Power Leisure Bookmakers Limited response to Hounslow Borough Council s Consultation on its draft Statement of Gambling Principles Paddy Power is Ireland s biggest Bookmaker and operates both a retail business through licensed betting offices and an online/telephone business. Paddy Power operates 251 licensed betting offices in Ireland and 325 betting offices in the United Kingdom. Paddy Power is a leading national operator of betting premises with clear and proactive policies to promote the Gambling Licensing Objectives. Operators of premises licences have full authority to provide their services by the provision of an Operators Licence granted by the Gambling Commission. The UK s gambling regulator has therefore approved the measures implemented by operators to ensure that effective anti-money laundering procedures are implemented and that policies have been developed that ensure responsible trading in accordance with gambling legislation, the licensing objectives and the Licence Conditions and Codes of Practice. Of particular relevance are the obligations and requirements now placed upon operators under the social responsibility provisions of the LCCP, which were introduced by the Gambling Commission earlier this year. Sections 9.3 and 9.4 We strongly disagree with the commentary included in the draft policy as it does not appropriately identify the permissive regime envisioned by Parliament and implemented by the Gambling Act 2005. Comments relating to the undue limitation of the Council s ability to deal with and curb the proliferation of betting shops and control the quantity of FOBTs available fail to consider the extensive social responsibility provisions now contained in the governing legislation. The reduction of stake and prize limits for fixed odds betting terminals is a matter for consideration by Parliament and may be addressed by central government consultation. The Authority s policy, as per section 349 of the Gambling Act 2005, should contain the principles that it proposes to apply in exercising its functions under the Gambling Act 2005. The statement of principles is therefore not an appropriate document to contain additional commentary, which is beyond the scope of the policy s function, and it should be removed. Any finalised policy must not suggest that gaming related applications pose an inherent risk to the local population, regardless of status or evidence of actual harm. Where operators are asked to mitigate any perceived risks, sufficient parameters should be identified addressing the specific risks concerned relative to those individuals who may be at risk from the grant of any proposed application. Document Ref : 2145163089
Conclusion We are committed to working in partnership with the Gambling Commission and local authorities to continue to promote best practice and compliance in support of the licensing objectives. Document Ref : 2145163089 Page 2 of 2 P38407/784
Lewis Aldous Licensing Manager London Borough of Hounslow REDe (Licensing Team) Civic Centre Lampton Road Hounslow Middlesex TW3 4DN 11 th December 2015 Dear Lewis, Consultation on the London Borough of Hounslow s Statement of Principles Gambling Act 2005 Coral Racing Limited is most grateful to be given the opportunity to respond to this consultation exercise. Coral was one of the first national bookmakers to be licensed under the Betting and Gaming Act of 1960, and so has been operating the length and breadth of the UK for over 50 years. Its premises comprise locations in the inner city, on the high street, in suburbs and in rural areas, and in areas of both high and low deprivation. It now operates 1850 betting offices across Great Britain, which comprise about 20% of all licensed betting offices. It is, therefore, a highly experienced operator. Coral Racing Limited are broadly supportive of the document but does have feedback on a section which we do not think should be included which is detailed in the 2 nd page of this response. Coral Racing again notes that the Board when considering applications are still required to aim to permit gambling where this is reasonably consistent with the licensing objectives, additionally noting that it should not take into account of any moral objections to gambling. Coral Racing Limited recognise the requirement to supply risk assessments with future applications and variations (requirement is from 6 th April 2016) following the consultation completion and are pleased to see this information included within your document. Coral s experience is that through all it does, it achieves an exemplary degree of compliance already, and attracts negligible evidence of regulatory harm. Through the additional local risk assessment to be introduced, Coral believe that these should be a) to assess specific risks to the licensing objectives in the local area, and b) to assess whether control measures going beyond standard control measures are needed. A number of Council s have created long lists of locations which by inclusion are required to be risk assessed & often with strict templates to be completed. Coral are of the opinion that as there is no evidence that the proximity of such locations causes harm to the licensing objectives, it is best left to the operators to provide their own risk assessments. Naturally, if these do not meet the level desired by the Council, we would adjust to suit. For your information we are in the process of agreeing our format for these risk assessments with Westminster City Council and if you would like us to share this with you prior to the introduction of the new requirement, we would be willing to assist. 1
