 30p. The maximum prize was £5
in cash or £8 in tokens or another non-cash prize.
- All-Cash machines were located in arcades, bingo
halls, pubs and betting shops and had a maximum stake of 30p,
with a maximum prize of £25.
44. The classification system for gaming machines
under the 1968 Act was, to say the least, complex: it was described
by the 2001 Gambling Review Report as "incoherent
and full of anomalies". The review also noted that the then
regulator (the Gaming Board for Great Britain) had within its
jurisdiction only that minority of machines which were situated
in casinos and bingo halls.
45. The 2005 Act established a new system for
categorising gaming machines (A, B, C, and D). The table below
sets out the current categories and their associated stake and
|Machine Category||Maximum stake (from July 2011)
||Maximum prize (from July 2011)
||Unlimited||Regional Casinos (none available)
|B2||£100 (in multiples of £10)
||£500||Casinos, Betting Shops
||£500||All licensed venues except pubs, clubs and travelling fairs
||£500||All licensed venues except pubs, clubs and travelling fairs
||£250||All licensed venues except travelling fairs
||£70||All licensed venues except travelling fairs
|D non-money prize (other than crane grab machine)
||All licensed venues
|D non-money prize (crane grab machine)
||All licensed venues
|D money prize||10p
||£5||All licensed venues
|D combined money and non-money prize (other than coin pusher or penny falls machines)
||10p||£8 (of which no more than £5 may be a money prize)
||All licensed venues
|D combined money and non-money prize (coin pusher or penny falls machines)
||10p||£15 (of which no more than £8 may be a money prize)
||All licensed venues
Table 1: Source: Gambling Commission guidance
46. As illustrated above, the 2005 Act continues
a regime of permitting different types of machine, and different
numbers of permitted machines, in various types of venue (depending
on whether they were seen as suited to 'hard' or 'soft' gambling).
While the regime was always rather complicated, the 2005 Act has
increased the complexity by introducing separate licensing categories
for three types of new casino (Small, Large and Regional), while
retaining a fourth category of the pre-existing (1968 Act) Casinos.
- The 2005 Act specified that
category A machines, with unlimited stakes and prizes, should
be allowed only in Regional Casinos. However, Regional Casinos
were not introduced because the Bill was amended to allow only
one Regional Casino and the Statutory Instrument needed to allow
its development was then defeated in the House of Lords in 2007;
as a result no category A machines are currently available in
- Other casinos are now permitted B1 machinesthe
numbers of which are limited by their ratio to gaming tableswith
a £2 stake and £4,000 prize limit and B2s with a £100
stake and £500 prize limit.
- Betting shops are also allowed up to four machines,
all of which may be B2s.
- Bingo clubs are allowed up to eight B3 or B4
machines, and an unlimited number of C and D machines.
- 'Adult gaming centres' are permitted a limited
number of B3 or B4 machines, as well as machines from lower categories.
- Private clubs, pubs, and 'family entertainment
centres' are permitted C and D machines. Members' clubs and miners'
welfare institutes are the only places allowed to offer B3A machines.
47. When we asked Jenny Williams, Chief Executive
of the Gambling Commission, about the rationale behind machine
categorisation she told us that the "categories that were
put in place were, essentially, a result of discussiontrade-off,
whatever you call itin Parliament at the time about how
precautionary the then Government felt they wanted to be".
48. We were told by the Gambling
Commission and by DCMS that gambling policy must be evidence-based.
It is apparent, however, that the allocation of gaming machines
under the 2005 Act is complex and was not made on the basis of
solid evidence about the risk of problem gambling.
49. The 2005 Act removed gambling opportunities
from many public areas, such as food outlets, and there was general
agreement among our witnesses that while the classification system
was "somewhat rough and ready" it was broadly justifiable
as it limited machines with higher stakes and prizes to more controlled
in the view of a number of our witnesses, the regulatory pyramid
had been undermined by the approach taken in the Act to one specific
type of gaming machine, the B2. The Casino Operators Association
argued that the measured approach to availability of gambling
machines had been "completely negated by the fact that 8,800
Licensed Betting Offices have been allowed to offer four hard-core
casino gambling machines in each of their shops."
The Methodist Church described it as "worrying" that,
as it saw it, the distinctions between "gaming environments
and hard gaming locations" were "increasingly being
Thomas, a member of the gambling industry and trustee of GamCare,
suggested that the Act could have reduced the prevalence of problem
gambling: the "principles behind the Gambling Act were sound
and if it had controlled hard gambling on the high street [...]
appropriately then the issues related to problem gambling would
50. B2 machines (FOBTs) have proved the most
controversial form of gambling machine in terms of their potential
impact on problem gambling. While other category B machines have
the same £500 maximum prize as B2s, it is possible to stake
up to £100 on a single bet (most commonly a single spin of
the virtual roulette wheel) on B2s whereas other category B machines
have a maximum stake of £2. Prior to the 2005 Act, FOBTs
were not classed as gaming machines under existing legislation
so there were no limits on where they could be placed and in what
Caborn, former Minister for Sport and Tourism, said that if they
had not been controlled, "you would have had wall-to-wall
FOBTs in this country".
