Olympic Entertainment Group Madis Jääger, CEO. Dublin 9 October 2013

Transcription

1 Olympic Entertainment Group Madis Jääger, CEO Dublin 9 October 2013

2 5 Reasons why Olympic is the best partner to work with in Ireland Olympic being listed on the Tallinn and Warsaw Stock Exchange, has developed the highest reputation, is transparent in its approach to stakeholders and is monitored by a number of regulatory bodies. Olympic offers all its casino guests an entertainment experience and emphasises the importance of responsible gaming, with built in protections to cater for any problem gambling and to ensure fairness to all. Olympic has the finest, proven concept for the small and medium sized casinos tried and tested with consumers in 9 various European jurisdictions, including Estonia, Italy and Poland. Olympic is one of the innovators in establishing modern gaming technology, aimed at ensuring fairness to all customer and guarding against any criminal conduct. 5 Olympic has extensive experience of establishing and running flagship casinos. 2

3 Proposals for discussion Safe and controlled environment Responsible gaming Gaming equipment limitations Bar as integral part of entertainment Slots, tables and other gaming equipment to be operated under strict control and in safe environment protecting customers. No gaming equipment should be operated outside casinos or gaming arcades. Player registration, age limit, self-exclusion program, problem gambling hotline, visitor tracking system, employees training, social responsibility initiatives European practice is 5-7 slot machines per each gaming table, depending on market size, max 15 gaming tables would enable to operate up to 105 slot machines Not in line with international industry standards, greater clarity needed 3

4 Safe and controlled environment Gaming equipment only in the licensed gaming environment (casino and gaming arcade) It is practically impossible to fully control and regulate gaming in bars, pubs, shopping malls and other public places Category 2S licenses will have significant impact to land-based operator but taxes on gaming and employees salaries will be difficult to collect Similar regulation for casino and gaming arcades Gaming equipment certification Only operators / investments with transparent and proven track record Employees certification, with no past criminal record Clear anti-money laundering regulation 4

5 Responsible gaming Player registration Age limit Drunk / disorderly persons should be denied access to gaming facilities Problem gambling info kiosks with information / material Problem gambling hotline Centralized self-exclusion program Employees training about risks of problem gambling Player tracking system to monitor visits and playing activities 5

6 Gaming equipment limitations Current proposed limits will not serve as player protection purpose According to Options for Regulating Gaming in Ireland ( ; 5.2.1), money which would have been spent in casino, will not be spent in non-gaming activities Players move to online or less safe environment Proposed limits allow very limited investment, resulting in low quality gambling only oriented casino environment and service accordingly Regular European practice is 5-7 gaming machines per each gaming table With max gaming tables it enables slot machines per casino 6

7 Bar as integral part of entertainment Modern casinos are entertainment complexes with different type of entertainment, e.g. concerts, exhibitions and shows, places to meet and relax Proposal to prohibit alcohol on the casino floor is at odds with international industry standards 2003 UK lifted ban on alcohol on the casino gaming floor, no player protection issues raised as result Future clarity is needed 7

8 Thank You for attention For future questions please contact: Madis Jääger, CEO Olympic Entertainment Group AS Pronksi 19, Tallinn 10124, Estonia Tel Fax

9 Additional corporate information 9

10 OEG Vision and Mission Vision To be a global casino and resort operator with a passion for service excellence Mission To give our guests a customer orientated, secure and safe environment with the finest design and craftsmanship, unparalleled in the industry and supported by the excellence of our name and reputation. 10

11 Olympic in Snapshot First casino opened in Estonia in land-based casinos in 7 countries Online casino services since 2010 # 1 operator in Baltic countries 3,052 slot machines, 188 gaming tables Shares listed in Tallinn and Warsaw Stock Exchanges Winner of Best Land-based Casino Operator award for 2013 by Totally Gaming Awards Total Revenues (m ) Gaming Revenue Mix by Segments Estonia Latvia Lithuania Poland Slovakia Belarus Italy EBITDA (m ) 21% 11% 2% 6% H m 15% 23% 23% H H H H

12 Company History Opening of flagship Reval Park Hotel & Casino 1 st casino in Latvia Listing on Tallinn Stock Exchange 1 st casino in Belarus 1 st casino in Slovakia Exiting Romanian market Entering online gaming market OEG founded 1 st casino in Lithuania 1 st casino in Ukraine Exiting Ukranian market Entering Italian market 1 st casino in Poland and Romania Listing in Warsaw Stock Exchange 12

13 Key personnel Armin Karu, Chairman of the Board Founded company 1993 First casino established in Tallinn Olympic Yachting Centre Owns directly (and by controlled companies) 46% of the shares Madis Jääger, CEO Joined OEG in 2010 as CFO Previous work experience as an audit engagement leader in PricewaterhouseCoopers (joined PwC in 2001) Meelis Pielberg, COO Joined OEG in 1996 Country Manager in Estonia Aigar Hain, Country Manager in Estonia Gints Pakarklis, Country Manager in Latvia Saulius Petravičius, Country Manager in Lithuania and Belarus Cezary Gizka, Country Manager in Poland Jozef Skuben, Country Manager in Slovakia Kaido Ulejev, Head of OlyBet 13

