The Gaming & Leisure Association of Ireland
Presentation to the Oireachtas Committee on Justice, Defence and Equality on the Heads of the Gambling Control Bill (2013)
Chairman and members of the Committee, thank you for the invitation to appear before you today to outline the GLAI’s recommendations and observations on the Heads of the Gambling Control Bill.
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The Gaming and Leisure Association of Ireland is a trade association made up of nine Private Member Gaming Clubs and Online Operators. Our members have all signed up to a voluntary Code of Practice, maintain the best available consumer protection standards, and work on an on-going and positive basis with anti-money laundering authorities, problem gambling experts, and An Garda Siochána.
- Our members enforce strict age verification mechanisms, undertake customer due diligence and player tracking;
- Our staff are trained to implement responsible gambling policies and identify problem gambling, and to offer self-help information to customers when necessary;
- Private Member Card Clubs are deemed ‘designated bodies’ under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 and as such are obliged to register with the Anti-Money Laundering Unit in the Department of Justice, and must appoint a money laundering reporting officer;
The GLA has developed our own Responsible Gambling guidelines and literature which shows our commitment to providing our casino services within our communities in a responsible and sustainable manner. I would be happy to circulate this to the Committee if you think it would be helpful to your work.
For the last number of years the GLAI has worked with Government to achieve and implement a workable regulatory regime for our sector. Existing legislation is not fit
for purpose and major regulatory gaps exist. Given that gambling services can
now be accessed on a 24/7 basis via the internet (on computers, tablets and smart phones) we believe that prohibition as a regulatory tool is no longer tenable.
Accordingly, there is a clear need for a fully regulated gambling sector in Ireland and we welcome the parameters around which the proposed legislation is seeking to structure our industry.
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The legislation before us has the potential to put in place a strong legal framework and with the right adjustments, will allow for responsible growth in the form of jobs and Exchequer contributions, as well as curtail criminality in the sector and protect the most vulnerable from any risks associated with gambling.
With a well-regulated and sustainable operating environment in place, we believe there is the potential to create a further 500 jobs in the casino industry over a short period of time; the possibility of generating heretofore untapped tourism streams; and the opportunity to provide gambling in a safe, secure and sophisticated environment.
Based on our working knowledge of the industry, and drawing upon the experience of other regulated jurisdictions, we would like to make the following recommendations. I would then invite any questions about both the current sector and its future potential.
I. A transitional arrangement must be put in place for existing Private Member Gaming Clubs so as to allow them to continue to operate and plan for future operations before, during and after the legislation and licencing process is put in place.
II. We welcome the proposed creation of the OGCI, but recommend that this
of political interference. Accordingly, ‘sole authority for the licensing of gambling’ and ‘exclusive authority to grant, renew, revoke and revise any license’ should rest with a regulator with an expertise in the industry, rather than the Minister of the day. This regulator must also be supported by adequate and effective enforcement mechanisms that will underpin this legislation from day one.
III. As profit margins for casino operators are far lower than many assume, the proposed duration for a casino licence of 10 years needs to be lengthened
to 15 years so as to enable operators to secure a return on the initial
investment required to establish a casino.
IV. There is a very modest limit proposed on gaming machines in casinos – 15 gaming tables and 25 machines. Currently there are approximately 5,600 gaming machines in 57 licensed gaming arcades around the country, with approximately an additional 20,000 in unlicensed venues. Gaming machines are popular, but to make them commercially viable a ratio of 2:1 will limit operators to higher stakes machines. A higher ratio of 5:1 will encourage operators to provide lower stakes machines also. Therefore, the ‘multiplier’ regarding the number of gaming machines permitted in a licenced casino should be increased from 2 to 5. We estimate that such an increase would still ensure that less than 1% of the gaming machine population post regulation would be housed in licenced casino venues.
V. An appropriate taxation level for all forms of gambling is a key component to the success of this regulation, in order to prevent the proliferation of black market operators and to provide business continuity to those of us operating compliant and regulated clubs. Equally, a taxation structure is required to facilitate the establishment of smaller venues in less populated areas.
VI. All gambling services distribution methods (on or offline; casino; slot machines or sports betting), must be treated in an equitable manner with
respect to regulation, licensing conditions and fees, taxation, player protection and supervision.