As a result of growing concern about the proliferation of these
machines, a deal was reached between DCMS, the Gaming Board and
the Association of British Bookmakers (which represents 85% of
the UK's betting shops): a Code of Practice for FOBTs was introduced,
limiting the number of gaming machines, including FOBTs, per betting
shop to four. It
also set limits on stakes and prizes; banned all casino-type games
except roulette; set a minimum time interval between bets; and
introduced signage and help pages on machines to deter problem
gambling and assist problem gamblers.
A subsequent inquirycommissioned by the Association of
British Bookmakers at the request of DCMSconcluded that
"there is no evidence in this study which suggests that FOBTs
are closely associated with problem gambling".
As a result, FOBTs were effectively "taken off probation"
under the 2005 Act and classed as B2 machines. The limit of four
machines per premises was reached as a trade-off between the DCMS
and the industry.
51. The betting shop sector argued that B2 machines
do not pose a significant risk of problem gambling. David Steele
from William Hill cited the fact that there was no difference
between the rate of problem gambling between the 2001 and 2009
British Gambling Prevalence Surveys (0.6% for both years), despite
about 30,000 B2s being introduced between those surveys. FOBTs
had been available in betting shops, however, since 2001. On the
opposing side, several faith groups, including Quaker Action on
Alcohol and Drugs and the Evangelical Alliance, said that "a
large body of research shows that gaming machines are one of the
riskier forms of gaming [
] because of their strongly reinforcing
evidence to the 2003 Joint Committee on the Draft Gambling Bill,
GamCare said that it had noticed an upward trend in people requesting
help on B2s (FOBTs).
Some of its witnesses said that B2 machines had been described
as accelerants or catalysts to problem gambling and Gordon House
said that an applicant for its help had called B2s "the crack
cocaine of gambling".
52. It was widely agreed that casinos, with their
strict entry controls and regulation, are the appropriate location
for hard gambling, including machine gambling.
Simon Thomas of the National Casino Industry Forum (NCiF) told
us that "having operated seaside arcades, inland arcades,
bingo halls, I can say with my hand on my heart there is no level
of regulation and protection like we are getting in the casino
industry, particularly money laundering and every single member
of staff being certificated".
However, under the current regime some types of casino are permitted
considerably lower stake limits than high street betting shops.
The NCiF argued that casino-style gaming machines such as B2s
should be allowed only in the heavily regulated environment of
Casinos, at the top of the regulatory pyramid are
permitted only Category B1 machines with a maximum £2 stake.
Of the 144,110 licensed slot machines in the UK, only 2400 or
1.6% are in casinos while there are over 32000 B2 machines in
8500+ high street betting shops offering £100 stakes on a
game that plays every 20 seconds and nearly 12000 B3 machines
in bingo clubs and seafront arcades also with a proposed £2
The NCiF's spokesman, Simon Thomas, explained that
the challenge faced by casinos was that "above us we have
the internet with very high stake gaming machines available and
below us we have the betting shops with £100 stake machines".
He therefore proposed a "£5 stake and a £10,000
prize" limit for the casino sector's B1 machines.
53. Casinos are the most highly-regulated
sector and they are therefore the most appropriate venue for hard,
high-stake forms of gaming. This is not reflected fully in the
current allocation of machines. We believe that it is illogical
to restrict the games available in highly regulated land-based
casinos when B2s, with high stakes and prizes, can be accessed
in betting shops. The Government should address the current imbalance
by permitting casinos to operate up to twenty B2-type machines
with a maximum stake of £100.
2) Betting shops
54. Decreasing the limits on maximum stakes on
B2 machines in betting shops (£100 stake on roulette games)
to something closer to those available in other high street locations
such as arcades, pubs and bingo halls (£2/£1) could
cause financial difficulties for betting shops. About 50% of the
profits of betting shops derives from machines and their business
model has become very reliant on them.
55. The betting shop industry argued for an increase
in the current allowance for B2 machines. David Steel of William
Hill told us that, because of physical restraints and levels of
demand, "five or six (B2 machines) would certainly satisfy
demand at the high points of the day for the vast majority of
shops in the UK".
Witnesses from the Rank and Gala Coral Groups expressed the opinion
that numbers of machines were not linked to problem gambling,
as it was impossible to play more than one machine at a time.
However, during the visit to Mecca Bingo in Dagenham, we noted
the fact that some customers can, and do, play on a row of machines
simultaneously. DCMS Minister John Penrose also stated the possibility
that limiting machine numbers, for example, in betting shops could
lead to players being unable to reach a vacant machine immediately,
thus experiencing a cooling-off period.
56. During the Second Reading of the Gambling
Bill in 2004, Tessa Jowell MP stated that the Government would
"monitor very closely any evidence that the availability
of these [B2] machines is leading to an increase in problem gambling,
in which case we will take action through the Gambling Commission
to address the matter".
