Working together to protect the Integrity of Sport Sports Betting Integrity at the 2015 Rugby World Cup V /04/2016

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1 Working together to protect the Integrity of Sport Sports Betting Integrity at the 2015 Rugby World Cup V /04/2016 Jack Stephenson-Saunders Lorraine Pearman 1

2 Contents Section 1 Background Section 2 Overview of Operational Activity Section 3 - Overview of Cases Section 4 - Betting at the 2015 Rugby World Cup Section 5 - Lessons learned Section 6 - Conclusions 2

3 Section 1 - Background 1. Two forms of sports betting posed potential risks to the integrity of the 2015 Rugby World Cup (RWC), World Rugby and the UK Government (HMG); o o Betting in breach of World Rugby Regulations; and Betting related to the manipulation of matches as a criminal offence. 2. There was nothing to indicate prior to the 2015 RWC that corrupt sports betting would be an issue. However, given the potential impact upon the sport of Rugby Union at international level, the reputation of the UK as a safe place to host major sporting events and our ability to offer corruption free betting markets the Gambling Commission (GC) and World Rugby believed it was prudent to put in place processes to help us manage any potential cases effectively and efficiently 3. World Rugby and the GC s Sports Betting Intelligence Unit (SBIU), with the support of other stakeholders including the National Crime Agency (NCA) and the National Police Chiefs Council (NPCC) were the principal actors within the collaboration. Section 2 Overview of Operational Activity 4. The agreed processes between World Rugby and the GC, to manage reports of suspected betting integrity related to the 2015 RWC were in place between 10 September 2015 until 6 November Engagement between stakeholders and preliminary planning commenced over 18 months prior to the 2015 RWC. These processes, although on a smaller scale, were trialled throughout the London Sevens tournament which took place in May 2014 and 2015 at Twickenham. 6. Information sharing was conducted in line with and underpinned by the Memorandum of Understanding (MoU) agreement between World Rugby and the GC. 7. A detailed Communications Policy was also implemented that was deployed in the run up to and during the tournament. This policy set out the communications plans in response to any sports betting integrity issues which might arise during the 2015 RWC. Its aim was to ensure that all stakeholders issue timely and consistent statements and/or have agreed response statements. 8. The SBIU was the GC s point of contact during the RWC and provided support to World Rugby via business as usual processes. However it was agreed that any incidents relating to the RWC would have been treated as priority. 9. World Rugby appointed dedicated points of contacts from within their organisation. These were Head of Legal & Legislative Affairs, and Legal Counsel/RWC Integrity Manager ( RWC Points of Contact ). 10. World Rugby also has a contracted integrity consultant with extensive experience in racing as well as with football referees ( RWC Integrity Consultant ) who was full-time with World Rugby for the duration of the RWC.

4 11. In addition, World Rugby nominated a number of Integrity Officers throughout the tournament. 12. These Integrity Officers included representatives from a range of national Sport Governing Bodies (SGBs) with experience of dealing with betting integrity incidents. 13. The Integrity Officers principle roles were to; provide betting integrity education sessions prior to the tournament, having a presence and acting as a point of contact at games and conducting follow up sessions at team hotels for players, managers and coaches etc. 14. It was agreed between the parties that any reports would be managed during SBIU normal business hours. SBIU and World Rugby checked the agreed channels intermittently outside of these hours and took appropriate action where relevant. 15. A rota including emergency telephone contacts of all parties was put in place should an urgent issue have been identified that required immediate attention. 16. It was agreed that an emergency meeting would take place should parties deem it necessary for urgent collaboration. 17. For example, notification of a media sting or a report of a match fixing event prior to a game taking place (This nature of incident did not occur). 18. Should criminality be suspected, the Sports Betting Integrity Triage Process would have been invoked. Section 3 - Overview of Cases 19. Prior to the tournament commencing, the GC wrote to betting operators to advise on the betting integrity support being put in place. As part of this support, it was requested that any reports to the SBIU regarding the 2015 RWC were treated as a priority. 20. Face-to-face engagement was delivered by RWC Integrity Officers, with players, coaches, support personnel and match officials. This helped to raise awareness and make people understand their obligations under the integrity programme. 21. A small number of reports were fed into RWC Integrity Officers from playing staff, managers and support personnel. These all related to unsolicited approaches being made to players either via social media or and reports were made immediately in line with the reporting protocols explained to teams in their pre-tournament education sessions. Subsequent enquiries ruled out any concerns around betting integrity in relation to any of these reports. 22. These reports were recorded on the SBIU Incident Log.

5 Section 4 - Betting at the 2015 Rugby World Cup 23. A number of UK licensed operators contributed data for our analysis. This data has been merged in order to give an indication of betting patterns and provide a comparison to the previous RWC. 24. In line with forecasts, all operators reported much higher levels than experienced for the 2011 RWC in New Zealand. 25. Tables 1 and 2 below illustrate an increase in the number of bets taken and total turnover in comparison between the 2011 RWC and the 2015 RWC. +218% 26. This data represents an average from information supplied by the contributing operators. 27. The majority of operators reported a split of 50:50 across in-play and pre-event betting.