VII. The proposed restriction on opening hours for casinos must be amended in recognition that land-based casino operators compete directly with their 24/7 online competitors.
VIII. We welcome the provision for alcohol licences in casinos, but recommend that the same restrictions should also apply to other gambling service providers.
IX. Rules applying to advertising and gambling should apply to all sectors equally.
X. And finally, remote gambling should be established in a manner that incentivises online operators to establish in Ireland, thereby creating a ‘Hub’ similar to that in Malta and the Isle of Man, and potentially creating up to 5,000 jobs.
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In conclusion, the GLAI is very grateful for the opportunity to appear before the Committee today, and grateful for your time in considering the points we have made. We look forward to working with you, and Government, in the coming months and years to implement workable, long-term legislation to regulate an industry long-in-existence in this country and crying out for sensible reform.
Paddy Power plc
Presentation to the Joint Committee on Justice, Defence and Equality 2 October 2013
1. Good afternoon Chairman and members of the Committee. My name is David Johnston and I am the Group General Counsel of Paddy Power plc. I’m joined today by my colleague
Catherine Colloms who is our Director of Corporate Affairs. We’d like to thank the Committee for the invitation to speak with you this afternoon.
2. Paddy Power is one of the world’s best known sports betting and gaming brands. We are headquartered in Clonskeagh, Dublin and listed on both the Irish and London Stock
Exchanges. We employ over 4,100 people globally with 2,338 employees currently based in Ireland and contribute €70 million per annum in taxes to the Irish Exchequer.
3. We hold gambling licences in Ireland, Northern Ireland, Great Britain, Italy, Isle of Man, Australia, British Columbia and Nevada. This affords us with what we would consider a unique position in an Irish context in relation to our knowledge and understanding of regulatory regimes and gambling regulation worldwide.
4. Paddy Power welcomes the publication of the General Scheme for the Gambling Control Bill 2013 as a first step to creating a modern, regulated environment for gambling in Ireland. We support the bulk of the provisions of the General Scheme although there are some areas we feel could benefit from further clarity in any future draft legislation.
5. We welcome the proposal to establish the Office for Gambling Control Ireland. We believe that an empowered and pragmatic regulator is essential for the growth of a modern and safe gambling industry in Ireland. We agree with the principle that flexibility and
technology-neutrality will be a key element of any successful regulated environment. In that context, we believe the legislation needs to avoid being overly prescriptive or granular and therefore unable to adapt to the fast-moving pace of change in the gambling industry and in technology generally.
6. Accordingly, rather than enshrining inflexible standards in primary legislation, we would suggest that the OGCI be provided with sufficient powers to enable it to develop Codes of Practice and Codes of Conduct in order to allow it to quickly respond to market
developments without the need for Ministerial orders or amendments to primary legislation. Consultation with licensees and other stakeholders would be a key part of any such regime. We have seen this approach work well in other jurisdictions and we believe it will allow for good regulation and ensure Ireland’s regulatory framework remains current and relevant. 7. Paddy Power has always been committed to acting fairly and operating the most robust
and stringent practices in the industry with regard to responsible gambling and age verification. We therefore welcome in principle the broad range of measures set out in the General Scheme around player protection; including self-exclusion and the establishment of
the Social Fund. We do however believe that some of the sections regarding these measures may require further consideration and elaboration.
8. For example, while most operators operate a self-exclusion policy, there is no
standardisation of approach across the industry. It is also widely recognised that there are serious challenges in ensuring that multi-operator self-exclusion schemes work for both individuals and operators and we are concerned that these are potentially unworkable in a retail environment. This is something that will require further
consideration and engagement by the industry with the OGCI to determine how best to implement this measure.
9. We are fully supportive of the Social Fund referred to in Head 77, however the manner in which it is funded may warrant further consideration as the approach can vary in different jurisdictions.
10. There are three other specific sections that we’d like to highlight this afternoon. The first we’d like to mention is Head 72, which enables the Minister to bring into effect rules governing advertising based on the principles listed in Head 72(3). The principles in Head 72(3) are however quite subjective and open to a wide degree of interpretation and we believe this is something that would be better dealt with in a Code of Practice developed by the OGCI or the Advertising Standards Authority for Ireland instead of being included in a Ministerial Order or indeed in primary legislation.