She also raised her concerns about the rate of play for B2 machines,
saying that "if you play constantly for an hour, you could
lose £18,000 an hour. I would be concerned about that".
57. We recommend that research
be commissioned by the Gambling Commission to assess the potential
of types of gambling to contribute to problem gambling levels,
in particular whether there is a link between features including
speed of play, stake and prize levels, accessibility and numbers
of gaming machines, and problem gambling.
Reasons for clustering of betting shops
58. Whilst acknowledging that the geographical
distribution of betting shops was changing, the Association of
British Bookmakers (ABB) pointed out that there had been no net
increase in the number of UK betting shops since the 2005 Act
came into effect in September 2007. They also pointed to "several
examples of LBO [betting shop] openings being blocked in a number
of London boroughs over the last twelve months" as evidence
that no additional action or legislation was necessary in this
59. However, we were informed of three possible
factors contributing to the clustering of betting shops: one was
simply related to the planning system; a second involved the interaction
between the planning system and the 2005 Act; and the third related
solely to a possible anomaly created by gambling regulation.
60. Betting shops are classedunder the
current planning systemin the same category as banks and
building societies. As a result, there is no requirement for a
change-of-use permission from a local council to convert, for
example, a bank into a betting shop. At present, local authorities
have to use an "Article 4" planning direction to prevent
a new betting shop from being established in converted premises.
However, the Local Government Association (LGA) told us that this
process was very time-consuming, expensive and complicated. Furthermore,
it said that Government proposals to require 12 months' notice
of the use of an Article 4 directionwhich reduces the likelihood
of a local authority having to paying compensation to the planning
applicantrisked further undermining the procedure's effectiveness.
The LGA proposed allowing local authorities to develop their own
classification system for planning purposes in order to make it
more sensitive to local circumstances. 
61. Some of our witnesses called for changes
to local planning powers to make betting shops sui generis
(a class of their own), so that local authorities could control
their number in any specific locality, if they wished.
This was the solution which was introduced by the 2005 Act in
relation to casinos in order to allow local authorities to reject
their development if they decided that they did not want a casino
in their area. Placing betting shops into a use-class of their
own was also a recommendation of the independent Portas Review
into the future of UK high streets, published in December 2011.
62. Secondly, prior to the Gambling Act 2005,
the issuing of premises licences for betting offices, along with
casinos and bingo halls, was subject to a demand test. The 2001Gambling
Review Report concluded that the demand test stifled competition
and reinforced the situation whereby a small number of large firms
could control gambling markets, particularly in the casino sector;
and that demand was best assessed by potential operators on commercial
grounds alone. The
2005 Act subsequently abolished the demand test and replaced it
with an "aim to permit" clause. This meant that local
authorities had a duty to license any premises which did not threaten
any of the three licensing objectives set out in the Act.
63. Some of our witnesses argued that scrapping
the demand test for gambling premises had made it easier for bookmakers
to locate on high streetsmainly in inner city areaswhich
reflect the economic and ethnic mix which, they argued, operators
target. Though the
ABB strongly believed that the existing licensing process and
legislation offered "enough protection to local communities",
residents' groups argued that the abolition of the demand test
"effectively removed the ability of communities to make substantive
objections to any licence application".
The London Borough of Haringey said that there was now "almost
no restriction on how many gambling premises [could] operate in
an area". The
Casino Operators Association argued for the reintroduction of
the demand test, saying that "the Gaming Act 1968 effectively
halted the uncontrolled proliferation of casinos in the UK largely
through its demand test and permitted areas regulations".
64. The third potential factor in the clustering
of betting shops was the restrictionnegotiated with the
industry in 2004 and codified under the 2005 Acton the
number of B2 gaming machines (one of the 'harder' forms of casino-style
gambling) which are permitted in each betting shop. The decision
to allow a maximum of four B2 machines per shop encouraged betting
shops to proliferate in some areas because the demand for B2 machines
outstripped supply in any one betting shop, making it economically
viable for them to cluster together.
65. The Minister for Tourism and Heritage, John
Penrose, told us that, if clustering proved to be a problem rather
than a concern, Ministers would take the issue "extremely
Betting shop clustering is currently a local planning issue rather
than one for the Gambling Commission, which would be expected
to respond only if evidence emerged that betting shops or B2 machines
were causing significant gambling-related harm. Mr Penrose informed
us of a forthcoming consultation by the Department for Communities
and Local Government which was likely to include some questions
on the issue of gambling. He said that tackling this issue was
"going to be a double action between DCMS and Communities
and Local Government to make sure that the interplay between gambling
regulation and planning is rightly based".
66. The 2005 Act has had the
unintended consequence of encouraging the clustering of betting
shops in some high streets by removing the demand test and limiting
the number of B2 machines permitted in each premises. The clustering
of betting shops is a local problem which calls for a local solution.
