Memorandum from Gamestec Leisure Ltd (DGB
65)
1. INTRODUCTION
1.1 Gamestec Leisure Ltd welcomes the opportunity
to present our opinions on the content of the proposed Gambling
Bill currently being examined by the Joint Scrutiny Committee.
1.2 Gamestec Leisure Ltd, is one of the
UK's largest operators of Gaming and Amusement equipment with
some 39,000 pieces of equipment being serviced by a labour force
of 1,200.
Our customers are active in a very broad range
of mainstream leisure activities including: Public Houses, other
licensed premises, Members Clubs, Licensed Betting Offices, Bingo
Halls, Casinos, Bowling, Family Entertainment Centres and many
other leisure facilities.
Our operation, whilst having its Head Office
in Leeds, covers the whole of the Great Britain including Northern
Ireland. We have some 17 depots around the country, which provide
a full range of services to our customers.
2. THE GAMBLING
BILL
2.1 Gamestec Leisure Ltd welcomes the introduction
of a new legislative framework for the industry as a whole. With
some 35 years now having passed since the introduction of the
1968 Gaming Act, we feel that the Bill has the opportunity of
reflecting the social, economic and technological changes that
have occurred since 1968.
On the whole, we believe that the new Bill has
in fact addressed many of the issues relating to the aforementioned
changes, however, we do have some serious concerns regarding the
apparent disproportionate advantages that appear to be targeted
at new entrants to the UK Gambling Industry. Whilst supporting
the general principles that have been applied, we feel that unjustifiable
restrictions are being placed on traditional areas of leisure
within the market place, creating an environment that does not
support the stated aims contained within "A Safe Bet for
Success" for the new legislative framework to be " in
the interests of fairness and efficiency".
2.2 Machines in public houses are a key
area of activity for our industry, and one that has for many years
been operated in a well-run and well-regulated environment, with
no empirical evidence of any social problems being created for
the vulnerable in our society. The proposed restriction to two
machines by right does not appear to reflect either fairness or
efficiency when one takes into consideration the current status
in the UK of the public house sector.
The public house market is in itself extremely
variable, ranging from small rural and community pubs with only
one or possibly no machines, to large city centre venues covering
several thousand square feet and catering to large volumes of
customers. In these larger venues, Magistrates have seen fit to
grant permits for several machines to meet the demand of customers
who gain amusement and entertainment from the AWP product. Whilst
the proposed Bill does allow for application to increase the number
above the two as a right, it will create an instant application
from some 11,000 plus premises that will wish to retain the rights
already granted.
An increase in the maximum number of machines
as a right to four would remove the administrative burden. Economics
and physical restrictions on available space would prevent any
proliferation from the levels currently experienced. This would
also allow for future product and market development in offering
choice to a wider group of customers.
2.3 The limitation of machines in public
houses to two as a right, does not seem to reflect the accepted
machine levels in members clubs where, they have the facility
to site three machines as a right, with a significantly higher
prize level. A situation that we agree with and is to continue
under the new Bill and one that we fully endorse.
2.4 Recent changes to the machine types
contained within the licensed betting environment, whilst also
being generally welcomed, have had a very negative impact on the
UK manufacturing and machine operating industry. The recent changes
to the proposals in the Bill where the four machines of up to
£500 jackpot with a £1 stake have been reconstructed
to include FOBMs (Fixed Odds Betting Machines) with Jackpots of
£500 and stakes of up to £100 has led to an immediate
reduction in the level of £25.30p stake machines. This has
had the immediate impact of reducing the UK replacement machine
market by between ten and fifteen per cent.
Whilst understanding and agreeing with the need
for regulatory action, we would welcome a change that would create
a more equal opportunity for UK manufacturers and operators to
compete with this new product entrant, mainly from overseas suppliers.
We believe this could be accommodated in a review of the proposed
stakes and prize levels.
2.5 We welcome the proposed changes to the
Gambling legislation that creates increased opportunities for
both the Casino and Bingo sectors but, would ask that consideration
be given to the impact that a large proliferation of edge of town
gambling establishments, offering unlimited stake and prize machines,
would have on the traditional products, that under current proposals
will not be offering an attractive option for the player.
Whilst the effects of the current proposals
outlined above, will be a reduction in manufacturing capacity
and a reduced business opportunity for the traditional leisure
operators within the mainstream leisure market, relatively small
changes to permitted machines in public houses to remain at the
current levels, by giving four machines as a right and creation
of a more equitable market in the Licensed Betting Office and
Adult Gaming sector through a stake and prize review, would help
to stabilise what is and will remain, a well-regulated and professionally
run sector of the industry where levels of negative social impact
have traditionally remained at a very low level.
3. GRANDFATHER
RIGHTS
3.1 Gamestec welcome the proposed use of
Grandfather rights but, would seek further clarification that
these rights will not be automatically rescinded by changes or
renewals of licenses that may be imposed by the introduction of
Local Authority control.
4. SOCIAL IMPACT
4.1 Gamestec supports the need for a regulatory
system that provides protection for the vulnerable. The evidence
provided from the proliferation study demonstrated that the current
level of problem gambling in the UK is at an extremely low level
(0.6 per cent to 0.8 per cent). We believe this is a result of
the well managed and regulated industry we have in the UK, where
the vast majority of machines are located in premises that operate
to very high standards.
Another key factor is the differentiation of
machines located in the majority of UK outlets that have relatively
low levels of stake and prize and have games that provide for
a high degree of amusement and entertainment whilst remaining
games of chance.
4.2 In contrast to the UK much has been
said about the Australian Market. Gamestec believe this to be
a false comparison. Unlike the UK where machine styles and stakes
and prizes are very distinctly differentiated between pub machines
and club machines and those found in Casinos, the Australian model
has allowed the sitting of larger numbers of high stake/high prize
machines in both Casinos, Clubs and Pubs alike.
4.3 Gamestec fully supports the maintenance
of the GICT and believes that contributions to this should be
part of the fit and proper test.
December 2003
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