11. The rules on promotions in Head 73 may also need some further consideration. Head 73 contains time based restrictions on the offer of promotions in relation to both remote and non-remote services. We do not understand the rationale for this and believe the
restrictions are unworkable in the context of the media we consume in Ireland and the global nature of the Internet.
12. Finally, in relation to Schedule 1, this proposes quite a complex regime of 43 possible licence categories, which hopefully can be reviewed for the purposes of the Act and perhaps
rationalised for ease of administration.
13. To conclude, we’d like to reiterate that we welcome the publication of the Gambling Control Bill General Scheme and believe it will play an important role in establishing a modern, well regulated regime for gambling in Ireland. We look forward to playing a constructive role and providing any assistance we can in the development of that regime. If the Committee has any questions on the presentation or our submission, we’d be happy to take them.
BETFAIR GROUP PLC:INTRODUCTION TO OIREACHTAS COMMITTEE ON JUSTICE,DEFENCE AND EQUALITY OCTOBER 2013
Speaking notes:
Chairman, Deputies, Senators, Betfair welcomes the opportunity to present evidence to the Committee on Justice, Defence and Equality.
In many ways Betfair is a perfect example of how technology can and has overtaken existing regulation, and therefore why the Gambling Control Bill is a timely piece of legislation that is being welcomed by the majority of stakeholders. As many of you probably know Betfair is a purely online betting operator that was created on the back of the wave of innovations since the invention of the internet. Betfair has made a long standing commitment to Ireland and seeks to be a constructive partner to ensure the regulatory process in Ireland benefits all stakeholders, including the end consumer (punters), the Irish Government and legitimate betting operators.
Since its launch in 1999 Betfair has grown to become a FTSE 250 company which currently employs 1,700 people worldwide. Here in Ireland the company has made significant long term investment with 100 jobs in its Dublin Operations Office and two data centres which equate to a €30million investment. Based on salaries, taxes paid and contracts with local suppliers Betfair makes an annual contribution of approximately €18million to the Irish economy.
What makes Betfair different to traditional operators is its betting exchange model which uses technology similar to a stock exchange to allow Betfair to offset its risk perfectly by exactly matching sports betting supply and demand in a way not previously done by traditional bookmakers. Betfair now also operates a sportsbook product, offering traditional fixed odds betting like most of its competitors that you will be familiar with.
The internet has allowed the gambling industry to evolve significantly. Consumers now have access to a wide range of products and where price comparison has never been quicker or easier this has driven up competition in the sector enormously.
It is therefore quite right that the Government is overhauling existing legislation to establish a regulatory regime that will incorporate changes in the sector and the emergence of remote gambling for the first time. This will help ensure any company taking a bet from an Irish resident, be it on the internet via laptop or mobile device, or over the telephone meets the regulatory standards set out by the Irish Government.
As with all such legislative proposals there will need to be consultation between the Department for Justice, operators and other stakeholders to get the details of the legislation correct and viable for the years ahead as technology continues to evolve. Betfair is willingly engaging in this process and will help wherever possible.
You will have received our submission to the Committee, and we are happy to go through any of the items in further detail. Betfair restricted its comments on the bill to the issues that are relevant to its business as an exclusively online gambling operator.
Betfair’s primary observation is in the area of relevant entities and the licencing process. Within a regulated gambling regime there needs to be clarity about which organisations are required to register and which individuals need to be listed on the licence application with the national regulator, in this case the Office of Gambling Control Ireland (OGCI). Betfair has been through licensing processes in many jurisdictions and our experience has led to our view that in all cases the number should be kept to a realistic minimum to avoid unnecessary burdens and costs on operators and the OCGI. For example, it would be assumed that if the person listed as a ‘nominated officer’ leaves the employment of a licensed operator this will need to be notified to the OGCI and a new individual instated into this position. With potentially hundreds of licensed companies this has the potential to be burdensome for all stakeholders.
- 2- Betfair’s other comments are as follows:
1. Licence application costs: It is essential that the costs and logistics of applying for a licence are provided upfront to operators so they can plan accordingly.