14 Key Markets Estonia 18 casinos, 741 slot machines, 18 gaming tables Market share 54% Largest competitors - Pafer 14%, Grand Prix 11% and City Casino 7% Latvia 38 casinos, 1,018 slot machines, 18 gaming tables Market share 22% Largest competitors - Alfor and Admiralu Clubs together (Fenikss) 44% and Joker 14% Lithuania 12 casinos, 420 slot machines, 651 gaming tables Market share 72% Largest competitors - Nese Pramogu Bankas 16% and VSGA (Tornado) 12% Poland 3 casinos, 266 slot machines, 38 gaming tables Market share 12% Largest competitors - ZPR and Orbis together ca 25%, Casinos Poland 16% Slovakia 5 casinos, 263 slot machines, 52 gaming tables Market share 76% Largest competitor - Casinos Slovakia 18% Belarus 5 casinos, 232 slot machines Market share in Minsk 9% Largest competitor Maxbet ca 29% Italy 2 casinos, 112 slot machines 14

15 Responsible gaming company Olympic is socially responsible company in all areas of business and gaming: We pursue sustainable business fair, transparent and progressive We act with social awareness we are proud of our high ethical standards We ensure that we continuously develop our industry-specific knowledge We are committed to legal and responsible advertising We pro-actively enforce effective anti-money laundering measures We provide safe, licensed and responsible gaming services We provide secure, professionally monitored gaming environment We rigorously respect customer confidentiality and privacy Girts Ludeks, Director of Latvian Games Business Association, I consider it very significant that along with business Olympic Casino Latvia also gets involved in different philanthropy projects, thereby supporting those who need help and indirectly raising the reputation of gaming organizers. Socially responsible and successfully managed companies help to improve and develop the industry as whole. 15

16 Responsible gaming within the group in cooperation with GamCare Gaming should remain a source of pleasure. GamCare an organization that has been a great influence in assisting us to develop our own strategies on a responsible approach to gaming including the following: Visitors minimum age and registration Voluntary casino access restrictions Special staff trainings on problem gambling Problem gaming aid brochures, contacts of help Online self testing options Prohibition on gaming on credit Strong restrictions on gaming advertising and direct mail Collaboration with problem gamblers groups. R. Kvietkovskis, Chairman of Lithuanian Gaming commission, Olympic casino Group Baltija is known as one of the most honest company complying with the agreement of voluntary self-restriction from playing program. 16

17 Initiator of regulated gaming OEG has actively been involved in creating existing casino gaming regulations as well as those relating to online operations, to achieve: well regulated gaming markets and the highest operating standards to protect players and to enable thorough supervision by regulatory bodies Such activities include: Restriction on location Establishing the minimum number of slots or tables per casino Achieving an average pay out of all slot machine bets no lower than 80% Promoting the registration of all casino guests Ensuring that all slot games are accurately certified Maintaining detailed registers of all Barred Players Implementing special requirements for online gaming Developing Electronic Gaming Reporting System. Erkki Raasuke, CFO of Swedbank Group Sweden, Olympic casino is clearly one of the success stories of Estonian business. The company that was started in the confusing and unpredictable 1990s has now developed into a professional and successful business group that has expanded far beyond Estonian borders. The name, executives and achievements of Olympic Casino have always been there for the public to assess. It has been the right decision and created the image of an open and proactive corporation. The company s aggressive expansion lays upon this strong foundation. 17

18 Giving back to the community Examples of charity programs, but not limited to: Charity fund-rising and sponsorship events Children's hospital support Warsaw National Museum support Contributor to Lithuanian children's hospitals via Adamkiene Foundation Charity programs sponsored Olympic employees, but not limited to: Maarjaküla children s hospitality program in Estonia, supported for many years Examples of sponsorship programs, but not limited to: Major sponsor of the Estonian and Polish Olympic Committees Promoter of international boxing tournaments Helping the restoring Latvia's historic Cesvaine Castle Supporting the Estonian Music Academy Examples of Corporate Social Responsibility, but not limited to: Olympic Casino Poland honoured with prestigious award Social Face of Business by Polish Business Club in 2011 Olympic Casino Latvia has been honoured with prestigious bronze award in the Sustainability Index in 2010 Elita Keisha, Chairman of charity Martin s Foundation, We are pleased to have Olympic Casino Latvia as our supporter for several years. Our foundation is helping children to overcome serious health problems. Thanks to generous donations of Olympic Casino we have been able to help more Latvian children and give them a hope for a brighter future. 18

19 We invest into our employees The Best Land-based Casino Operator of the Year, 2013 by Totally Gaming Awards in 2013 Finalist of The Best Land-based Casino of the Year, 2013 Olympic Casino Eurovea, Bratislava, Slovakia, by Totally Gaming Awards in 2013 The Marketing Deal of the Year ECA, 2013 Promotion of the international show-bartender competition Flairmania The Best Dealer - European Dealer Championchip, 2011 LIISA RENNSTEIN - Dealer, Reval Park Hotel & Casino, Estonia The Best Bartender - World Championchip, 2007 KRISTA MERI - Bartender, Reval Park Hotel & Casino, Estonia 19

