Helen Grant MP Minister for Sport and Tourism Department for Culture, Media and Sport 100 Parliament Street LONDON SW1A 2BQ 29 January 2014

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1 Helen Grant MP Minister for Sport and Tourism Department for Culture, Media and Sport 100 Parliament Street LONDON SW1A 2BQ 29 January 2014 Dear Minister Following the meeting on 10 December 2013 with you and the Secretary of State for Culture, Media and Sport to discuss match-fixing, the Sports Betting Group (SBG) is writing on behalf of sport to provide a more thorough response to some of the issues that were raised. Significant progress has been made in tackling the threats posed to the integrity of sport by corrupt betting in recent years, and we would like to provide an overview of the work that has been done on behalf of the sector during this time. The SBG was formed in 2010 following the publication of the Report of the Sports Betting Integrity Panel (chaired by Rick Parry), which was commissioned by the DCMS the previous year. The report put forward a number of recommendations for sport, Government, the Gambling Commission and the betting industry. One of the key recommendations directed at the sports sector was to provide leadership by setting up the SBG. The SBG is made up of leading sports integrity practitioners from football, horseracing, cricket and rugby, while it also has representation from the Professional Players Federation (PPF). The Sport and Recreation Alliance provides the Chair and secretariat. The SBG also receives input from other governing bodies, competition organisers, integrity bodies and wider sports stakeholders. Since its establishment in 2010, the SBG has played a central coordinating role for the sector by providing knowledge and expertise, while at the same time working with the Government and other agencies to improve the regulatory framework for sports betting integrity. Specifically, the SBG has: Run a seminar at the DCMS which was attended by some 80 stakeholders from the sporting world and featured keynote speeches from the then Minister for Sport Hugh Robertson MP, Rick Parry and Sir Craig Reedie, together with several presentations addressing various integrity issues and guidance on best practice.

2 Conducted a thorough audit of over 40 sporting bodies to measure their progress in protecting themselves from the threats posed to integrity by betting and make them aware of any deficiencies identified. Published a simple six-step Code of Practice for sports governing bodies on betting integrity, as well as setting up a dedicated website containing additional information, educational material, policy submissions and details on how to report suspicious activity. Following the launch of the Code of Practice and the website, the SBG conducted a second, smaller audit of sports governing bodies that showed good progress had been made by a number of sports in this area. Provided direct support to the British Olympic Association and helped it to compile its successful athlete education programme in the lead up to London Through the PPF and its professional player associations, educated more than 5,600 sportsmen in 2013 on sports betting integrity issues. This was delivered face-to-face during team visits to almost every professional football, cricket and rugby union club and was backed up by leading e-learning systems. In addition, the main player associations provided responsible gambling education and, when necessary, treatment services for players with gambling addictions. Been well represented on the Tripartite Technical Forum on Betting Integrity. The Tripartite Forum brings together sport, the Gambling Commission and betting operators with the aim of achieving closer collaboration and mutually agreeable solutions to issues surrounding betting integrity in sport. Delivered bespoke educational workshops and provided practical advice to over 70 key stakeholders from across sport at a recent Gambling Commission event held at Twickenham. Worked with DCMS and Parliamentarians to improve the Gambling (Licensing and Advertising) Bill which is currently going through Parliament. The SBG provided oral evidence at the prelegislative stage, as well as to the Public Bill Committee in the Commons. These are just some of the achievements of the SBG in the last few years and we hope that you agree that the Group has played a crucial role in coordinating the sector, raising awareness and providing advice and support to governing bodies. In addition to this, individual sports have worked hard to ensure that they have robust integrity infrastructures in place. As reflected in the Parry recommendations, it is essential that NGBs take a sport-specific approach to dealing with integrity issues since every sport has a unique structure, risk profile and level of resource. Furthermore, their European confederations and international federations may also require particular policies to be adopted that meet the wider interests of the sport concerned. As such, it is not always appropriate to have a one-size-fits-all approach to integrity issues. You will find