2. Level of probity on licence holders: Betfair would like to suggest that the Department of Justice seeks to adopt a similar approach to the UK with regard to the information it requires from licence holders (Head 25). The
Gambling Commission provides clear information on what is expected of companies wanting to become licensed1,
including a detailed Operating Licence Application Form for companies2 and a Personal Declaration form for
relevant individuals within a company.3
3. Secondary regulations/technical guidelines: With the establishment of the OGCI operators will expect to see secondary regulations, often called technical guidelines or standards, which will outline exactly how the licensing process will work, including the requirements on product testing prior to licensing. The Irish Government should seek to work with the industry, through formal consultation, so operators have the chance to inform and share their experiences of regulations and processes in other countries. Any final regulations should be published well in advance (a minimum of six months) before any new licensing regime becomes active in order to ensure operators wanting to apply for a licence have time to review and submit applications.
4. Self-Exclusion Register and Social Fund: Betfair supports the introduction of a self-exclusion register (Head 71) within a regulated gambling market in Ireland. The register would be most effective if it is shared with all licensed operators and it is made a licensing condition that operators cannot accept new customers whose names are on the register. This would ensure that if an individual has self-excluded from one operator they cannot open an account with another operator while their name remains on the self-exclusion register.
5. Establishment of a Social Fund: Betfair is also supportive of the establishment of a Social Fund to achieve the purposes of the fund set out in Head 78. There needs to be clarity as to how the Social Fund will operate and at what level contributions from operators will be set. The establishment of a Social Fund could potentially mirror the operational structure of the ‘Responsible Gambling Trust’ (RGT) which exists in Great Britain where the gambling industry voluntarily funds the RGT which is made up of experts with a background in helping people with addiction, the gambling industry or Government. Betfair seeks to be a responsible operator and integrate corporate responsibility into its business practices wherever it has an office.
Thank you and happy to take any questions or supply any further detail which may be helpful to your work.
1Gambling Commission, How do I apply for an operating licence – remote?:
http://www.gamblingcommission.gov.uk/gambling_sectors/remote_eg_online_gambling/getting_a_licence-_what_you_ne/applying_for_a_licence_-_remot/how_do_i_apply.aspx
2 Gambling Commission, Operating Licence Application Form:
http://www.gamblingcommission.gov.uk/pdf/Operating%20licence%20application%20form%20-%20August%202012.pdf
3Gambling Commission, Operating Licence Application Form Annex A Personal Declaration:
http://www.gamblingcommission.gov.uk/pdf/Operating%20licence%20application%20-%20(Annex%20A)%20personal%20declaration%20form%20-%20July%202010.pdf
PRESENTATION TO THE COMMITTEE ON JUSTICE, DEFENCE AND EQUALITY
ON HEADS OF GAMBLING CONTROL BILL 2013
OCTOBER 2013
F.A.O. Alan GuidonClerk to the Committee
Introduction
The Irish Showmen’s Guild (ISG) was established in 1954 to look after the interests of the Showmen (generic term for people engaged in the business of travelling fun fairs and circuses) who operate Irish based funfairs, fairgrounds and circuses. We currently have 105 members representing around eighty families. Most of our
members run small, family owned operations and have been involved in the industry for several generations. The Irish Showmen’s Guild is affiliated to the European Showmen’s Union (ESU-UFE), a trade body representing the interests of Showmen at European level. The work of the Guild involves a broad range of technical, social and administrative issues relating to our industry and which recognises the
importance of working with all relevant statutory bodies in the regulation of our industry.
The opinions and suggestions contained in the accompanying presentation are designed to assist in producing a review on the Heads of the Gambling Control Bill 2013 and how they may affect our members. We thank the Committee on Justice, Defence and Equality for allowing us to make this presentation and hope the Committee will accept it in the spirit of co-operation in which it is intended.
The Irish Showmen’s Guild have been proactive in the drafting of the original 1956 Gaming and Lotteries Act and subsequent amendments.
In previous submissions (1984 and 1999) the Guild highlighted areas within the 1956 Gaming and Lotteries Act that were causing difficulties for our members and the enforcement authorities. Our concerns and recommendations for change have remained consistent throughout the decades.