20 Dynamic and developing operator Olympic Casino is a full member of European Casino Association Olympic as industry leader The team of OEG is one of leaders, and they have turned the company into leader a leader in innovation, a leader in corporate social responsibility and a leader in driving the entire global gaming industry forward. Frank Fahrenkopf President and CEO of the American Gaming Association State of art layout and interior design Olympic Casino interiors are winning interiors. They are both beautiful and emotional. Their sensuous and delight-promoting designs enable a strong experience and pleasure for their customers. They are, at the same time, contemporary and classical. David Kranes US casino interior design expert Olympic as innovations leader You were the first operator to bring EZ Pay cashless solution to Europe. You were the first operator in the world to sign up for the IGT Cloud, bringing the benefits of server-based gaming to venues of any size. Patty Hart President and CEO, IGT 20

21 H Gaming Revenues up 5.7% y-o-y Gaming Revenue Bridge by Segments ( 000 ) ,251 Gaming revenues H Quarterly Sales Revenue (m ) ,721 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q ,650 Estonia Latvia Lithuania Poland Slovakia Belarus Italy Gaming revenues H Estonia and Latvia accounted both 23% of total gaming revenues as at end H Active operations in Italy since November 2012 Belarusian market suffering from new regulation, which requires customer identification Existing casino chain with 17 locations acquired in Latvia on 28 June 2013 Total Revenue Mix by Segments Estonia Latvia Lithuania Poland Slovakia Belarus Italy 20% 12% 2% 3% 15% H m 24% 24% 21

22 H Operating Profit up 6.4% y-o-y Operating Profit Bridge by Segments ( 000 ) Quarterly Operating Profit (m ) ,721 EBIT H , Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q ,473 Estonia Latvia Lithuania Poland Slovakia Belarus Italy EBIT H Profitability impacted largely on taxation regulations in each country Additionally, profitability of Lithuania and Slovakia impacted by opening of new casinos While Latvia accounted for 48% of Group s operating profit the y-o-y growth was highest in Poland. Operating Profit Mix by Segments Estonia Latvia Lithuania Poland Slovakia Belarus Italy 10% 16% 3% H m 48% 23% 22

23 H EBITDA down 3.3% y-o-y EBITDA Bridge by Segments ( 000 ) , ,674 Profitability impacted largely on taxation regulations in each country as well as lower depreciation Additionally, profitability of Lithuania and Slovakia impacted by opening of new casinos Quarterly Operating Profit (m ) EBITDA H Estonia Latvia Lithuania Poland Slovakia Belarus Italy EBITDA H Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q Operating Profit Mix by Segments Estonia Latvia Lithuania Poland Slovakia Belarus Italy 16% 12% 6% 1% H m 43% 22% 23

24 Estonia Estonian gaming market: Market volume: 52 million 9 casino operators Olympic Casino in Estonia: Established market leader Market share 54% 18 casinos, including the country s largest casino Reval Park Hotel & Casino 18 gaming tables, 741 slot machines 531 employees «Reval Park Hotel & Casino, Tallinn» Main Competitors: Pafer 14% Grand Prix 11% City Casino 7% 24

25 Latvia Latvian gaming market: Market volume: 150 million 16 casino operators Olympic Casino in Latvia: The second largest casino operator Market share 22% 38 casinos, including the country s largest casino Olympic Voodoo Casino 18 gaming tables, 1,018 slot machines 652 employees «Olympic Voodoo Casino, Riga» Main Competitors: Alfor and Admiralu Clubs together (Fenikss) 44% Joker 14% 25

26 Lithuania Lithuanian gaming market: Market volume: 18 million 4 casino operators Olympic Casino in Lithuania: Established market leader Market share 72% 12 casinos, including the country s largest casino Olympic Casino in Radisson Blu 65 gaming tables, 420 slot machines 626 employees «Olympic Casino in Radisson Blu, Vilnius» Main Competitors: Nese Pramogu Bankas 16% VSGA (Tornado) 12% 26

27 Poland Polish gaming market: Market volume: 214 million 3 casino operators Olympic Casino in Poland: The second largest casino operator Market share 12% 3 casinos, including the country s largest casino Olympic Casino Sunrise 38 gaming tables, 266 slot machines 352 employees «Olympic Casino Sunrise, Warsaw» Main Competitors: ZPR and Orbis together ~ 25% (estimation) Casinos Poland 16% 27

28 Slovakia Slovak gaming market: Market volume: 17 million 3 casino operators Olympic Casino in Slovakia: Established market leader Market share 76% 5 casinos, including the country s largest casino Olympic Casino in Carlton hotel 52 gaming tables, 263 slot machines 264 employees «Olympic Casino in Carlton, Bratislava» Main Competitor: Casinos Slovakia 18% 28

29 Belarus Belarusian gaming market: Market volume: 38 million (estimation in Minsk) 18 casino operators Olympic Casino in Belarus: Market share 9% 5 casinos 232 slot machines 80 employees Main Competitors: Maxbet ~ 29% (Minsk, estimation) 29

30 Italy Italian VLT market: Market volume: 5.0 billion 10 concessions, 56,500 VLT licenses Olympic Casino in Italy: 2 VLT gaming halls 638 m slot machines 20 employees Opening new VLT gaming halls: 4 VLT gaming halls 320 slot machines 80 employees 30