We therefore recommend that local authorities be given the power
to allow betting shops to have more than the current limit of
four B2 machines per premises if they believe that it will help
to deal with the issue of clustering. The limit of four B2 machines
under current legislation should be maintained as a minimum limit
to create certainty for operators. However, if problems arise
with individual betting shop chains or premises in connection
with B2 machine use, local authorities should haveas a
safeguardthe right to require the removal of any machines
over the minimum allowance.
3) Bingo Halls, Arcades and Adult Gaming Centres
67. The adult gaming, bingo and arcade sectors
argued that they had been most adversely affected by the 2005
Act. One of the key changes made by the Act was the removal of
certain machinesknown under the 1968 Act as section 16
and 21 machinesfrom arcades and bingo halls. Section 16
and 21 machines had a stake limit of £2 and prize limit of
£25. They allowed up to 20 games to be played concurrently
on the same machine meaning that the total prize could be £500.
Section 16 and 21 machines were replaced with B3 machines with
a £500 prize limit but a lower stake limit of £1. Therefore,
previously a player had to stake £40 in order to have a chance
of winning £500: now the stake for the same winnings could
be as little as £1. The British Amusement Catering Trade
Association (BACTA) told us that the removal of the section 16
and 21 machines from arcades had resulted in more than 200 amusement
arcade closures in the previous 18 months, a fall in the number
of amusement machines being manufactured from 55,000 to approximately
10,000 per annum, and hundreds of jobs being lost.
Leslie MacLeod-Miller of
BACTA told us that "arcade revenues are down somewhere between
20% and 30%".
This view was supported by high street gambling company, Praesepe
plc, and the British Association of Leisure Parks, Piers and Attractions
68. Kevin Allcock from Mecca Bingo told us that
his company probably lost about £0.5 million of income "overnight"
as a result of this change.
Although the limits on both the number of machines and the maximum
stake payable were subsequently increased,
some feared that this might have come too late for some operators
that had already suffered losses.
69. We support the original
vision behind the 2001 Gambling Review Report in which bingo halls
were to be maintained as social, soft gambling environments. In
the case of Adult Gaming Centres we believe that they provide
a controlled adult environment and have robust access controls,
as demonstrated by their low failure rate in the Gambling Commission's
test-purchasing scheme. We therefore recommend that Adult Gaming
Centres are permitted B2 machines on the same basis as betting
4) Commercial Snooker Clubs
70. The commercial snooker club operator, Rileys,
argued that its business was specifically damaged by the removal
of B3 machines from its premises under the 2005 Act, as well as
by other factors such as the smoking ban. The company told us
that the machines it had prior to the Act, which offered a maximum
£500 prize, were "critical to the profitability"
of its business, adding that, when they were removed, its revenues
immediately dropped by £888,000 and were still in decline.
Rileys argued that it should be able to offer B3 machines with
a £2 stake and £500 prize because it provided a controlled
environment as a private members' club and already held an alcohol
licence. Its suggested method for allowing thisto alter
the Act to create a new operator's licence under section 65(4)had,
thus far, been rejected by DCMS. The Minister for Tourism and
Heritage, John Penrose MP, told us that he sympathised "to
a point" with Riley's position but that amending the Act
to give further allowances to specific sectors, such as commercial
clubs, had the potential to open the way for other private clubs
to demand similar machines in order to compete or simply to maintain
parity. Rileys rejected
this premise and pointed out that other private clubs, namely
Working Men's Clubs, had never requested B3 machines. The company
further argued that the strict criteria for entry to the market
and the necessity of obtaining local authority and Gambling Commission
approval would prevent a significant number of commercial clubs
from taking advantage of any special provisions. The Minister
suggested that Rileys could "work within the existing legislation"
by opening Adult Gaming Centres adjacent to its venues, which
would allow it to subsidise its existing business by using them
to offer B3 machines.
71. We recognise the potential
pitfalls of amending the Act to meet individual hard cases and
also note that it would be unlikely that the Government would
be able to find room in its legislative programme for such amendments
in the near future. However, it is clear that commercial snooker
clubs have suffered disproportionately from the removal of B3
machines and are now struggling to remain profitable. We therefore
recommend that commercial snooker clubs be permitted to offer
STAKES AND PRIZES
72. The impact of high stakes and prizes on problem
gambling levels in the UK was disputed and much of the industry
argued that limits should be increased.
Some groups held that there was a link between stake and prize
limits and problem gambling. Quaker Action on Alcohol and Drugs
cited the advice given to the Gambling Commission in 2009 by a
panel of experts which reached a general consensus that stake-size
was "a risk factor", primarily because high stakes could
lead to high losses and therefore greater financial harm. The
panel also concluded that setting stakes "too low" would
"probably be among the least effective options for promoting
responsible and safe play", by encouraging a 'grey market'
of illegal and unregulated operators offering cheaper gambling
73. In 2011, stake limits for B3 machines were
increased to £2 and the number of B3s allowed in adult gaming
centres and bingo halls was raised to 20% of total machines. We
asked the Minister about the rationale behind these increases
in light of his insistence that further such changes would only
be made on the basis of firm evidence that they would not cause
harm. The Minister's response was, firstly, that the changes were
a manifesto commitment and, secondly, that making (lower stake)
B3 machines more "attractive" could draw people away
from B2 machines. He acknowledged, however, that he did not have
"solid ground beyond that". 