Irish Showmen’s Guild October 2013
Page 2
Head 1. Definitions and Intrepretation
The definition of “Gaming” constitutes the most important part of the 1956 Gaming & Lotteries Act that adversely affects the operation of traditional fairground prize Stalls. The original definition of Gaming:- means playing a game (whether of skill or chance
or partly of skill and partly of chance) for stakes hazarded by the players has failed to
keep abreast of technological change and progress. It is the opinion of our members that that the traditional fairground Prize Stalls such as Hoopla, Darts, Delph,
Coconut-Shy or other variation of Prize Stall with redemption of non-cash prizes should be considered separately to the proposed definition of “gaming”:- means
playing for a stake a game of chance for a monetary prize or other form of reward, and includes the playing of games available in casinos.
The nature of the traditional fairground Prize Stall involves the direct presence of a fairground operator who must travel and operate his particular Prize Stall as opposed to a Gaming Machine which can be sited and operated without the direct supervision and operation of the owner/operator. It is the personal presence of the fairground operator which sets the traditional fairground game apart from the Gaming Machine. In this instance the stake required must cover the fairground operators costs
including the substantial cost of transportation of the fun fair from site to site and the cost of the prize (Soft Toy, Hardware etc.).
The Gambling Control Bill 2013 General Scheme proposes to define a funfair thus:-
means a fair consisting wholly or principally of the provision of amusements and
subsequently defines gambling as (v) amusements, Gaming, and the presence of Prize Stalls in particular, are never the main activity of the fun fair.
The Planning and Development Act, 2000 (Certification of Fairground Equipment) Regulations, 2003 – S.I. No. 449 of 2003 refers to the definition of a funfair as having the meaning as defined in section 239 (1) of the Act:- means an entertainment where
fairground equipment is used.
The Guild contends that the 1956 Gaming & Lotteries Act sufficiently clarifies at 6.-(1) that Gaming carried on at any place as part of a circus or other travelling show (funfair) shall not be unlawful gaming if – (a) gaming is not the main activity at the show (funfair). We are suggesting that a more appropriate definition of “funfair” would be:- means an entertainment where fairground equipment is used and gaming
is not the main activity of the fun fair.
This suggestion does not include the potential use of a Gaming Machine in a travelling fairground Gaming Arcade both of which are clearly defined in the Gambling Control Bill 2013 General Scheme as:-
“gaming arcade” means any covered area having machines, at least some of which are gaming machines, and which is not open to young persons.
Irish Showmen’s Guild August 2013
Page 3
“gaming machine” means a machine constructed or adapted for playing a game of chance for reward by means of it having a slot or other aperture for the insertion of a player card, cash, tokens, and subject to the terms of the licence, credit cards or debit cards.
In May 1999, the Minister for Justice, Equality and Law Reform, Mr John ’Donoghue, T.D., established an Interdepartmental Group to review the regulatory environment within which gaming and lottery activities are carried out. In their report (7.8) the Review Group suggested that, subject to appropriate safeguards, gaming in line with the revised legal requirements should be permitted in association with events such as funfairs, carnivals, and other special or once-off events.
The recommendations of the Review Group suggested that:-
(27) Gaming in conjunction with carnivals, travelling shows (funfairs) etc., conducted in accordance with the general provisions of the new legislation, should be allowed under temporary permit from the Gaming and Lotteries Authority. Such permits may attach additional conditions as appropriate to the circumstances.
(28) The arrangements for these events should be such so as to provide adequate safeguards in order to prevent underage gaming.
The subsequent Report of the Casino Committee - Regulating Gaming in Ireland noted at 1.5.11 that “… The Committee is not recommending preferential treatment for already licensed operators in that industry. It is simply acknowledging that they are engaged in lawful activity and that, in developing the new licencing regime, careful consideration should be given to the status of this sector.”
It is our contention that the Casino Committee could have avoided ambiguity by separating their consideration of what defines an Amusement Hall and a travelling Fun Fair. The Gambling Control Bill 2013 General Scheme clearly defines an
“amusement hall” / “amusement arcade” means any covered area having
amusement machines only, and which is open to young persons as well as adults.
There is no ambiguity within the meaning of this definition when compared to how a Gaming Arcade is defined in the General Scheme:- means any covered area having
machines, at least some of which are gaming machines, and which is not open to young persons.
