Select Committee on Culture, Media and Sport Memoranda


Memorandum submitted by the Betting Office Licensees Association (BOLA)


  The Betting Office Licensees Association (BOLA) is the off-course betting industry's leading trade body. BOLA has both large and small members, including all of the leading British bookmaking companies, and represents some 5,500 of the country's 8,100 licensed betting offices.

  The Culture, Media and Sport Committee (the Committee) has announced its intention to examine the Government's response to the Report of the Gambling Review Body (the Review Body) published in July 2001. The Committee has said that its initial inquiry will focus on changes to regulation of gaming machines and the casino industry, and the potential impact of the Government's proposals on the National Lottery.

  Although BOLA is primarily concerned with licensed betting offices, the various industries that comprise the overall gambling sector have sufficient in common for the Association to have views on most of the matters the Committee has said it intends to examine. For example, all gambling operations considered by the Review Body rely on gaming machines of one type or another. This paper does not, however, wish to comment on the proposals that relate only to casinos.

  In general, BOLA has welcomed the Government's response to the Gambling Review Body's Report. The Review is the most comprehensive study of gambling in this country since the 1978 Royal Commission and the changes the Government has said it intends to make will have a major impact, both socially and on this country's highly-regarded and successful gambling industry.

  No responsible operator or representative body will disagree with the Review Body's objectives of keeping gambling crime free, ensuring that the customer is fairly treated, and protecting the minority for whom gambling can be a problem. In addition to social considerations, the industry is aware that its high international standing is founded on these principles. Thus there is wide recognition that any change must be socially as well as commercially correct.

  In BOLA's view, however, a small number of the proposals outlined in the Government response document "A Safe Bet for Success—Modernising Britain's Gambling Laws" are either of questionable wisdom, or should be implemented in advance of primary legislation. The issues of most interest to BOLA are:

    —  the introduction of Jackpot Machines in Licensed Betting Offices.

    —  rejection of the Review Body's recommendation that side betting be permitted on the National Lottery.

    —  transfer of premise licensing from magistrates to local authorities.

    —  abolition of the demand test

    —  the appointment of a Charitable Trust to help fund organisations involved in the treatment of problem gambling


  The Committee has requested comment on the impact of the proposals on the suppliers, lessors and users of gaming machines. In general, BOLA supports the machine regime outlined in the Government's response on the grounds that it will help operators and their suppliers meet customer expectations of a modern leisure industry.

  In particular, the betting industry is pleased that its case for machines with a maximum prize appropriate to the betting office environment has been recognised. One of the main customer criticisms of the Amusement with Prizes (AWP) machines currently allowed in betting offices is that the maximum prize of £25 is an anomaly in premises where far larger sums of money can be won or lost. Thus the proposed four Jackpot machines (or a mix of Jackpot and AWP machines) with a maximum prize of £500 will be welcomed by all bookmakers.

  As betting offices have a good record of adhering to the over 18 age rule, and as the adults who frequent them do so with the prime intention of gambling, this change will not jeopardise the safeguards the Government and the industry are so keen to maintain.

  BOLA's only reservation about the introduction of Jackpot machines is that, as matters stand, it could be three or more years before betting offices are able to install them. Prior to the announcement of the Gambling Review, the Government had agreed in principle to the introduction of a higher value slot machine in LBOs. Had the Review not taken place, it is reasonable to assume that this type of machine would already be available in betting offices.

  Under these circumstances, the betting industry believes that it will be unfair if this already overdue reform has to wait for primary legislation, particularly as changes to the machine regime in bingo halls have recently been implemented. Accordingly, we seek the support of the Committee for our request that the proposed Jackpot machines be introduced as early as possible through secondary legislation.

  There is one aspect of the Government's apparent intentions on machines with which BOLA strongly disagrees. At present, there are an estimated 2,000 machines, described in "A Safe Bet?" (paragraph 4.22) as fixed-odds machines in betting offices across the country.

  These machines are, in fact, no more than betting terminals. They offer fixed odds betting on numbers' and, in effect, they fulfil the same function as a cashier accepting a numbers' bet over the counter. They meet the criteria of providing a betting rather than a gaming opportunity by offering odds about future events which take place at a central location. This means that, unlike gaming machines, these machines have no influence over the result of the event. As they already offer prizes substantially higher than the £500 Jackpot limit, which BOLA is happy to accept in the context of gaming, it would be a retrograde step for them to subject to this maximum. This is a matter that BOLA intends to take up with DCMS.


