Memorandum submitted by RAL Holdings Limited
"A SAFE BET FOR SUCCESSMODERNISING
BRITAIN'S GAMBLING LAWS"
RAL was formerly part of the Rank Group, and
became a private company in 1996. Its principal business activity
is the operation of "all cash" gaming machines at 140
premises around the UK. These premises trade as "Quicksilver
Licensed Gaming Centres" and each unit operates around 40
"Category C Machines".* RAL employs around 700 staff
In this response to the White Paper we address
the following issues:
(i) The definition of "Adult Gaming
(ii) Linked gaming machines in an Adult Gaming
(iii) The proposed licensing of I-Gaming
in the UK and the opportunities for future taxation that this
could create if dealt with expeditiously.
(iv) Social responsibility in the gaming
(v) The establishment of a single regulatory
body for all forms of gambling in the UK.
(vi) The licensing of all gambling operators,
as individuals, in the UK.
(vii) The need for caution in the proposed
introduction of large numbers of Category A machines* in casinos,
particularly in an environment where it may be difficult to ensure
effective delivery of support to problem gamblers.
* Applying the machine classification system
proposed in section 4.11 of the White Paper.
THE DEMOGRAPHIC PROFILE OF "LICENSED
GAMING CENTRE" CUSTOMERS AS PROVIDED BY RAL'S MEMBERSHIP
DATABASE OF 50,000 REGULAR PLAYERS
The Response in Detail:
During the consultation process prior to the
publication of the Gambling Review Report, RAL hosted a visit
by Sir Alan Budd and members of the Gambling Review Body to an
RAL outlet in London. Over a two hour period it was obvious that
they were surprised at the difference between their pre-conceptions
of the "Adult Gaming Centre" and the reality of their
observations. It was clear this type of business was providing
slot machine entertainment in adult only premises for a wide cross
section of the public, demographically split 50:50 male/female
(see Annex 2).
The White Paper, in section 4.13, suggests that
Category B (*) gaming machines should only be installed in premises
that are specifically licensed for gambling: casinos, bingo clubs,
betting shops and adult gaming centres. All the aforementioned
being premises from which children are barred and which will be
brought clearly within the arrangements for licensing and inspecting
gambling premises to ensure proper adherence to regulation and
safeguards it brings. We welcome this proposal.
We recognise however that there are operators
in the UK Gaming industry who do not operate controls on access
by under 18s, or who operate with a "designated area"
within their premises featuring all Category C machines.
We feel that it is important that these operators
are not allowed to operate Category B machines and, that if they
wish to do so, they should convert their premises to "adult
only" and apply for the appropriate licence (or permit) for
an "Adult Gaming Centre".
We advocate that in any new legislation there
should be two clearly distinct types of permit available for premises
which are geared specifically for the provision of "Coin
Op entertainment"' and for simplicity, these should be called
"Permit 1" and "Permit 2".
Permit 1 should allow the operation of an unlimited
number of all Category C machines and be applied to a premises,
(not simply to an area within a premises), and should exclude
Under 18s from all parts of the premises. An important adjunct
to this type of permit should, (as proposed in the White Paper),
be parity with a LBO in the provision of four Category B machines.
This would provide a clear picture for a local authority with
regard to the type of business being conducted, and they would
understand the penalties that could be applied to the operator
if he were to transgress in any aspect of the operation of the
premises, ie to allow under 18s access.
Permit 2 should allow the operation of a "Family
Amusement Centre" such as those found predominantly at coastal
resorts but also in some large towns and cities, and also in "out
of town" shopping centres. Permit 2 premises would provide
for the operation of all types of trivial coin operated equipment
such as videos, novelty games, kiddie rides, pushers, cranes and
so on. Regulators, opinion formers, and local authority officers
would be able to clearly understand the type of business that
was being proposed in any licence application, including the proposals
for policing the "designated area" and make a decision
We strongly believe that the creation of "Permit
1" and "Permit 2" would solve the problems of definition
and allow regulators and local authorities a far clearer understanding
of what is being proposed in a licence application.