31 Upgraded Online Casino Services January 2010 July August 2013 Olympic Casino Eesti AS, OEG subsidiary, received the first Estonian online gaming license Olympic Casino Latvia SIA, OEG subsidiary, received the second Latvian online gaming license Launching online casino games, poker and sports betting under the new brand OlyBet. 31

32 New Casino Hotel Project in Estonia Hilton Tallinn Park 202-room upscale hotel to be operated by Hilton Total cost of ca 36 million euros Opening planned to December 2015 Casino at 1,600 m 2 will be holding separate areas for slot machines, gaming tables and club poker, special area for VIP players, spacious casino bar with stage area and comfortable lounge. Hotel includes: 202 rooms 26 suites Restaurant seating 122 SPA with pool, fitness centre and saunas Conference rooms seating

33 Thank you! 33

34 LICENCED GAMING ASSOCIATION OF IRELAND Presentation on the Heads of the Gambling Control Bill 2013 to the Oireachtas Committee on Justice, Defence and Equality. 4 October 2013 Carraig Court, Georges Avenue, Blackrock, Co Dublin T: E: licencedgaming@gmail.com Present Barry Galvin of Barry C Galvin & Son, Advisor to the Association Brian Freney, Chairman of LGAI and operator of Star Leisure, Bray CHAIRMAN and members of the Committee, thank you for your invitation to appear before you today to give you a brief overview of the Licenced Gaming Association of Ireland s observations and proposals on the Heads of the Gambling Bill Introduction The members of the Licenced Gaming Association of Ireland are all holders of current Gaming Licences and Court Certificates, and all operate in areas where Part 3 of the Gaming & Lotteries Act 1956 have been adopted. Barry C Galvin and Son has represented clients in the sector for many years and was recently involved in substantial cases where the Gaming & Lotteries Act 1956 was in issue. There are 57 licenced premises (2012) throughout the country that are mainly located in holiday/leisure and seaside locations. In most cases the businesses have been family-run for several generations and are a part of the commercial fabric of these locations. Practically all of these businesses comprise the same traditional model of two segregated business offerings. One is a family amusement area which is open to children and adults alike, while the other is a Gaming Area which is restricted to strictly over 18 s. The family amusement area machines can be split into two main categories. First there are the amusement machines, ie video shooting games, car simulator and video games, pool, air hockey, table soccer, pinball, kiddies rides, dance machines etc; secondly there are the amusement with prize machines ie, prize cranes, skill prize games, quiz prize games, redemption machines etc. Within the Gaming Area the machines would be a combination of both traditional and electronic slot machines and automatic table games etc. To maintain a gaming licence the operators must provide, on an annual basis, the following to the Court and the Revenue Commisioners: Confirm correct zoning and planning for the operation of a Gaming Arcade; Adhere to the opening and closing hours determined by the Court; Confirm that an annual inspection by the fire officer has been carried out to confirm compliance of the building; Provide a complete listing to the Court of the number and type of machines available for play; Confirm tax clearance certification; Pay the sum of 505 per machine per annum, plus a premises licence of 630; Provide amusement facilities in addition to gaming; Provide for confirmation by An Gardai Siochana that the licence has been operated in the previous 12 months in a correct manner; Provide satisfaction to the general public that the licence has been operated in the correct manner in the previous 12 months, and place ads in the newspaper advertising the notice of renewal of the licence. (continued over) Registered in Ireland No: Directors: B. Freney B. McCormick

35 Rather than restate all our observations outlined in our submission, I will restate our main recommendations under the following headings: Security of Tenure The Draft Bill does not take into consideration the past and present participation and investment of the licensed proprietors of gaming/amusement arcades. The Bill opens up a number of uncertain possibilities, in many cases without the possibility of participation or objective challenge. Some parts of the legislation might well be a disproportionate interference with the right to work/private property. We propose that there should be recognition of the existing licenced proprietors and their investment in the business. We submit that appropriate arrangements should be provided to ensure a smooth transition to the proposed new licencing regime. With regard to the number of existing gaming/amusement businesses throughout the country which have been licenced for many years and which are the source of income and employment of a large number of persons we maintain that constitutional and EU protected proprietary rights have been established, and that these cannot be taken away, except in circumstances that are proportionate to the aims sought to be achieved and on payment of the appropriate compensation. Proposed segregation of amusement and gaming areas Head 17 In the past decades it has been a legal requirement for the granting of a Gaming Licence that amusement machines be operated in the same premises as gaming. These have been, and still are, traditionally separated from each other as age restriction is relevant in the gaming area. For the reasons set out in Section 5 of our submission, it is proposed that existing and future Gaming Licence holders would be obliged to operate a supervised access-controlled doorway to separate amusement and gaming areas, and any new arrangements be implemented for future premises as part of the planning process. Opening hours Head 17 We submit that the proposed times are too restrictive and suggest that current general operating times for a 2A licence 10am opening and closing time of 2am should continue for existing licence holders. These times are already licenced by the Court, are adhered to by the licenced operators, and are the business model to which they have scaled their businesses over recent decades. It is also important to note that the critical time-frame of 11pm to 2am, especially on weekend nights, is pivotal to the commercial viability of the industry. Additionally, the fact that the main commercial competition comes from the same machines which can be played online 24 hours a day should be taken into consideration. We also propose that the closing time for a 2B licence should be 10.30pm all year round, with the additional facility to grant a seasonal extension to allow for festivals and other activities associated with holiday/leisure and seaside locations. Definition of an Amusement Machine The definitions at (ii) and (iii) of an amusement machine are contradictory and do not adequately reflect what exists at present. An amusement machine that is intended exclusively for amusement purposes should be defined as a different category and distinct from an amusement with prize machine on which one can obtain a benefit. We propose that the two definitions namely amusement machines and amusement with prize machine be included in the new legislation We also propose that the amusement hall/amusement arcade definition should read fixed facility providing amusement and amusement with prize machines, open to adults and young persons Prohibit the use of Gaming Machines in Bookmakers We submit that gaming machines should be totally prohibited in bookmakers. We agree with The Report of the Casino Committee which states: the Committee recommends that gaming and betting be treated as two completely separate types of gambling activity, which raise very distinct regulatory issues and which should be treated separately in any regulatory arrangement. The Committee considers that this is fundamental for the regulation of gaming. The Committee recommends that there should be no betting of any kind permitted on or in any licenced gaming premises. Likewise there should be no gaming activity of any kind permitted on or in any betting or bookmakers premises Head 73: Promotions and Gambling LGAI is totally opposed to the promotion of any gambling event, or service, by way of direct communication to individuals, and believes the prevention of such activity is for the protection of vulnerable persons from risks to their well-being arising from gambling. (continued over)