We consider that the decision
to raise the stake limit on B3 machines was made on the basis
of little or no evidence. We welcome the Government's position
that further changes to machine stakes and prizes should be evidence-based.
74. During our visit to Australia we examined
how the industry and the Government had responded to problem gambling.
In summary, though the picture is not yet clear, some of the innovations
introduced seem to be fairly effectivesuch as messages
that pop up on screen to break the trance-like state that repeated
play of gaming machines may induce, and limiting the maximum stake.
However, some of the more radical ideas, such as abolishing cash
stakes and instead making machines operable only through smart
cards with a pre-determined loss limit, have yet to be tested.
It is important that the
likely effectiveness of any measures for tackling problem gambling
is assessed before such measures are put in place. We recommend
that the Department for Culture, Media and Sport seek to learn
from the experiences of other jurisdictions, such as Australia,
which have implemented measures to combat problem gambling including
educational programmes and machine displays showing time spent
Tackling problem gambling
75. Throughout this inquiry we received significant
amounts of evidence from the gambling industry stating that it
regarded problem gambling as a serious issuenot least because
of the significant potential for reputational damageand
had taken measures to tackle it. Much of the industry held that
the Act did not provide much, if any, improvement in protection
measures against problem gambling as the sector had already been
operating in a socially responsible way. Ladbrokes told us that
it had "voluntarily implemented" many of the Gambling
Commission's Licence Codes of Practice "years before the
introduction of the Act".
Other members of the industry told us that, long before the 2005
Act, they had been making financial contributions to organisations
helping to tackle problem gambling, such as Gamcare, which runs
a helpline, therapy services and prevention training for industry
workforces, and the Gordon Moody Association, which provides residential
treatment. The bingo
and arcade sectors, in particular, argued that their venues had
a positive social impact on their local areas because of the employment
they brought, as well as providing a social environment in which
the local community could congregate.
arguments that the 2005 Act changed little in reference to problem
gambling, we regard it as an important step forward that, for
the first time, the Act gave the Government the powerand
the gambling industry the responsibilityto tackle problem
76. Codes of practice have been drawn up by industry
groups to put in place measures to tackle problem gambling. As
we have already discussed, as a result of concerns over B2s, a
Code of Practice for the operation of B2s, including technical
standards, was agreed between the major betting shop operators
and the Gambling Commission in 2003. After the 2005 Act, the Gambling
Commission introduced a Licence Conditions and Code of Practice
(LCCP) document, which required all licensed operators to implement
customer protection measures. Online companies, for example, must
carry out age verification checks within 72 hours of customer
registration. Betfair told us that much of the online industry
also employed "Know-Your-Customer" (KYC) checks, as
they are compulsory in some other jurisdictions, but which are
not yet required by the Commission for any sector other than land-based
77. We have seen that information
about problem gambling and sources of help has been made available
inside the gambling venues which we have visited. An information
campaign, aimed at the relatives of problem gamblers, could lead
to more people seeking help because relatives of problem gamblers
may not enter gambling venues and see the information provided
there. We recommend that the Department for Culture, Media and
Sport develop a public information campaign outside of gambling
premises to highlight sources of help for problem gamblers and
their relatives. The Government should also make an assessment
of the ability of existing support and advice centres to deal
with any significant resulting rise in demand. If a significant
increase is expected then the industry should fund, out of the
existing voluntary levy, increased provision of advice and support
by these existing centres.
78. One way in which individuals can attempt
to tackle any problem gambling behaviour is by opting to be denied
access to gambling premisesso-called 'self-exclusion'.
The ability of customers to self-exclude from gambling premises
is a significant feature of programmes to tackle problem gambling
behaviour. The Gambling Commission also requires all except ancillary
and software licence holders to provide information pertaining
to self-exclusion options. However, there is currently no nationwide,
cross-industry system for customer self-exclusion. Some of the
international regulators from whom we heard evidence called into
question the effectiveness of current (off-line) self-exclusion
systems. Graham White, Chairman of the Jersey Gambling Commission
You can walk into one casino and self-excludea
week and two days later, you can go into another one. You can
go into a bookmaker and self-excludea week and two days
later, you can go into William Hill as opposed to Coral, for example.
That is the weakness of the exclusion system.
79. Figures from the Gambling Commission also
suggested that there was a problem in some parts of the industry
with self-excluders being allowed to gamble. Figures for the betting
sector showed that, while the number of self-exclusions had gone
up significantly (from 11,424 in 2008-9 to 20,823 in 2010-11),
the number of "known breaches of self-exclusion" had
more than doubled (4,033 to 10,468) between 2009/10 and 2010/11.
Other sectors had lower levels of self-exclusion, with the bingo
sector experiencing a significantly lower number of both exclusions
and breaches: the latter was down by 32% from 2009/10 to 2010/11.