3 attached some more detailed information from each of the sports bodies that have been invited to the next meeting on 3 February on the specific steps that they have taken within their sport to safeguard integrity. Nevertheless, the SBG continues to strive for a collaborative approach wherever possible. Indeed, there are a number of initiatives that are currently being investigated that will further help to build on the steps that have already been taken. Some of these were discussed at the meeting on 10 December, and include: Scoping out the possibility of establishing a pan-sport independent reporting line which will allow participants and members of the public to anonymously report suspected breaches of integrity. SBG is working with Crimestoppers to see what the available options are, while the British Horseracing Authority has been providing advice based on its own experiences with its dedicated reporting line Racestraight (also provided by Crimestoppers). Following the Gambling Commission event held in November 2013 at Twickenham, discussions have been ongoing about how sports bodies can more effectively share educational material and information. SBG is examining the possibility of establishing a dedicated online portal that will enable sports bodies to share resources and best practice with regard to participant education. Through the Tripartite Forum, SBG is working with the Gambling Commission and betting operators on a specific piece of work with the aim of developing a better shared understanding of the common areas of risk to sports betting integrity in the UK (and beyond where international influences impact the UK). Sports governing bodies are also currently working with an IT software company with a view to developing technological solutions that would restrict or prevent certain categories of individuals from gambling. Such software would make it easier for sports bodies, regulators and operators alike to prevent and identify integrity breaches and take any necessary action in a timely manner. In light of all this work, it is clear that sport is fully committed to doing everything possible to uphold integrity and prevent betting related corruption at every turn. We realise that there is still more to do, and the SBG will continue to strive to provide leadership and support wherever possible, and also to act as a valuable conduit between sport and the Government on issues relating to sports betting integrity. However, sport remains of the view that there are a number of areas where the Government could provide greater assistance to help us achieve our objectives. Some of these points were covered in the letter that sport sent to you following the 10 December meeting, but for ease of reference we have listed them below. Specifically, we see the main areas for action as: Review and amend the offence of cheating under S42 of the Gambling Act The existing legislation is out of date and does not criminalise the act of fixing (either match fixing or spot fixing ), so a new definition that covers cheating in a sporting event for betting

4 purposes should be introduced. S42 is contained in an Act that was, according to its own clear objectives, not designed to protect the integrity of sport. To prosecute offences under existing legislation, proof is either needed of the receipt/offer of a corrupt payment by the sportsman in an agency context (POCA 1906) or a causal link between the corrupt act in the relevant sport and gambling (GA 2005). Experience shows, from an evidential perspective, the difficulty of a successful prosecution. Other jurisdictions, recognising the growing gravity of the threat, have either already introduced bespoke legislation criminalising sporting corruption or are in the process of doing so (for example Australia, but there have also been positive developments in Italy, Russia and Switzerland).The first recommendation of the Parry report, commissioned by DCMS, was to undertake this review. There is concern that the custodial sentences set out for offences under S42 are not nearly enough and that much stronger legislative deterrents/sanctions are needed to help counter the threat of corruption (see in particular the All Party Parliamentary Group report from 2005). We would ask DCMS to urgently enact the Parry report recommendation for a review of this topic. We also understand that amendments on this subject will be tabled at the Report Stage of the Gambling Bill. The establishment of a proactive sports integrity unit and/or the re-enforcement of the existing Sports Betting Intelligence Unit (SBIU) within the Gambling Commission. This is a key recommendation of the Parry report. It is a long-standing frustration that the police and Gambling Commission have, for their various reasons, placed actively protecting and promoting sport events as a low priority, at best. We very much hope that the recent NCA action represents a deliberate and planned proactive move within law enforcement, as opposed to reactive. Sports governing bodies are in any event ready and willing to work with them. Ensure all operators offering bets in the UK are regulated to the same standard by the Gambling Commission, including the application of Licence Condition We welcome you addressing this issue in the current Bill. As part of the enforcement regime for the new law, we would urge the clear adoption of rules preventing payment systems from transferring UK funds to the accounts of unregulated offshore operators. Include spread betting within betting regulation and law. We welcome the move by the FCA to issue new guidance to spread betting companies, but the most effective way to address the anomaly in relation to spread betting would be to transfer responsibility for sports spread betting from the FCA and bring it under the regulatory remit of the Gambling Commission. This could be done through the Gambling (Licensing and Advertising) Bill. At present the FCA says that primary legislation prevents it from requiring spread betting companies to share

5 information directly with sports governing bodies, in contrast with Licence Condition This is not satisfactory and we believe that the matter should be addressed during the passage of the Gambling Bill. Consider providing a financial contribution to help fund the various initiatives, education programmes and structural enhancements that sports bodies have had to make and will continue to have to make to protect themselves from the threats posed to integrity by corrupt betting. With the Government due to receive in the region of 300 million per annum in additional tax revenues from overseas betting operators starting from later this year, we would urge the Government to allocate a small portion of this money to help fund sports betting integrity measures. We remain committed to adopting a collaborative approach and, as such, we would request that the Government takes appropriate action in the areas outlined above. As I am sure you will appreciate, the fight against corruption cannot succeed unless all of the parties that came together within the Parry forum continue to work together in a complementary and constructive manner and are appropriately resourced to carry out their respective roles. We trust that you will find this information helpful and we look forward to discussing the issues with you in more detail on 3 February. Yours sincerely T M LAMB Chair, Sports Betting Group