36 Establishment of Fund LGAI very much welcomes the establishment of the fund in Head 77 and acknowledges the purposes of the fund. We would very much appreciate the consideration of the national gambling addiction centre Tiglin when considering the allocation of funding. The LGAI is currently working closely with Tiglin and believes the countrywide services it provides are the best available. We also welcome the self-exclusion register as detailed in Head 71. Establishment of an Interim Gaming Regulation Authority it is blatantly obvious as set out in Section 2 of our submission (Factual Information) that the current situation is one of large numbers of unlicenced machines being operated nationwide. Apart from adversely impacting on the existing 57 Licenced Gaming Operators, it also endangers the public at large. Gaming machines are known to be operated in casino s, private members clubs, gaming arcades, amusement arcades, bingo halls, take-aways, public houses, sports and social clubs, taxi rank offices and other similar venues. This situation needs to be resolved immediately. To this end LGAI totally supports the idea (until the new Act is in force) of the establishment of an interim authority. This would be specifically to: Prevent unlicenced operators currently operating 24-hour gaming so as to protect the vulnerable from risks to their well being arising from gambling; Protect the jobs of the people working in licenced gaming/ amusement arcades; To stop substantial revenue being lost to the state; To prevent unlicenced slot machines being operated in unlicenced premises. The Draft Bill contains many fundamental changes and sometimes vague and complicated concepts. The LGAI submits that it should be simple to adopt the submissions contained herein so as to facilitate an early overhaul of the sector in a structured fashion. This could be done by adopting best practice as already being delivered by licenced operators throughout Ireland; clarifying and simplifying the law; preserving existing properly-licenced businesses; and addressing illegal operations by permitting them to be licenced where appropriate, or closing them down where thought necessary We would like to thank the Chairman, and the Committee, and welcome any questions. (continued over)

37 Townspark, Cahir, Co Tipperary /10/13 Alan Guidon Clerk to the committee, Gambling Control Section Department of Justice. Opening Statement to Joint Committee on Justice Defence & Equality Re: Gambling Bill by Paul J Mullins of the Aiseiri Group. The Aiseiri group established in Cahir County Tipperary in 1983, has Primary Addiction Treatment Centres in Counties Tipperary, Wexford & Kilkenny, and a Half-Way house in Waterford. We are pleased to be invited to place our views and experience in working with problem and pathological gamblers to this committee. Aiseiri has two adult treatment centres in Wexford and Tipperary, and an Adolescent centre in Ballyragget Co Kilkenny. The adult centres take 12 residents for a 4 weeks residential treatment programme, and the adolescent centre works with 15/21 year olds male and female for a six weeks residential treatment programme. Since its foundation Aiseiri has been working with problem gamblers using the 12 step recovery programme. This programme has proved successful for hundreds of thousands of people suffering from alcohol, drugs, and gambling addictions. The most important thing about the 12 step programme lies in the fact that it works. However due to the changing and challenging nature of problem gambling including internet and gambling on social media sites we have developed individual treatment plans based on the gambling clients pathway model. We follow best practise in the area and therefore offer value for money in terms of a better treatment episode for all those presenting with a gambling problem. We assess using the South Oaks Gambling Screen and the Diagnostic Statistical Manual (DSM) 5 of the American Psychiatric Association. We are happy that the gambling bill includes treatment, education, and research. Aiseiri will conduct research on past and current residents over a two year period 2012/13 and present same to the dept in early 2014 which we hope will assist in the final legislation. We would recommend that education on the dangers of gambling/betting be introduced to all secondary and tertiary education in Ireland. That a prevalence study be carried out to determine numbers and those in danger of moving from social gambling to problem gambling. Over the past few years, and certainly since the financial crisis in Ireland, we have witnessed an increase in those presenting with a gambling problem. The financial implications for a pathological gambler and his family are for the main part long term