GamCare told us that "the operation of self-exclusion largely
depends on the vigilance of staff and there are many examples
of the system breaking down".
80. A study, cited by the Ladder Community Safety
Partnership and produced by a group of organisations including
GamCare and Manchester Metropolitan University, found that "gamblers
who had self-excluded from one or two venues in a locality tended
to move between different gambling operators as a strategy to
The study argued that a national self-exclusion system for problem
gamblers would help this situation by greatly simplifying the
It was also argued that allowing a previously self-excluded customer
to re-enter a gambling venue without requiring them to produce
evidence that they had sought or received any form of problem
gambling treatment could lead to that individual re-encountering
81. We recognise the significant
practical challenges that introducing a national "universal"
self-exclusion system would involve, including confidentiality
and legal issues. However, the Government should support the development
of a system which would allow a customer to self-exclude from
all forms of gambling regulated by the Gambling Commission.
RESEARCH, EDUCATION AND TREATMENT
82. Under the 2005 Act, a voluntary levy was
introduced on the gambling industry to fund research, education
and treatment (RET) programmes to tackle problem gambling. There
is provision under the 2005 Act to make the levy mandatory if
the Government were to decide that not enough money was being
raised from the industry on a voluntary basis. Some witnesses
argued that there was cause to introduce a compulsory levy on
the gambling industry on the basis that it was not giving enough
money to research, education and treatment programmes.
Others argued that, so far, the simple threat of a mandatory levydescribed
by the Evangelical Alliance as a "Damocles sword"had
proved sufficient incentive for the industry to provide the funding
83. The Jersey Gambling Commission, which operates
a similar voluntary levy system to the UK, argued that the levy
should not be made compulsory, firstly, because this would cause
hostility from the compliant industry and, secondly, because any
percentage-based levy would unevenly impact on operators. Instead
it suggested a flexible system, such as that provided under Jersey
Law, which allowed a compulsory levy to be imposed only on non-compliant
sectors. This would leave the already compliant sectors able to
continue to give funds towards research, education and treatment
on a voluntary basis.
84. The voluntary levy for research,
education and treatment has thus far been successful at raising
the target of £5 million per annum. An important lever for
obtaining funds from the gambling industry is the potential for
reputational damage if insufficient monies were raised or if a
compulsory levy were deemed necessary. While it is important that
the option of enforcing a compulsory research, education and treatment
levy be maintained, we recommend that the current voluntary levy
is continued. However, should one or more sectors of the gambling
industry fall short in their duty to fund research, education
and treatment programmes, the Government should implement a compulsory
levy on those sectors.
THE TRIPARTITE STRUCTURE FOR RAISING
AND DISTRIBUTING THE LEVY
85. Before the 2005 Act, a body called the Responsibility
in Gambling Trust raised and distributed funds for research, education
and treatment. Its responsibilities were split after the implementation
of the 2005 Act: the industry-dominated GREaT Foundation became
the fundraising arm of a tripartite structure involving the Responsible
Gambling Strategy Board (RGSB) and the Responsible Gambling Fund
(RGF). Overall policy aims and strategy are set by RGSB while
GREaT collects the voluntary donations from the industry to fund
research, education and treatment projects selected and monitored
by the RGF.
86. The boundaries between the elements of the
tripartite structure have never been clear. GREaT has distributed
funds for treatment directly to GamCare (which runs a helpline
and therapy services and trains the industry workforce in prevention)
and the Gordon Moody Association (which provides residential treatment).
The RGF has received money from the industry through GREaT to
distribute to other organisations under the guidance of the RGSB:
for example, the National Problem Gambling Clinic, run by the
NHS, received funding from RGF. GREaT, RGF and RGSB were thus
intended to work together to fund and plan research, education
and treatment provision.
87. The cost-effectiveness of the tripartite
structure was called into question by its fundraising wing, GREaT.
It argued that the predecessor body, the Responsibility in Gambling
Trust, was able to do the same job for less money: for example,
while the Responsibility in Gambling Trust estimated that it cost
£474,000 for it to raise £5 million per annum from the
industry the "like for like" figure for RGF and GREaT
combined was £500,000.
88. The tripartite structure drew criticism from
all sides of the debate, largely because it was seen by many as
overly bureaucratic, and because of the discord between GREaT
and RGF. RGF described
industry funding levels as "lower than hoped" and, as
a result, said: "some aspects of RGSB's Strategy cannot
yet be addressed. There is little flexibility within the budget
for 2011/12 for RGF to review the proportion of funding to each
area of activity".
The RGF went so far as to advise that a statutory levy should
be enacted unless a funding distribution method could be put in
place to prevent the views of industry or service providers from
dominating the process.
GREaT, meanwhile, stated that the tripartite structure had had
a "negative impact on" its ability to raise funds, and
raised concerns about the poor relationship between RGF and the
treatment provider GamCare.