Head 70: No “young persons” as employees or players
If not appropriately amended the Gambling Control Bill 2013 General Scheme could impose an age limit to participants of the traditional fairground Prize Stall. It is our contention that there should be no age limit imposed to participants of these family activities. We wholeheartedly agree that the current age limit for Gaming Machines should be increased to the suggested 18 years and confined to specific areas to achieve the primary purpose of protecting vulnerable persons, including children.
Irish Showmen’s Guild August 2013
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Head 53: Hours of business
Many of our members attend annual Festival events throughout the Country on a seasonal basis. The proposal within the Gambling Control Bill 2013 General Scheme that a mobile gaming facility at funfairs and circuses concludes at 10:30pm is
therefore unreasonable when compared with the proposal that gaming in a public place (shopping centres, airport concourses) must conclude by 12 midnight. Due to the seasonal nature of funfairs and circuses we contend that the hours of business match the suggested hours for a gaming hall or arcade:-
(i) from 1st May to the end of September not before 10:00am, not after 1:30am
(ii) Rest of year, not before 10:00am, not after 12 midnight.
Thank you for the opportunity to make this presentation. We will be happy to reply to any questions the Committee may have.
In attendance on behalf of the Irish Showmens Guild :-
Mr Don Bird Mr Chris Piper
Director Director
Irish Showmens Guild Irish Showmens Guild
KIlglass KIlglass
Mitchelstown Mitchelstown
Co Cork Co Cork
The Remote Gambling Association
31 Southampton Row | London WC1B 5HJ | UK Tel : +44 (0) 203 585 1242
e-mail : [email protected]
Brussels Office
Rue du Trône 60 | 1st floor | Brussels 1050 | Belgium
T +32 2 626 95 00 | F +32 2 626 95 01 |
30 September 2013
HEADS OF GAMBLING CONTROL BILL: REVIEW BY THE COMMITTEE ON JUSTICE, DEFENCE AND EQUALITY.
Introduction
1. This submission is made on behalf of the Remote Gambling Association which is the largest trade association representing the online gambling industry.
2. RGA membership is restricted to operators and software suppliers. The operators must be licensed for gambling purposes within the European Economic Area (EEA), the Isle of Man, or the Channel Islands.
3. The members of the RGA have substantial experience in engaging with legislators, regulators and other stakeholders to ensure remote gambling is conducted in a fair, safe, and crime-free environment. This experience is based on operating in fully regulated jurisdictions where it is possible for private sector operators to obtain licences on a non-discriminatory basis. 4. Rather than restate all of the arguments that were outlined in the RGA
submission, I will recap our recommendations:
Our recommendations are as follows:
The government should acknowledge that the regulatory regime cannot be considered in isolation from the tax regime and should ensure that the tax burden is not so onerous that it will undermine the regulatory system and its social objectives.
Where possible the expertise and experience of the gambling industry should be utilized by the government and regulator and a constructive dialogue sustained throughout the process.
It should be established that remote operators must apply the regulatory requirements to those who are normally resident in the State.
OGCI success will be largely dependent on appointing people with the right skills and experience.
OGCI should establish an intelligence gathering and sharing function to help safeguard the integrity of sport.
As a point of principle licence fees should not exceed the cost of regulation.
The requirement for an extensive range of suppliers to be registered with the OGCI should be removed or limited significantly.
The definitions of bingo should be expanded to cover all forms of the game.
Some flexibility should be introduced so that OGCI can take full account of management control factors as part of an overall assessment of viability rather than being overly constrained by the one criteria of having
‘adequate reserves’.
Customers should have the option of being able to exclude by particular products; the self-exclusion register should be restricted to Irish residents; the self-exclusion period should be a minimum of six months rather than one; and customers should be able to use other methods to self-exclude rather than being restricted to doing it in writing.
We would recommend early engagement between the OGCI and its licensees to consider how best to apply the new advertising regime in a way which is both practical and effective.
Contributions to the new Social Fund, irrespective of whether it is voluntary of compulsory, should be based on a percentage of company gross profits and not turnover.
The sponsorship rules should be amended so that a potential source of valuable funding is not denied to professional sports.
There should be consistency between licensing periods for comparable land-based and remote gambling activities.
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