38 placing a huge burden on both those suffering from this insidious addiction and their families. We would like to work with all concerned including the gaming and betting industry, in helping the problem gambler. We need to work together and the provision of a statutory framework and a fund as is the case in the UK is to be welcomed. For far too long gambling has been seen as the poor relation of the other main addictions currently affecting Irish society, i.e. Alcohol/Drugs. It destroys as many if not more lives; research suggests that there is a higher rate of suicide among problem gamblers than in the other addictions mentioned. Gambling has been called the hidden addiction and those of us working at Aiseiri have witnessed first-hand the devastation wrought by gambling. We agree with the compulsory training of staff in terms of recognising incidences of potential problem gambling with their customers. This alone may help in the reduction of pathological gamblers as we recognise that a small cohort of the gaming/betting industry s customers, contribute a disproportionate amount of their profits. We have gained invaluable experience in working with problem and pathological gamblers across our adult and adolescent centres and have previously conducted research among adolescent gamblers in residential treatment. ( Paul J Mullins 2008/9) Paul has also completed a short research study with members of Gamblers Anonymous both studies available at Acadamia.org, and sent to the Minister for Justice Dept. We hope to be able to offer a day programme for problem gamblers in 2014 as not all can avail of a four week long residential treatment episode, and costs remain a hindering factor for those seeking help. I would like to take this opportunity to thank the committee for the invite and wish them the very best in their endeavours to complete the gambling bill. Paul Conlon. CEO Aiseiri Group. Paul J Mullins. MACI MEASG MICPT Addiction Counsellor, Researcher, Lecturer.

39 Oireachtas Committee e on Justice, Defence and a Equality Rehab Group Presentation on the Gambling Control Bill 2013, General Scheme Good afternoon, Deputies, Senators, ladies and gentlemen, I would like to thank you for inviting i us to address you here today. We welcome this opportunity to emphasise some of our keyy concerns in relation to t the General Scheme of the Gambling Control Bill The Rehab Group operates Ireland s largest charitable lottery and we are particularly alarmed about proposals included in the Scheme in relation to such lotteries. We believe that the implementation of current proposals would result in the complete elimination of charities from the lottery marketplace, because of the preferential and discriminatoryy position afforded to the National Lottery. This will increasee dependence on Exchequer funding and increase charities reliance on other types of fundraising, which have also been seriously impacted by the recession. Over the past threee decades, the impact of the National Lottery on Rehab ss lottery activities has been catastrophic, due to the t unfair legislative regime currently in place. In 1987, Rehab held a strong 25% share of the lottery market. In 1989, following two yearss of operation by the National Lottery, our market share had dropped to just 5%. Today our market share is just 1%. In 1996, following many years of negotiations with the charitable lottery sector, the Government introduced the Charitable Lottery Compensation Fund. F This recognised the t inability of charitable lotteriess to competee with the National Lottery as a result of the severe s restrictions created by the cap on prize funds provided for underr the Gaming and Lotteries Act No restrictions apply to the prize funds of the National Lottery. 1

40 In 2012, the Government took the shocking decision, without consultation, to phase out the Charitable Lotteries Compensation Fund. In this context, a complete removal of the cap on prize funds would be the only correct and legal approach. However, the General Scheme continues to place an absurdly low cap on the prizes which can be distributed by charitable lotteries. It limits the monthly prize fund to 400,000 while the National Lottery can offer unlimited prizes and has offered weekly prize funds of up to 190 million, through the Euromillions lottery. The limit of 1,750 on scratch cards will have a particularly catastrophic impact on charitable lotteries as it reduces the current prize fund limit by 82.5% and will render them entirely unattractive to consumers and, therefore, uncompetitive in the lottery market place. In the absence of a fair and reasonable charitable lottery compensation fund, we urge the Committee to recommend that the cap on prize funds be removed entirely, to ensure fair competition and to prevent abuse of dominance in the marketplace by the National Lottery. This is an issue which, we believe, must be rectified before the sale of the National Lottery is completed. The Scheme further exacerbates issues in relation to competition in the market place by failing to recognise the size of lotteries in its requirements for a minimum charitable contribution. We propose that the proceeds of a lottery be defined in terms of net gaming revenue the money that the charity actually receives after the payment of prizes. This is the approach which has been adopted for the National Lottery. A rising scale of charitable contribution would ensure that the bigger the lottery, the greater the percentage paid to good causes. Overall, we have grave concerns about the structures which will underpin the regulation of gambling and lottery activities in Ireland. Instead of the establishment of an office, located within the Minister s Department, to oversee a small number of gambling and lottery activities, we propose the establishment of a specific regulatory authority, with an independent board, which is fully transparent and beyond political influence, charged with overseeing the operation of all gambling and lottery activities in Ireland. 2

41 Unfortunately, it is the case that, in the absence of a fair and reasonable charitable lottery compensation fund and, in light of the current proposals to continue to cap prize funds for charitable lotteries, the future of charitable lotteries is very bleak. It is likely that many of the legislative proposals provided for in Head 19 will quickly become obsolete, as this anticompetitive legislation fully eliminates the ability of the charitable lotteries to compete in the market place and, therefore, their ability to operate at all. We would like to thank the Committee for its attention and would be pleased to answer any questions that you may have. Thank you. 3

