Joint Committee on the Draft Gambling Bill First Report


Further memorandum from the Rank Group Gaming Division (DGB 170)

INTRODUCTION

  This brief submission seeks to deal with reasons why the legislative change proposed allowing Casinos to offer bingo and betting should be endorsed by the Joint Committee.

  The Gambling Review Report of July 2001 (The "Budd Report") recommended that Casinos should be able to offer a mix of gambling activities, including bingo and betting.

  A "Safe Bet for Success", presented to Parliament by DCMS in March 2002, confirmed Government's intention that Casinos will be allowed to offer additional gambling products such as bingo and betting.

  The draft Gambling Bill adopts these provisions in paragraph 141 (4) [Nov 2003], or paragraph 143 (4) [Feb 2004].

PROPOSITION

  The draft Gambling Bill proposes that Casinos should be able to offer both bingo and betting products to their customers. The Rank Group Plc supports this legislative change for the reasons set out below.

SUBMISSION

Customer Choice

  Casino players who attend the most highly regulated venues, with the strictest identification and admission controls, increasingly expect a wider leisure provision than just casino table games. Within this highly controlled environment, an element of product diversity and variety, namely bingo and betting, should be allowed. This proposal mirrors the approach adopted in many overseas jurisdictions (including the Isle of Man) where bingo and betting have happily co-existed within the curtilage of a casino operation.

  Such additional provision affords the casino player a degree of respite and an element of variety from the gaming tables. A husband and wife, or group of friends, benefit from the personal freedom to share a night out at the same venue, but with the option to chose different gaming options on the same premises. Customers are capable of exercising choice and judgement.

CUSTOMER DEMAND

  Results from the British Gambling Prevalence Study (National Centre for Social Research, London, June 2000) identified that some 5% of bingo players polled gambled on Casino gaming tables. This statistic contrasts with some 20% of the national population who have ever visited a UK Casino.

  In respect of Betting, a recent survey of Victoria Casino members (Edgware Road, London) identified that some 60% of those polled would use betting facilities, if provided by the casino operator, under the current legislation.

DEMAND CRITERION/DEMAND TEST

  The Gambling Bill will abolish the demand criteria for bingo and casinos and the demand test for betting offices. In future Bingo, Casino and Betting Shops will be free to position themselves together in one location.

  Under current legislation there are a number of existing locations where under one roof both casino and bingo co-exist side by side, separated only by a party wall, and sharing joint services.

  It would be perverse, if in a single location, customers could not be afforded the protection and security of a common, controlled and safe environment to enjoy their preferred choice of activity.

HARD AND SOFT GAMING

  Concern has been raised that the mixing of casino gaming (characterised as hard gaming) and bingo (characterised as soft gaming) is not desirable.

  We would agree if it were the case that both products were to be offered in an uncontrolled poorly regulated gaming environment. This is not the case.

  However, it is clearly shown from the experience overseas, that hard and soft gaming can operate from the same shared premises without encroachment and for the convenience of players. The safeguards proposed are appropriate to cater for the different social atmospheres created within a single highly regulated and controlled casino environment.

SAFEGUARDS

Licensing

  The provision by Casino Operators of Bingo and/or Betting is subject to satisfactory determination of applications for an Operators Licence, Personal Licences and Premises Licences. For example, the competencies required to offer either bingo or betting would need to be demonstrated by the prospective operator to the satisfaction of the Gambling Commission.

  At any one of these three stages, a refusal or conditions precedent may be prescribed by either the Gambling Commission or the Local Authority to ensure that the three regulatory objectives of the Gambling Bill are met.

REGULATORY OVERSIGHT

  Casino operators are the most regulated of gaming providers with tough regulatory oversight including a highly experienced and dedicated regulatory agency with extensive powers (including those under the Regulation of Investigatory Powers Act 2000, RIPA) on-going fitness and probity checks including personal declarations and a regular programme of visits to all premises, including random Audit and Compliance tests. Failure results in fines, loss of personal licences, revocation of gaming licences and/or criminal prosecutions.

PROBLEM GAMBLING

  Admittance to Casino premises requires positive proof of identity and the further onerous requirements of "The European Money Laundering Directive", including recording of players gaming activity (win/loss). The British Casino Association has a mandatory code on problem gambling all members. The code requires that operators provide a self barring scheme, that they display posters and leaflets setting out problem gambling advice, provide telephone numbers of agencies for help and support, undertake product risk assessments, maintain a problem gambling awareness programme for gaming staff and take a responsible approach to casino advertising.

CONCLUSION

  The policy objective of modernising gaming legislation, whilst maintaining the highest standards of regulation within casinos, but offering increased customer choice is achieved by the totality of the Governments proposals.

  We urge the Committee to endorse this specific change.

March 2004


 
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