Memorandum from Bell-Fruit Games (DGB
28)
1. INTRODUCTION
1.1 Bell-Fruit Games Ltd (BFG) welcomes
the opportunity to submit written evidence to the Joint Committee.
1.2 BFG is one of the UK's leading designers
and manufacturers of amusement and gaming machines and is located
in Nottingham. We are the largest of a group of three companies
involved in the design and marketing of games, the others being
Mazooma Games and QPS, and both are based in Newark. This year
BFG have manufactured about 27,000 machines for the UK and overseas
markets, with a sales turnover of about £45 million. We employ
275 workers at the Nottingham facility and a further 56 at Newark.
The business was established in the mid-sixties and many of our
employees are long serving, with a significant proportion having
over 25 years' service with the company.
2. RESPONSE
2.1 BFG embraces gambling reform and welcomes
a replacement for the 1968 Act, recognising the need for legislation
that reflects gambling now being a part of the mainstream leisure
expectation in the UK and change in technological environment.
However, we are concerned about some of the detail.
2.2 Our response focuses on those areas
of greatest concern to our business, our employees and our customers.
3. CONCERNS
3.1 Pub Machine Numbers—We believe
that the government is right in its view that machines which are
currently known as AWP (but to become category C under the new
Bill) should only be allowed in premises to which access by children
is either not permitted or controlled; however, children are generally
controlled and accompanied by an adult in the licensed house environment.
We also agree to retaining three machines which are currently
known as Jackpot (but to become category B under the new Bill)
in clubs, to which children are not denied access but again are
generally controlled and accompanied. Our concern is that such
inconsistency could result in the pub customer being disadvantaged.
3.2 Furthermore, limiting the number of
category C machines in pubs to two by right will create a mountain
of post-Bill bureaucracy as some 11,000 pubs currently having
two to four machines or more apply for special permits.
3.3 Restricting machine numbers per pub
to two will result in a dramatic decline in the pub machine market
leading to a reduction in development investment and innovation,
consequently preventing the proliferation of new creative product
and market development appealing to a wider pub user base.
3.4 Whilst the average machine density in
pubs may currently be just below two, taking into account the
many small and rural licensed houses that have one or no machines,
the vast majority of larger houses currently have more than two
and in many cases five.
3.5 We agree with and support the British
Beer and Pub Association (BBPA) in their campaign to have the
Bill allow a minimum of four machines as a right in licensed premises.
3.6 Pub Machine Guidelines for Siting—At
present there are no agreed guidelines. There is no evidence of
any problems existing that should cause pub customers to be disadvantaged
by restricting the siting of machines in pubs.
3.7 Australian Experience—There has
been much reference made to the rise in problem gambling following
gambling reform in Australia. It should be noted that gaming machines
with much higher stakes and prizes (the same as casinos) than
those proposed in the UK are available in hotels and clubs in
Australia. We believe that low stake low prize machines outside
premises for over 18s will not lead to the problems as seen in
Australia.
3.8 Fixed Odds Betting Machines (FOBMs)—In
a recent "agreement" between the British Bookmakers
Association (BBA), the DCMS and the Gaming Board, betting shops
have been granted the right to site up to four machines per shop
with stakes of up to £100 and prizes of £500. This will
result in the proliferation of FOBMs to the detriment of the low
stake/low prize AWP which will, in turn, have a significant effect
on our business, probably to the tune of a ten per cent reduction.
3.9 The new Bill should address this issue
by ensuring that FOBMs fall into the category B definition thus
providing parity, in terms of machine numbers, stakes and prizes,
with other category B machine users.
3.10 Machine Testing—We fully support
the requirements for new standards of testing for category A machines.
However, the draft Bill appears to enable change to the currently
successful testing regime of category B, C and D machines. We
are concerned that if this will be the case, the speed and effectiveness
by which new products are currently taken to market could be impaired.
4. CONCLUSION
4.1 The new Bill should not create a decline
in the low stake/low prize machine market in licensed locations
such as pubs and other licensed facilities where these machines
are ancillary but vital to revenue, to the benefit of the newly
regulated environments. There is no evidence to suggest any problem
gambling is caused by machines in the pub environment and the
product currently offers a traditional part of the pub's entertainment
proposition and is the mainstay of support for an industry employing
circa 23,000 in the UK.
December 2003
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