Select Committee on Culture, Media and Sport Memoranda


Memorandum submitted by Coral Eurobet


  Coral Eurobet are pleased to provide written evidence to the Culture, Media and Sport Committee of the House of Commons, relating to the proposed changes to gambling legislation—"A safe bet for success".

  Coral Eurobet support the principles of the recommendations:

    —  To simplify the regulation of gambling.

    —  To extend choice for adult gamblers.

    —  To ensure that gambling is conducted honestly and the Industry is crime free.

    —  To ensure that consumers are protected.

    —  To ensure that there is protection for children and the vulnerable.

  Our response will cover the issues which specifically concern the changes to regulation of gaming machines, the casino industry and the potential impact of the Government's proposals on the National Lottery. In addition we would wish to take the opportunity to comment on certain areas that impact, in a broader sense, beyond the Committee's initial terms of reference.

  You will have received a detailed response from the Betting Office Licensees Association (BOLA). Coral Eurobet endorse the comments contained within BOLA's submission.


  Coral Eurobet welcomes the Government's proposal to permit betting shops to site a mixture of four all-cash and jackpot machines.

  We support BOLA's comments in that the introduction of jackpot machines into betting shops is long overdue. Given that recent deregulation has allowed bingo clubs to mix all cash and jackpot machines, Coral Eurobet believe that the proposed jackpot machines should be introduced through secondary legislation as soon as possible.

  In our view the above action would not disturb the balance of the gaming machine regime outlined in the Government's proposals.

  Coral Eurobet welcomes the Government's confirmation that the "Gaming Machines—Methods of Payment" proposals contained in the Home Office Consultation Paper (published March, 2001), is to be progressed over the coming months. Clarification of the exact timetable would be most welcome.

  However, there is one element of the gaming machine proposals that gives us cause for major concern. Paragraph 4.22, referring to Fixed Odds Betting Terminals, states an intention to draft new legislation in such a way that betting terminals are controlled in the same way as gaming machines, eg outside of casinos, the prize limit for gaming machines will be £500. In our case the Fixed Odds Betting Terminal is simply an alternative to the manual process of placing a bet with a cashier. Our current limit on winnings ranges up to £500k, dependent on the product.

  If the proposal is implemented as drawn this will result in a significant reduction in consumer choice, whilst the impact on innovation and development within the Industry would be stultifying with a "ripple" effect on manufacturers,suppliers and software designers.

  Coral Eurobet views the proposal as a retrograde step for betting shops.

  Betting shops have been legally accepting bets on the outcome of random numbers events since 1996.

  Automated betting terminals (often described as fixed odds betting terminals) were introduced into Coral shops in 1999.

  Significant investment from bookmakers and suppliers has been made after having taken legal advice and having consulted with the Gaming Board in 1999.

  There are now some 2,500 of these terminals sited in betting shops throughout the UK.

  This product range is now an integral part of our business and is responsible for a significant portion of bookmakers profits, as well as providing income streams and employment for terminal suppliers and software developers.

  The Government, in October 2001, introduced a new tax regime for betting (Gross Profit Tax). The new regime was introduced in order to give UK business the ability to compete globally, thereby "growing the cake"—of which the Government has a 15 per cent take. Paragraph 4.22 is a threat to the Government's future income, as well as the industry's future income.

  The above are matters that we expect to discuss further with DCMS in the near future and one upon which we would want to make further representations as things become clearer.


  This is not a specialist area for Coral Eurobet, therefore we have not commented beyond the fact that we support the Government's principle of extending choice to adult gamblers in well regulated environments.


  Coral Eurobet support the measures outlined in the Government's proposals.


  Coral Eurobet have made a significant, voluntary contribution to the Gambling Trust and will continue to support the efforts of organisations such as Gamcare and Gordon House.


  Coral Eurobet support the comments made in BOLA's submission in that there is little or no evidence to suppose that the proposed deregulation will adversely affect the National Lottery.

  However, evidence is available regarding the impact on the Irish Lottery following the introduction of side betting in Irish betting shops.

  This evidence, conducted by Mori and Europe Economics, has been supplied to the Committee by BOLA and demonstrates that National Lotteries and side betting can compliment one another, rather than pose a threat to each other.

  Given the original terms of reference of the Gambling Review Body, namely:

    —  Extending adult choice.

    —  Keeping gambling crime free.

    —  Protection for children/vulnerable

  Coral Eurobet is disappointed and surprised that side betting on the National Lottery was rejected by the Government.

  Side betting on the National Lottery already takes place in offices, factories and other venues. This activity is currently relatively harmless, (eg the school fund raising event having a sweep on the outcome of the bonus ball).

  In our view, it is absurd that well regulated, licensed betting shops are not allowed to take side bets when there is such an obvious demand and that demand is currently being met illegally, and with no gross profit tax payments going to the Government.


  Gambling Commission—a single regulatory body has appeal on the grounds of neatness. However, we feel that the diversity of gambling is such that there would be a danger of the Commission becoming unwieldy, resulting in an expensive, bureaucratic body.

  The range of powers afforded to the Commission appear limitless, therefore we would wish to seek further clarification on this issue as the proposals are progressed.

  Licensing of Individuals—we strongly support rigorous licensing procedures. We support a more demanding "fit and proper" criteria which might include criminal record checks, financial checks and testing for knowledge and competence at Senior Executive level.

  We do believe that individual licensing should not extend to the industry's 15,000 Shop Managers, who are essentially processors or retailers of betting transactions and we are pleased that the issue is to be further reviewed.

  Licensing of Premises—we are unable to see the advantages of the proposal over that which currently exists. The existing system, operating through the Magistrates Courts, functions effectively and is conducted in an environment where all interested parties, including the public can attend and make their views known.

  The proposal that it be dealt with by the Local Authorities as an administrative process, in circumstances where they are already hard pressed to meet all their current statutory requirements, seems to add little to efficiency or local democracy.

  Demand Criteria—we understand that it is the Government's intention to produce national criteria to provide clear guidelines for Local Authorities.

  We remain of the view that those criteria should have some regard to current provision.

  We also believe that the process should be more rigorous, in as much as applications should be supported by:

    —  Planning consent

    —  Evidence of some holding interest in the property.

    —  Evidence of resource to complete the project.

    —  Applicant should already be Licensed as "fit and proper."

  Coral would be pleased to assist in helping to establish the new national criteria.

  Opening Hours—the Gambling Review provides an opportunity to remove a current anomaly with regards to betting shop opening hours.

  Betting shops are able to open from 7.30 am until 10.00 pm in the summer months—6.30 pm closing is compulsory in the winter months.

  Given the continuing globalisation of sport and the increase in winter televised sport, including horseracing after 6.30 pm, it seems appropriate to allow the opening hours to be extended, during the winter months, where there is demand for the facility.

  Stadia—Coral Eurobet own two greyhound stadia (Romford and Hove) and would welcome the opportunity to assist in the development of guidelines for gaming machine licensing within stadia.

  Operating as a gambling venue, our view is that greyhound stadia should be afforded the same entitlement as other gambling venues,(eg bingo where a mixture of all cash machines and four jackpot machines can be sited).

  Coral also welcomes the Government's suggestion that greyhound stadia should be considered as appropriate venues for casinos. In addition, we are pleased that further consultation is to take place as to how future licensing arrangements can allow operators of greyhound tracks to make more efficient use of their facilities on non-race days.

  Coral similarly supports off-course access to greyhound totalisators and the removal of the rules restricting charges for the entry of bookmakers to greyhound tracks.

3 May 2002

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