89. Shortly after providing their written evidence
to us, RGF and GREaT terminated their funding agreement, effective
since March 2012, as a result of a dispute over the issue of independence
from the industry. RGF objected to GREaT's view that the voluntary
nature of the industry's contributions should mean that it was
"fully involved in the decision making process" concerning
The tripartite structure has therefore in effect collapsed. RGF
blamed "insufficient will and determination on the part of
those who signed up to" the tripartite agreement for its
failure to succeed.
90. In November 2011, the Responsible Gambling
Strategy Board (RGSB) released its third annual strategy document
detailing its objectives and setting out its recommendations,
to the Gambling Commission and the Government, for the principles
which it believes should apply to successor arrangements in the
wake of the withdrawal of RGF. As the RGSB itself has stated,
it is not yet clear what structure will replace the function of
the RGF. The main principles outlined by the RGSB include:
impartiality of funding decisions
Command the confidence of stakeholders
in setting priorities
Secure credible, independent research
into which treatment strategies work and include research, education
and treatment in a coherent strategy
Deliver proper accountability for use
of funds provided, by using the grant management, commissioning
and data collection frameworks already established by RGF, and
Ensure continuity of funding at the target
income levels set by the voluntary agreement.
91. We recommend that, in designing
successor arrangements to the tripartite agreement for the funding
of research, education and treatment, the Department for Culture,
Media and Sport and the Gambling Commission focus on minimising
overlap between the responsibilities and activities of the bodies
involved as well as ensuring effective communication between them.
While the Responsible Gambling Strategy Board continues to advise
the Gambling Commission, and through it the Government, we believe
that the Department for Culture, Media and Sport should also take
a more pro-active role in identifying the research needed for
strategic policy development and ensuring that these needs are
reflected in the research being carried out.
92. We support the recommendations
of the Responsible Gambling Strategy Board for the principles
which should apply to the successor arrangements to the tripartite
agreement as laid out in its 2011 Strategy document. In addition,
the advice from the Responsible Gambling Strategy Board regarding
the amount required for future research, education and treatment,
if accepted, must be clearly communicated to the gambling industry.
This advice should set out how the money donated by the industry
will be spent. We await with interest proposals from the Gambling
Commission for a replacement for the now defunct system for funding
and commissioning research, education and treatment programmes.
DISTRIBUTION OF FUNDS
93. As the dispute between the RGF and GREaT
Foundation indicates, not everyone was happy about how the funds
raised from the industry were distributed. GamCare said that the
funding provided through GREaT had been "focused on treatment
[and that] very little has been spent on prevention and education.
The remainder has been invested in research".
The Casino Operators Associationdescribing the tripartite
structure as "overly-expensive, self-serving and unnecessary"recommended
that it be abolished, allowing the industry to give directly to
organisations like GamCare and the Gordon Moody Association.
 The Evangelical
Alliance argued that education funding could be at risk under
the current system due to funding being channelled by the industry
94. Education and research have been, to an extent,
the poor relation of treatment. Levels of understanding among
the general public about gambling, probability and odds are low,
particularly among under-16s. This situation has the potential
to contribute to problem and excessive gambling as people could
have unrealistic expectations about their chances of winning.
Some witnesses suggested that the gambling industry was unwilling
to see its donations going towards educational programmes because
it feared reputational damage.
GamCare suggested that education was needed in schools because
"the promotion of gambling products has become more pervasive,
and so the teenager's perception of gambling as an acceptable
leisure pursuit is being reinforced with no effort to ensure they
are equipped to gamble safely".
GamCare told us that it had developed an education programme aimed
at 12 to 16 year olds which it intended to pilot in three areas
if funding of about £75,000 per pilot was made available
through GREaT over two years. 
95. Some funding for research into gambling came
from the Government, with the intention that a sound base of knowledge
would be developed to allow evidence-based policy making. The
Government funded the previous National Centre for Social Research
surveys into gambling. As noted above, we are disappointed that
the Government has withdrawn funding from future surveys without
having indicated how it intends to ensure the provision of up-to-date
and robust data on problem gambling in future.
96. The Gambling Commission
should make an assessment of the available gambling education
programmes aimed at under 16 year oldsincluding that which
has been developed by GamCareand make a recommendation
on their merits, based on projected cost and level of impact.