42 BET BEWARE LIMITED GAMBLING CONTROL BILL 2013 PRESENTATION NARRATIVE FOR JOINT ALL PARTY COMMITTEE MEETING DAIL EIREANN WEDNESDAY 9 TH OCTOBER 2013

43 INTRODUCTION: Bet Beware Limited is a not for profit organization that was established by a group of concerned individuals with backgrounds in the betting and gambling businesses. It has the objective of focusing on the very real issues of a social and economic nature associated with all forms of betting/gambling activity that impact on individuals and society in general. Whilst the organization neither condones nor condemns betting/gambling it holds the opinion that betting/gambling, contrary to industry spin, is not in the main entertainment or fun. In the vast majority of cases individuals participate in betting/gambling with the real or imagined expectation that they will win. Most lose and many experience anxiety and varying degrees of depression as a consequence of the losses. This presentation to day coupled with our response document is an attempt to present our views to the persons responsible for the drafting of the legislation for eventual presentation to The Oireachtas. In the main the response focuses on the off course betting industry, an industry where certain members of our group have extensive business experience. It is however the intention of Bet Beware to engage with OGCI when it is established in an effort to influence various aspects of the actual regulatory framework. However to use a phrase borrowed from Head 33/Page 43 of the General Scheme document there is a serious disparity in the matter of Equality Of Arms for organizations such as ours in engaging with government on this issue by comparison with the vast resources that the off course betting industry have up to now committed and will continue to commit into the future in its efforts to ensure that legislation is structured that favours the profit and greed driven objectives of most, but not all, of its members to the detriment of not only the poor and vulnerable members of society but of society in general. The Off Course Betting Industry would like to think of itself as well regulated. However one of its most senior former executives and founder of a major bookmaker enterprise has stated that over the years it has been able to drive a coach and four through the Betting Act 1931 helped in no small measure by the inability of An Garda Siochana to monitor and enforce the 1931 Act. So much for a sense of Social Responsibility!. Bet Beware believes that unless the legislation is rigid in structure and the OGCI monitors the industry in a comprehensive and detailed manner then a coach and four will be driven through this new legislation also by the off course betting industry. HEAD 1 DEFINITIONS & INTERPRETATIONS: 1. The definition of a Bet should be defined in more precise detail for the protection of users of betting services and in particular in the interests of fairness and transparency. The definition could be a bet is a wager made on an event to be decided in the future. It is important that decided in the future should be part of the definition. It is universally accepted that a bet is a wager made on an event that is decided in the future rather than commenced or started in the future. 2. The definition of Betting should exclude any reference to Virtual Events. Serious doubts exist about the integrity and fairness of Virtual Events. There are reasons to believe that the result is known before the event takes place i.e. concluded or finished. There have been instances in the past

44 year alone where results cards have appeared on television screens in betting shops declaring the result before the advertised start time of the actual event. Bet Beware believes that there should be a prohibition on Virtual Events in the new legislation and that this prohibition should not be considered for repeal until such time as the OGCI have undertaken a detailed investigation into all aspects of Virtual Events. 3. The definition of Fixed Odds Betting Terminals needs to be particularly looked at so as to eliminate all possible loopholes. The stakes in terms of profit are so high for the bookmakers and the consequences for communities, families and individuals potentially so disastrous that it is imperative that government ensure that the definition is rigid and not open to interpretation by the array of lawyers that the major bookmakers have lined up to take on the government on this issue alone. With a population of something like 800 shops owned by the 7 major operators the potential profit [not turnover] from FOBT s using UK figures as a guideline is a mind boggling 150 million per annum. That is money that they intend to take out of the pockets of the poor, vulnerable, depressed, or simply foolish individuals at a time when the various welfare agencies both state run and charitable are unable to satisfy the demands being put upon them for help. Perhaps a current government Minister, Mr. Pat Rabbitte, described these devices and all their guises accurately when he addressed an industry forum entitled Irish Casino Review A Regulatory Update organized by A.L. Goodbody in October To the consternation of the assembled, with a small number of exceptions, he described FOBT S as THE CRACK COCAINE OF GAMBLING. 5. The definition of Licensed Bookmakers should contain a form of words that incorporates the suggested additional words that should be used in the definition of a Bet. A suggested definition is as follows: A Licensed Bookmaker shall be a person and/or company who is the holder of a Bookmakers License issued under this Act to engage in betting on events to be decided in the future. HEAD 2 COMMENCEMENT, TRANSITION, SHORT TITLE: 1. Paragraph 2 [vi] states that having a betting or gaming licence...does not confer any expectation, entitlement or presumption as to the granting of licence under this Act in relation to the same or similar service. It should be made clear that same or similar service includes the same and/or similar betting products provided by the bookmaker in the past and the fact that particular products were provided in the past does not mean that there can be an automatic presumption by the bookmaker that they can be or will be entitled to provide them as soon as the new Act becomes law. This is particularly important because it is the opinion of Bet Beware that television screen Roulette, a gaming product that is not permitted in betting shops under section 19[3] Betting Act 1931 and chapter 5 of Gaming & Lotteries Act 1956, was introduced by predominantly I.B.A. members and Paddy Power in the past two years in an effort to establish a FOBT type product in advance of the new Act coming into being and to then make the case to government that it is an over the counter business established for a number of years. Incidentally this television screen Roulette was introduced in late 2010 despite the fact that in the government Regulating Gaming In Ireland report published in 2006 it specifically stated in chapter of page 82 that gaming and betting be treated as two separate activities and that no gaming activity of any type be permitted in betting shops and in chapter of the same page that Roulette was