RAL are pleased that the White Paper recognises
that the "Adult Gaming Centre" provides alternate entertainment,
on the High Street, to the traditional LBO, (betting shop). The
demographic information shown at Annex 1 clearly demonstrates,
from a membership list of 50,000 players, that Adult Gaming Centres
provide a leisure gaming experience to a wide cross section of
the public and are certainly frequented by a much larger number
of women than a typical LBO. On this basis, whilst we are pleased
that it is proposed that we be allowed to operate four Category
B machines, we would like to suggest a slight variation to allow
for the fact that we are not in a position to offer the same range
of betting opportunities as a LBO. We feel that it would be relatively
easy to construct machines that provide a common jackpot of £500
on the basis of eight Category C machines to one Category A machine.
An operator could then, rather than providing one Category B machine
paying out a single prize of £500, instead provide eight
Category C machines, all playing for one common £500 prize.
In this way an Adult Gaming Centre operator could operate a maximum
of 32 (four times eight), of these machines. Linked games, where
players compete with one another for a prize, have grown in popularity
over the past three years and this proposal would be a simple
extension of this successful formula.
RAL is pleased to note that the Government has
accepted the recommendations of the Review Body in respect of
on-line gaming products. We note the comments in section 4.48
that "there is a potentially vast international market for
which gambling operators based in this country will be encouraged
Section 4.52 notes, "there is every reason
to believe that Britain can establish a reputation for itself
as a world leader in the field of on-line gambling". There
are sound commercial and social arguments to encourage the location
of I-Gaming businesses in the UK. These arguments fall into two
categories, firstly the protection of the UK
Currently it is not possible for UK companies
to set up hardware and software systems for I-Gaming on the UK
mainland, and operators, therefore, have to set up convoluted
software architecture in order to ensure that they comply with
the current regulations. The effect of this is to encourage the
UK I-Gaming punter to play on Caribbean-based web sites which
are not regulated and which are often, demonstrably, unreliable
and unfair. Naturally these offshore operators would have no truck
with UK organisations such as Gamcare who might seek an input
into the way that the business is conducted. By granting licences
to UK operators the UK, authorities and regulators would then
be able to have an input into the ways that sites are presented,
promoted and managed. This in exchange for a UK kitemark that
would indicate probity, trustworthiness, and systems that have
been checked and verified by a third party tester. This could
be further reinforced by only permitting UK-based operators to
advertise in the UK. This in turn would drive would-be punters
to these UK sites as opposed to those in other jurisdictions and
would ultimately lead to greater opportunities for taxation.
The second strand to this issue is clearly fiscal.
Many jurisdictions are now moving toward licensing I-Gaming, and
the rewards in terms of opportunities for taxation for these jurisdictions
are likely to be vast. The I-Gaming market (whether this means
Internet, Digital TV, WAP, GPRS or 3G methods of delivery), is
widely predicted to grow exponentially over the next few years
and there will clearly be many first mover advantages.
We believe therefore that I-Gaming legislation
must be disconnected from other possible new gaming legislation
as proposed by the Gambling Review report, and implemented as
quickly as possible. There is a real risk that UK plc will miss
the boat if this is not done!
In recent years RAL has been in the vanguard
of support for Gamcare, and have been able to convince the trade
association BACTA, that Gamcare notices should be displayed in
gaming machine venues across the country.
We have found that promoting social responsibility,
and in particular the work of Gamcare, to staff through posters,
leaflets and during induction training sessions, is received positively
by people joining the industry and assists in dispelling any negative
preconceptions that they might have about the gambling industry.
Clearly the same shift in attitude can be achieved with the general
public and assists in promoting the industry as an integral part
of modern day life.
The imposition of a levy to provide funds to
support the GICT (Gambling Industry Charitable Trust), would be
divisive and would, ironically, undo a lot of the good work that
has been carried out in the area of social responsibility and
gambling in recent years. It could once again set the industry
in the opposite camp to the charities. However, clear evidence
on the part of a Gaming operator not only of voluntary support
for the GICT, but also of the implementation of awareness and
support programmes, should be a clear criteria not only for the
grant of a licence but also for its renewal.
It has been suggested that a figure of approximately
£3 million is required to support the various charities and
other support organisations associated with problem gamblers.
We question this arbitrary sum and suggest that proper research
be carried out by the Gambling Industry Charitable Trust in order
to ascertain precisely what the quantum is, both for providing
support for the existing charities and also to provide funds for
We wholeheartedly support the recommendation
that a new regulatory body (the Gambling Commission), is established
and becomes responsible for the control and regulation of all
sections of the gambling, gaming and betting industry in Britain.
