Gambling (Licensing and Advertising) Bill

Supplementary written evidence from The National Casino Forum (GB 12)

The National Casio Forum (NCF) represents 90% of British bricks and mortar casinos. NCF is seeking an amendment to the Gambling (Advertising and Licensing) Bill 2012 to permit UK terrestrial casinos to be able to offer remote gambling through computer terminals in UK casinos. On Monday 11th November the National NCF submitted written evidence to the committee in support of its request. Mr Roy Ramm gave oral evidence to the Bill Scrutiny Committee on Tuesday 12 th November of behalf of NCF.

It is important to emphasise that NCF’s proposal is not a significant change to what casinos are currently permitted in terms of the provision of computers with internet access.

The debate has been distorted by the perception that a dedicated internet linked computer is entirely synonymous with a category A machine and that the industry is seeking these additional products "by the back door" to create what has been referred to as "machine sheds". That is simply not the case.

The NCF proposal would not bring about a fundamental change to the character of British casinos or create an imbalance between table gaming and other forms of gambling.

During the course of the committee’s examination of the NCF submissions and in our subsequent discussions with officials it has become clear that the NCF needs to present further evidence to clarify:

· What we are currently permitted to do,

· The impact of the proposed amendment and

· The measures to protect the public.

Currently permitted

· We are permitted to provide computers, laptops or i-Pads with open internet access. These facilities are usually provided in what are, essentially, "internet café" or "business lounge" style areas.

· We are permitted to advertise our on-line products in our casinos, but importantly we cannot indicate that the product is available from any internet linked computer within the casino or advertise our on-line site on or around an actual internet access computer.

· We are permitted to use posters, tent cards, video screens, employee t-shirts etc. and are also permitted to register our casino customers for our on-line gaming products but we cannot allow them to play on-line in the casino.

The impact of the proposed amendment

· We would, as now, provide computers, laptops and i-Pads, however terminals might have a default home page being the on-line website of the casino operator concerned.

· The computers would be in fixed positions. This is for practical reasons such as the need for a power source, to allow CCTV surveillance and monitoring and to prevent customers removing them.

· Computers would be offered as desktop or laptop devices on tables or plinths, as "an i-Pad on a stick" (plinth) or as tablets attached to chairs.

· The computers would not look like any other gaming machine; they would look like PCs, tablets or any other internet access device.

· The computer terminals will not have cash boxes and they will not be played using cash.

· The computer terminals would not be located in the ‘non-gaming areas’.

· The stakes and prizes available in the casino would be precisely the same as those available outside the premises. The stakes, prizes and how the games are played must be consistent to ensure that customers, all of whom must have accounts, are receiving consistent terms and conditions wherever they access their accounts.

· The facility would also allow customers to play in poker competitions or individual games, perhaps with other players in the club, but principally to play on-line in competitions. Players would be able to play from the comfort of an in-club dedicated computer rather than on their mobile phones, as they might now.

· The key and vital difference would be the ability to place branding and advertising on or around the computers, specifically indicating that they could be used to access the company’s on-line gambling.

· The Secretary of State could restrict the number of devices to be made available.

· The amendment will not affect how the stake and prize limits function within the on-line environment.

Measures to protect the public

· We have consistently said that all the measures currently applicable to on-line sites would be overlaid with additional measures that can only be provided in a regulated environment.

· We will ensure that players are subject to our Challenge 21 regime and are over 18 years of age.

· We will ensure that players are not ‘vulnerable’ within the meaning of Section 1 of the 2005 Act.

· Players would benefit from the industry’s commitments to player protection outlined in the Playing Safe statement of Principles.

· Access to the gambling site would only be gained by the standard protocols currently applied to on-line sites i.e. registered customer signing onto their on-line account with their name and password.

· Unregistered customers without an account would be required to register and provide all their details and ID information as currently required.

· There would be no direct or automatic access to play without the customer signing in.

· Anonymous play would not be permitted.

· Anonymous or generic log-on would not be permitted.

· There would be no mechanism for the computer to accept cash.

· Funding for play would be via non-cash deposits into the customer’s account as per any on-line transaction.

· No cash transactions would be permitted in the casino.

· A full audit trail for all transactions would apply in accordance with AML requirements.

· The area would be supervised by trained and licensed casino staff and be subject to casino surveillance measures.

· Social Responsibility information would be available in accordance with GC Guidelines.

· The terminals would be under the supervision of our trained and licensed staff and covered by casino surveillance.

· Data to facilitate research into player behaviour and to compare off and on-line gaming would be collected and our amendment would provide a unique opportunity to better understand on line play and to compare and contrast whether on-line play in a casino differs from on-line play outside a casino.

In summary, a casino would, look little different with the amendment to the way it currently appears without it. However, crucially, we could use our premises to "join up" our land-based and on-line gambling brands in the same way as other retail or leisure business. We want to be able to emulate John Lewis and many other customer focused retailers and to provide a seamless offer of our products within our land based and our on-line environments.

Through this bill, the government proposes to licence and endorse the promotion of on line gambling. We are struggling to see why, with all the above controls, it is not only acceptable but also desirable to offer the product in the most controlled of gambling environments.

We hope that the additional evidence submitted herein receives the endorsement of the committee and persuades the government to accept an amendment to the bill and to allow casinos to offer remote gambling.

November 2013