10 Ev 178, Ev 152, Ev 158, Ev 180, Ev W 44, Ev W 32,
Ev W 01, and Ev W 52 Back
Ev W 06 Back
Ev 180 Back
Ev W 01 and Ev 178 Back
Ev 180 Back
Ev 161 and Ev 167 Back
Ev 161 Back
Ev 193 Back
Gambling Review Report p94 Back
HC Deb, 1 November 2004, cols.31-32. Back
Ev 227 (Bingo Association); see also Ev 06 (Gala Coral Group),
Ev 161, and Ev 186 Back
See Annex 2 for a description of the methodology and an estimate
of the robustness of this survey. Back
National Centre for Social Research, British Gambling Prevalence
Survey 2010, p9 Back
The others took place in 1999 and 2007. The 2005 Act was brought
into force fully only in 2007, so the 2010 survey was the first
under the new Act. Back
British Gambling Prevalence Survey 2010, p11 Back
British Gambling Prevalence Survey 2010, pp9-10 Back
Ev 227; see also Ev 152 for other similar views. See Ev 268, Ev
W 71 and Ev 193 for the counter argument. Back
Q 528 Back
Q 561 Back
Ev 214 Back
Q 650 Back
British Gambling Prevalence Survey 2010, p77 Back
Impact of high-stake, high-prize gaming machines on problem
gambling, 2008 Desk exercise by the Gambling Commission, Contributing
Ed. Professor Mark Griffiths p2 Back
The Royal Commission on Gambling, chaired by Lord Rothchild,
CM 7200, July 1978, p20 Back
Culture, Media and Sport Select Committee, The Government's
proposals for gambling: Nothing to lose? Seventh Report of
Session 2001-2, HC 827-I, p8 Back
Ipsos MORI, British Survey of Children, the National Lottery
and Gambling 2008-9, July 2009, p2-3. See also: Ev 23 Back
Ev 210 Back
Ipsos MORI, Underage Gambling in England and Wales: A research
study among 11-16 year olds on behalf of the National Lottery
Commission, June 2011, p10. Back
Ev 180 Back
DCMS, Post-Legislative Assessment of the 2005 Gambling Act,
October 2011, p11 Back
Ev 180 Back
Ev 186 and DCMS, Post-Legislative Assessment of the 2005 Gambling
Act, October 2011, p11 Back
Gambling Commission: Press Release (2010) Monitoring under-age
gambling in adult gaming centres. Back
See text box on p4 Back
Ev 214, 210, 268, 193, and Ev W 71 Back
Ev 214 Back
Impact of high-stake, high-prize gaming machines on problem
gambling, 2008 Contributing Ed. Professor Mark Griffiths.
See also Ev 210 and Ev 193 Back
Gambling Review Report, p129, paras 23.1 and23.4. Local
authorities were responsible for licensing and enforcement for
the remainder of gaming machines. Back
Categories of Gaming Machines Regulations, S.I. 2007/2158, as
amended by Categories of Gaming Machines(Amendment) Regulations,
S.I. 2009/1502 Back
HL Deb, 28 March 2007, Col 1693 Back
Q 749 Back
Ev 193 Back
Ev W 25 Back
Ev 210 Back
Ev 158 Back
Q 599, see also Ev W 10 Back
Q 585 Back
Ev W 10 Back
Fixed Odds Betting Terminals and Code of Practice: A report
for the Association of British Bookmakers Limited, April 2005,
HC Deb 15 September 2004 col 1591W, see also Fixed Odds
Betting Terminals and Code of Practice: A report for the Association
of British Bookmakers Limited, April 2005, p1 Back
Qq 585 and 596 Back
Ev 193 Back
Ev 173 Back
Joint Committee on the Draft Gambling Bill, Session 2003-4, HC
139-I, HL Paper 63-I, para 492 Back
Q 30 Back
Q 29 Back
Q 30 Back
Q 80 Back
Q 772 Back
HC Deb, 1 November 2004, Col.38. Back
Q 599 Back
Ev 186 Back
Ev 270 Back
Ev 210, Ev W 93, Ev 255 Back
Gambling Review Report, July 2001 Back
Ev W 93, 78, Ev 10, Ev 186 Back
Ev W 13, see also: Ev W 40, Ev W 71 Back
Ev W 93 Back
Ev W 25 Back
Q 123, Ev 152, see also Ev 231 Back
Q 758 Back
Q 758 Back
Ev 217 Back
Q 278 Back
Ev W 44, Ev W 06 Back
Q 207, see also Q 204 Back
In 2008 bingo clubs had their allowance for B3 machines increased
from four to eight. After a further review in 2010 the stake limit
for B3 machines increased (from £1 to £2) and the B3
allowance for bingo clubs and adult gaming centres was increased
to 20% of their total machine numbers. Back
Ev W 17 Back
Q 837 Back
Q 837 Back
Ev 152, 186 Back
Gambling Commission: A medium to long-term programme of research
for investigating gaming machines in Great Britain: Recommendations
from international and British expert panels, 2009 Back
Q 767 Back
Ev 231; see also Ev 152 Back
Ev 152 Back
Ev 180 Back
Ev 161 Back
Q 656 Back
Gambling Commission: Industry Statistics 2008-2011, p15 Back
Ev 283 Back
Ev W 10, see also: Gambling and Debt Pathfinder Study,
October 2009, Carolyn Downs and Ryan Woolrych, p122 Back
Gambling and Debt Pathfinder Study, October 2009, Carolyn
Downs and Ryan Woolrych, p122 Back
Ev 268, 193 Back
Ev 255 Back
Ev 185 Back
Ev 165 Back
Ev 165, 167, Ev W 80 Back
Ev W 80 Back
Ev W 139 Back
Ev 165 Back
Ev W 139 Back
Responsible Gabling Strategy Board: Third Annual Statement, November
2011, p21 Back
Ev 173, see also Ev 80 Back
Ev W 25 Back
Ev 255 Back
Ev 283 Back