45 categorised as a gaming activity. In total disregard for what was stated in and television screen Roulette was introduced in late HEAD 4 PRIMARY PURPOSES: 1. Paragraph [i] refers to fairness in the conduct of gambling. A key feature of this concept is that if you cannot win then you cannot lose. In this respect Bet Beware is aware from its research that there are increasing instances of gamblers not being paid winnings when they present a docket for payment on the basis that the bet was placed after the off time of the event. This is particularly the case in respect of Virtual Events. However the gambler only discovers this when presenting a docket for winnings. The legislation needs to include a clause compelling bookmaker shops to display a late bets register so that gamblers can access this register. Furthermore, it should be stipulated that after a specified period of time all unclaimed stakes derived from late bets must be remitted by the bookmaker to the Social Responsibility Fund and that such remittances be in addition to the agreed payments to the fund. HEAD 6 MINISTER TO DESIGNATE OFFICERS AND CERTAIN FUNCTIONS: 1. Bet Beware believes that It is absolutely imperative from the perspective of the operations of the OGCI in the best interests of government and the general public that no representations are considered from any past or current employees of bookmakers or their trade associations for any position whatsoever at OGCI. HEAD 17 SPECIFIC MATTERS AFFECTING PARTICULAR ACTIVITIES AND LICENCES: 1. Paragraph 3[v] states that no cash transactions may take place for the remote betting. It needs to be made perfectly clear that no cash transactions also means that the sale of credits and/or vouchers over the counter to gamblers to enable them to participate in remote betting whilst present in a shop is also prohibited. 2. Paragraph 8 [ii] also states that there shall be no cash transaction permitted for remote gaming. Again it needs to be made perfectly clear that cash transactions are not permitted for any gaming activity that might be made available in shop from a remote device/location and transmitted into the shop and displayed by the means of a television monitor. 3. Paragraph 16 states that all transactions for remote gambling must be by electronic cash transfer. Once more there will be a need to make perfectly clear that electronic cash transfer means from the gamblers bank account to the bookmakers bank account and not to mean that the gambler can transfer cash over to the bookmaker at the counter using a bookmakers deposit account cards that have become the subject of sustained advertising by some bookmakers in recent times. HEAD 18 MATTERS SPECIFIC TO CASINOS AND CASINO GAMES: 1. Paragraph 4[1] of Part B states that casino games may be played on a table in premises that have been specified in category 2R licence and in no other place or premises. It is an accepted fact

46 throughout the gambling community worldwide that Roulette is a casino game. Accordingly Bet Beware believes that Roulette whether live or virtual should not be permitted under the new legislation and that it should be made clear in the legislation that Roulette in all its guises will be regarded as a prohibited activity in betting shops. 2. Paragraph 8[v] of Part D states intoxicating liquor shall not be brought into or consumed in the area reserved for casino gaming. Bet Beware believes that certain betting shop operators have over time deliberately located shops either in public house car parks or immediately adjacent to public houses and that this is not in the best interest of gamblers because of the potential for diminished judgement occasioned through the intoxicating effect of alcohol. There should be a clause in the new legislation prohibiting the location of a betting shop in a public house car park and/or within a specified distance of a public house. HEAD 29 PUBLIC NOTICE OF INTENTION TO APPLY: 1. In addition to the requirements proposed under Paragraph 1 of this head there should be a requirement that a copy of the application must be affixed to an exterior door/wall of the premises accessible to the general public in similar manner to planning permission applications. In the case of applications for licences for multiple premises a copy of the notice of application should be affixed to each and every premises. HEAD 33 HEARINGS AND ORAL SUBMISSIONS: 1. Paragraph 4[i] makes reference to equality of arms and states that as far as possible the chair shall endeavour to ensure that it exists. Bet Beware believes that there is a very real need to ensure equality of arms right now at this pre legislation enactment stage so that organizations, such as it and also the various charitable organizations with real concerns for not only addicted gamblers and problem gamblers but also persons who simply lose too much money, can engage with government and contribute in a comprehensive and meaningful way to the drafting of the legislation. Because of the disparity of equality of arms as between the parties it has been the experience in the UK that the bookmakers have been able to dupe The Gambling Commission that the issue of FOBT addiction and/or harmfulness to society should be evidence based with the onus on organizations opposed to UK to provide the evidence. Bet Beware agrees with an evidence based approach and believes that the bookmakers should produce the evidence that FOBT s and/or FOBT related products in all their guises are not addictive or harmful. Bet Beware believes that in Ireland the government, particularly in these times of economic collapse, should be unrelenting and that in relation to all betting and gaming products that the onus be put on the bookmakers to provide evidence or alternatively a compelling written justification to show that the betting/gaming products are harmless rather than harmful. HEAD 43 FEES IN RESPECT OF LICENCES: 1. Paragraph 1[iii][a] suggests that there should be a fixed fee in respect of betting shops. Bet Beware believes that the fee should be variable and not fixed and should be based on a number of factors including but not limited to location, opening hours, terms/conditions of trading and turnover.