6 28. Betting by matches 29. Generally the betting reported by respondent operators showed similar patterns and more or less in line with expectations. Not all operators specifically reported the overall numbers of bets and the information provided differed across the various responses. However the table below shows on average the approximate profile by match: Event % of total turnover Stage/Round England v Australia 5% Group Stage New Zealand v Australia 4.1% Final Australia v Scotland 3.4% Quarter Final Australia v Wales 2.8% Group Stage England v Wales 2.7% Group Stage Section 5 - Lessons learned 30. This was the first time formalised betting integrity plans had been implemented into a Rugby World Cup on such a large and integrated scale. Following an Operational Wash-up meeting conducted by the GC in conjunction with the NCA, Police and World Rugby, it was concluded that, on the basis of the evidence, the 2015 RWC was free from any manipulation. 31. The process of feasibility from design to implementation took approximately 18 months. Early stakeholder engagement to gain agreement as to high level operating principles and standard operating procedures is seen a critical factor by all those involved to setting direction and providing the momentum for the project. 32. Learning point: If tournament organisers wish to deploy a similar capability at future events then engagement between stakeholders needs to ideally begin at least 18 months prior to the start of the event. This will allow stakeholders time to establish and agree information sharing principles and produce operating designs and policies. 33. Feedback suggested that having designated single points of contacts (SPOCs) for all betting integrity tournament stakeholders contributed to the efficient running of predefined processes. Having identified SPOCs in place ensured information was relayed to the correct department/individual in an effective and timely manner. SBIU acting as the hub for intelligence sharing is an established model that has proved to be effective at both business as usual level and for bespoke support for major tournaments. 34. Learning point: Designated SPOCs should ideally be identified and contact details made available across all relevant stakeholder groups. 35. Learning point: SBIU should be central to the management of betting integrity (as the established national platform). SBIU should be kept informed of issues, however minor, as the SBIU may hold relevant intelligence that is not available to other stakeholders. Further to this, the SBIU are the only constant in any model that is developed for betting integrity support for future tournaments and therefore it is important that they are aware of all issues and determine their impact both on past, current or future events.

7 36. Betting integrity education specific to the tournament was delivered by RWC Integrity Officers prior to and during the tournament. This engagement with players, coaches, support personnel and match officials at the tournament helped to raise awareness and make people understand their obligations under the integrity programme. 37. Learning Point: The network of dedicated integrity officers, who are drawn from the integrity units of other sports and security backgrounds proved to be highly effective. It provided points of contact for participants who were experienced in dealing with betting integrity related issues who could then progress reports to the appropriate SPOC. This increases confidence that any betting integrity incidents are appropriately managed. 38. Should criminality have been suspected, it was agreed that the established Triage Process would have been invoked. The Triage Process would support parallel investigations by law enforcement and World Rugby to avoid potentially any delays in either of the investigative processes. 39. Learning Point: Using established processes and responses appropriate to the tournament, provides assurance to stakeholders that should a betting integrity incident occur, these will be effectively managed 40. Information sharing was underpinned by a Memorandum of Understanding (MoU) between the GC and World Rugby. This set out stakeholder responsibilities regarding the transfer and storage of information, in line with government standards and the Data Protection Act Learning Point: Information sharing protocols between the GC and all other stakeholders must adhere to current legislation and government standards. All stakeholders must be aware of their responsibilities, which can be set out prior to the start of an event in an MoU. 42. Learning point: Where possible, processes and systems should be tested before the start of an event, either using smaller live events or through an office based testing exercise. This will allow processes to be trialled in a safe environment and amended should any gaps or weaknesses are identified. Section 6 Conclusions 43. As far as we are aware no major incidents of sports betting integrity impacted the 2015 RWC. We cannot say this with complete certainty as monitoring of betting markets was restricted to those that are regulated by the Gambling Commission however we understand that the third-party monitoring agency engaged by World Rugby to live monitor global betting also reached the same conclusion. 44. All the indications are that the approach adopted for the 2015 RWC provided an effective mechanism to identify and support decision makers with any suspicious activity driven by either unusual betting, suspected corrupt sports betting or other match fixing activity. 45. The importance of detailed operational planning, stakeholder engagement, testing of the agreed process and communication management cannot be over emphasised. The planning will ensure the processes and protocols that form the basis of the model are in place; the engagement will ensure those directly involved understand what needs to be

8 achieved and their responsibilities within the model; and testing will reiterate responsibilities, identify capability gaps and how those gaps can be addressed. 46. The model adopted for betting integrity support arrangements for the 2015 RWC could be deployed by event organisers of other major events or tournaments, adapted to suit specific risks and/or threats. 47. However, early and robust planning is required to establish such a capability for national and international sporting events to ensure effective delivery similar to that of the 2015 RWC.

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