  The legislation which brought the National Lottery into being in 1995 specifically prohibits bookmakers from taking side bets on the Lottery numbers. The arguments for and against this embargo have been well rehearsed over the years, but whenever the issue has come under serious scrutiny the outcome has been a recommendation in favour of side betting being allowed. For example, the Culture, Media and Sports Committee has twice (on the first occasion as the National Heritage Select Committee) recommended that this ban be lifted. Recently, the All Party Gambling Group interviewed representatives of BOLA and Camelot and came to the same conclusion.

  Although the National Lottery itself was outside its remit, the Gambling Review Body also recommended that betting on the Lottery should be allowed. In "A Safe Bet?" the Government concedes that the evidence suggests that the introduction of side betting on the Irish Lottery coincided with, rather than contributed to, a fall in Irish Lottery sales. It also comments that the extent of the risk that side betting here would have a direct impact on National Lottery sales is uncertain. Nevertheless, the Review Body's recommendation has been rejected, thus maintaining a situation in which the National Lottery is the only future event in the betting industry's 40 year history on which it is illegal to accept bets.

  Given the Committee's past interest in this issue, it seems unnecessary to reiterate in full the arguments in favour of side betting. However, BOLA has submitted to the Government detailed research conducted by Mori and Europe Economics which shows that side betting would be unlikely to damage the National Lottery and could, in fact, complement it. A copy of this research is being forwarded under separate cover.


  The decision to transfer responsibility for the licensing of gambling premises from magistrates to local authorities is difficult to understand. No substantial reason was given by the Review Body for this recommendation, which the Government has endorsed in spite of what "A Safe Bet?" described as various concerns raised during the consultation exercise about the ability of local authorities to take on an enhanced role.

  The Government's reason for accepting this recommendation is that it favours local authorities having responsibility for local licensing matters because this will enable people to have a say in decisions that affect their lives. In order to avoid some of the anomalies that might otherwise occur the Government envisages the proposed Gambling Commission issuing guidance and advice which local authorities would be obliged to take account of. It has also identified a need for clear statutory criteria against which all licensing decision will be made.

  While the measures envisaged by the Government go some way towards addressing the industry's concerns, they do not change the fact that local politicians, who may have different pressures from area to area and whose identities and affiliations can be subject to radical change, could be open to influence in a way that magistrates are not.

  In BOLA's opinion this proposal appears, at best, unlikely to bring any benefit. It smacks of change for the sake of it, while the industry has confidence in the present system, which it would like to see retained.


  Though agreeing with the Review Body on the need to stimulate competition and improve customer choice, it is important that regulation remains sufficiently robust to ensure that the British industry's reputation for integrity is not damaged by over-adherence to these aims. For example, it seems to us that there is an anomaly in expressing concern about problem gambling and, at the same time, recommending changes which, as the Review Body's has conceded, are likely to increase the number of problem gamblers.

  The measure most likely to cause an escalation in problem gambling is abolition of the demand test. By recognising that the incidence of problem gambling in the UK is lower than in other comparable countries and, at the same time, recommending a change that could lead to a substantial rise in the number of outlets the Review Body appears guilty of contradictory thinking. It is, therefore, disappointing that the Government apparently has failed to recognise this threat to its social objectives. Before agreeing that the demand criteria should be abolished, the Committee may wish to satisfy itself on whether this would be consistent with its wider and, we would argue, more important social policy objectives.


  It seems to BOLA that there is an irony in the proposal that the industry should meet the cost of treating the increase in problem gambling that may occur if the demand test is abolished.

  This comment should not be taken as an indication, however, that the betting industry is not prepared to play a full part, along with Government, other gambling activities and, as we believe should be the case, the National Health Service, in addressing a problem which may be less severe than in other comparable countries, but which still should not be ignored.

  As evidence of this commitment, BOLA played a leading part in establishing the Gambling Industry Charitable Trust, which is already raising and distributing funds, with organisations such as GamCare and Gordon House benefiting from this activity. Both BOLA and individual members have contributed to the Fund Trust, which we believe is a good example of self regulation and enlightened self help, and we look forward to continuing to do so.

30 April 2002

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