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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