Rileys is one of the oldest names in the leisure industry with its first club opening in

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1 RILEYS BINGO APPLICATION 1. Background Rileys is one of the oldest names in the leisure industry with its first club opening in Manchester over 100 years ago. There are currently 102 Rileys trading throughout the United Kingdom of which all but four are clubs for members. Up to 2011 Rileys operated offering snooker, pool, darts, bar facilities, food and gaming machines. Rileys decided some years ago to look at putting bingo into their premises as it would appeal to the female part of the demographic group which Rileys customers fit into. An Application for an Operating Licence was first made in 2007 but it was not until the advent of Bingo Express in 2011 that Rileys proceeded with Applications for Premises Licences. Rileys are very experienced in ensuring that their products are used responsibly and not, when required, by those under the age of 18. Rileys have for many years operated with Alcohol Licences and gaming machines whilst, at the same time, allowing under 18 s to be members and have never had any issues with the authorities with regard to underage customers using these products. The same social responsibility and training will be in place for bingo. By 12 June 2012, Rileys were operating 11 sites under Bingo Premises Licences with a further six Bingo Premises Licences granted by Local Authorities but not yet trading. No Local Authority has refused an Application for a Bingo Premises Licence. The Applications for Bingo Premises Licences commenced in March 2012 when the Category C Operating Licence was granted by the Gambling Commission. Rileys agreed to all conditions proposed by the Gambling Commission including a condition to submit, on a monthly basis, returns to the Gambling Commission showing the extent to which the bingo was being played at their premises. Rileys continue to liaise with the Gambling Commission and to update their training and compliance manuals

2 based on their experience of operating these sites and on advice from the Gambling Commission. The latest training document is attached with this information. 2. Bingo Express Bingo Express is a new way to play bingo. The traditional way to play bingo would be for a caller to select a ball with a number on from a container and shout out the number so that players could mark the number off a card. Bingo Express does away with the need for a person to select a ball and call out the number. Customers purchase tickets by approaching a member of staff who is responsible for the Bingo Express machine and only when approved by the member of staff can that person purchase a bingo game ticket from the machine. The machine only operates when validated by a staff member. Games can be played every 15 minutes and there are screens set out around the club which show the results of each game. Any person who wins a game has to have the ticket checked by the member of staff responsible for the Bingo Express machine before a prize can be claimed but other members of staff within the club are trained to understand the responsibilities of bingo. No person under 18 is permitted to play bingo in the same way that no person under 18 is allowed to purchase alcohol from the bar or play the gaming machines. The same age verification checks are made on customers for bingo as would be made for alcohol and gaming machines. The Bingo Express machine and the games on it are approved by the Gambling Commission (see attached Guidance to Local Authorities). 3. Primary Gambling Activity Rileys are fully aware and have received advice of the requirements set out in the Gambling Act 2005 and the Guidance to Local Authorities. The Gambling Act s150 confirms that the Premises Licence authorises premises to be used for a particular type of gaming (in this case bingo) which must be specified on the Licence (s151). Section 153 of the Gambling Act 2005 confirms that the Licensing Authority shall aim to permit the use of premises for gambling,

3 in so far as the Authority thinks it is in accordance with the relevant code of practice, the Guidance issued by the Commission, the Licensing Objectives and any Statement published by the Authority. A Premises Licence for gambling may not authorise the use of premises for activities for more than one of the kinds specified in Section 150(a) to (e). 4. Gambling Commission Licence Conditions and Codes of Practice Supplement 4 Primary Gambling Activity The Gambling Commission has issued Guidance to Local Authorities but in January 2009 specifically issued guidance in connection with primary gambling activity. Part II of the LCCP4 sets out Codes of Practice relating to primary gambling activity. The ordinary code provision notes that Licensees should have regard to the following factors: - The ratio of space available to customers allocated to the primary gambling activity to that allocated to other gambling activities; - The extent to which the primary gambling activity is promoted on the premises and by way of external advertising compared to other gambling activities; - The use, either expected or actual, to be made of the different gambling facilities.

4 In respect of non-remote Bingo Licences, the ordinary code provision continues and refers to the following factors: - The frequency and extent that bingo is or is intended to played on the premises compared with the period when the premises are open; - Whether there is the following:- Capacity on the premises for the generation of main stage bingo numbers; A facility to sell tickets or cards for bingo games on the premises; Bingo available to be played when other sessions are advertised; Display of prize board information; A means of stopping a game to claim a win. LCCP4 continues: - Not all the indicators will need to be present in a particular case, nor would do they preclude others, but the combination of those factors that are present should be sufficient to indicate that the activity is the primary one in any given premises. The activity which must be primary for a Bingo Premises Licence to be granted is the primary gambling activity. It is not the primary activity at the premises. 5. Rileys Primary Gambling Activity

5 - All of the licensed area is available to customers for bingo as the screens are set out throughout the premises. A small area is allocated to gaming machines. - Bingo is promoted through the premises by posters and point of sale information. It is set out in the exterior title of the club and advertised at the entrance to the premises. There is also a great deal of online advertising for bingo which far exceeds other promotions. - Rileys expect bingo to be used more than any other gambling activity. Rileys experience is that more people use the bingo than any other gambling activity and this was backed up during a Gambling Commission unannounced visit on Monday 11 June when the Inspecting Officer commented that more people were playing bingo than using any machines. - Whilst Rileys does not have a main stage, it has the Bingo Express machine which generates the numbers which can be seen on the machine and on the screens throughout the premises. - The facilities available for tickets and cards to be purchased for the bingo games on the premises. - Bingo is available whenever sessions are advertised. - The prize board information is displayed at the premises.

6 - Games can be stopped. - The attached brochure shows a typical entrance to Rileys with the words Bingo both within the title of the club and shown at the door. A customer s journey through Rileys playing Bingo Express, point of sale information, online information and other promotional activities. - Customers are asking for more bingo sessions to be put in and a new website is being launched in September An advertising campaign on Facebook and Twitter is very active as well as the posters and points of sale information within the club. 6. The Gambling Commission/ Compliance Rileys have appointed Peter Hannibal (ex-gaming Director at Gala Bingo) as a Consultant and Nicola Morrice (who has a Grey Licence for casinos and has dealt with a high level of compliance within casinos) as a Project Manager to liaise with the five national Operations Managers. Nicola has a point of contact with the Gambling Commission to ensure that there is constant dialogue and feedback and matters have recently been discussed on Wednesday 13 June at the Gambling Commission. Rileys continue to notify the Gambling Commission of key events and to supply statistical information on a monthly basis.

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