We believe that it will be essential that the new body be given
sufficient power and resource to properly police and regulate
an industry which will, on the back of technological change, be
evolving at an ever increasing pace. There can be no doubt that
many foreign gaming operators will see the apparent liberalisation
of the UK as an opportunity to be exploited. Strong barriers and
controls will need to be in place, (and able to be enforced),
to ensure that only those operators who are able to demonstrate
the highest levels of probity are able to obtain, and retain,
We believe that the new body should certainly
have the power to prosecute. We feel that a weakness of the Gaming
Board has been having at times to rely on the Police who do not
necessarily see an infringement of the 1968 Gaming Act as top
of their list of priorities.
We applaud the recommendation contained within
the Gambling Review Report that a new single regulatory authority
(Gambling Commission), should license all gambling operators and
key workers (s18.13). We believe that this is long overdue and
has, to a certain extent, prolonged the public misconception that
gaming is a little "shady". RAL holds a number of different
licences for the operation of gaming machines and cash bingo and
so on, and sees only positive results from requiring any operator
involved in any form of gambling, gaming or betting to present
his or her bona fides.
We believe that this licensing should, (as a
minimum), apply to all directors and senior staff within any organisation.
It should be the subjective judgement of the officers of the Gambling
Commission as to which further individuals might also be required
to be licensed.
RAL believes that this should extend down to
unit manager level providing not only an improved skill set, but
also a portable qualification that may provide the individual
with better future employment prospects.
Section 1.4 of the White Paper makes the following
point; "Experience from around the world suggests that over-enthusiastic
de-regulation can cause real social and economic problems, from
which it is hard to rein back".
Those of us who have worked in the gaming industry
in the UK for a number of years, have serious concerns as to the
social effect of allowing the unfettered introduction of Category
A(*) machines in the planned "International Casinos".
We feel that, whilst we welcome change and progress, (and it is
obvious that the UK has been held back in terms of development
over the past 10 years), nevertheless gaming machine numbers must
be firmly linked to the number of table games available. We would
draw the Committee's attention to the system in Belgium where
there is a clear link between the two. As business levels grow
during a session, and more table games are opened up, a corresponding
number of gaming machines are switched on. As business levels
then subside the corresponding numbers of gaming machines are
switched off. In this way the balance of table games to slot games
is maintained and slot games are never allowed to take precedence
over the gaming tables. We believe that this would present an
ideal control over the introduction of Category A(*) machines.
We believe that there is incontrovertible evidence
from other countries that severe social problems are likely to
arise if operators are not restricted in the number of Category
A (*) machines which may be installed in gaming venues. Convincing
arguments will no doubt be put forward to suggest that this will
not be the case, and we would simply ask that due consideration
is given to the various research documents which are available
on the subject. In addition, we are concerned that, contrary to
the arguments put forward by some casino operators, it will prove
very difficult to deliver effective support for problem gamblers
in vast "sheds" where many different forms of gambling
will be available under one roof. If there are only a few gambling
opportunities in any given venue, gambling is less anonymous which
may deter some people from excessive gambling for fear of being
seen and disapproved of. Currently other various limits to accessibility
include opening hours and conditions of entry, both of which it
is proposed be relaxed in the future and which may then impact
in a negative way on harm minimisation programmes.
THE DEMOGRAPHIC PROFILE OF "LICENSED
GAMING CENTRE" CUSTOMERS AS PROVIDED BY RAL'S MEMBERSHIP
DATABASE OF 50,000 REGULAR PLAYERS
Customer Demographic Profile
RAL Gold Card Members
Total Membership: 49,764 of which 43 per cent
female, 57 per cent male
Broken down into age groups:
|18-25||26 per cent of which 21 per cent female
||79 per cent male|
|26-35||22 per cent of which 31 per cent female
||69 per cent male|
|36-45||15 per cent of which 50 per cent female
||50 per cent male|
|46-59||13 per cent of which 65 per cent female
||35 per cent male|
|60+||12 per cent of which 73 per cent female
||27 per cent male|
No age given 12 per cent
29 April 2002