Your draft statement makes comments within sections 9.3 & 9.4 regarding FOBT s and their style of gaming. Within section 9.3, the statement includes the phrase The view of the Licensing Authority is that our ability to deal with and curb the proliferation of betting shops in town centres and high streets as well as controlling the quantity of FOBTs available is severely restricted under the Gambling Act 2005. The Draft Statement should not include inaccurate references like this and terminology which appears to position well operated businesses on the edge of legality. As has been well documented, the actual number of betting premises is declining and whilst they may be moving to different shopping locations, this has largely previously been due to planning regulations as well as being located simply where footfall is higher. Betting shops have had their planning use class changed over the last 12 months and Councils now have the ability to scrutinise new applications with greater rigour as they are all classed under a sui generis planning use. Your statement also includes within section 9.4, a reference to reducing stakes within the class of B2 machines. Again, in our opinion, this should not be included within the statement. Coral Racing and the wider betting industry have gone to great lengths to ensure that all customers using the facilities have the relevant information available whilst at the same time, implementing revised procedures limiting stake levels and ensuring that our 'responsible gambling' position is maintained at all times. We strongly caution against the Council adopting an individual approach to this serious matter and trust that it will ensure that any decision and opinion stated in future, is from the relevant research documentation. If we can provide any further information, we would be pleased to do so. Yours sincerely, John Liddle Director of Development Coral Retail 2
From: Licensing To: Lewis Aldous Subject: FW: Consultation on Statement of Gambling Principles Date: 22 October 2015 10:28:08 From: Marilyn Smith Sent: 22 October 2015 09:59 To: Licensing Subject: FW: Consultation on Statement of Gambling Principles Hi Lewis Thanks for consulting us. My only comment is over temporary events and fairs, where they are only allowed to be present for a limited number of days It isn t clear who would monitor and enforce that. Probably more of an internal discussion to be had, especially in the light of the new enforcement structure Marilyn Smith Head of Development Management REDe London Borough of Hounslow Office: 0208 583 4994 Follow us online: Twitter: @LBofHounslow and Facebook: www.facebook.com/hounslowcouncil From: planning comments Sent: 21 October 2015 09:30 To: Marilyn Smith Subject: FW: Consultation on Statement of Gambling Principles From: Lewis Aldous Sent: 16 October 2015 17:01 To: Licensing; 'info@gamblingcommission.gov.uk'; 'hounslow.licensing@met.police.uk'; 'firesafetyregulationnw@london-fire.gov.uk'; 'cpcc-gcsx@hounslow.gcsx.gov.uk'; Health and Safety (SM&PP); Pollution; planning comments; 'nru.betting&gaming@hmrc.gsi.gov.uk'; tradingstandards; 'info@bacta.org.uk'; 'contact@beerandpub.com'; 'sallysmith@hounslowchamber.org.uk'; 'mail@abb.uk.com'; 'info@gamblersanonymous.org.uk'; 'info@sia.homeoffice.gov.uk'; Community Safety; 'licensing@ealing.gov.uk'; 'licensing@hillingdon.gov.uk'; 'licensing@richmond.gov.uk';
'licensing@lbhf.gov.uk'; 'licensing@spelthorne.gov.uk'; 'seema.malhotra.mp@parliament.uk'; 'ruthcadburymp@parliament.uk' Cc: Nigel Farmer Subject: Consultation on Statement of Gambling Principles Dear All, The London Borough of Hounslow are required by the Gambling Act 2005 to review and publicly consult on our statement of Gambling Principles (Gambling Policy) at least every 3 years. The time has now come to consult on our new policy. It is my anticipation that the policy will be considered at a full Borough Council meeting in January 2016. I have attached to this email a copy of the draft new statement of gambling principles, a summary of the changes made and a copy of the current statement of principles for comparison purposes. The public consultation will run for 8 weeks between 19 th October 2015 and 14 th December 2015. I would welcome any comments you wish to make on the new policy by writing to me at licensing@hounslow.gov.uk before the 14 th December 2015. If you have any questions then please do not hesitate to contact me using the contact details below. Kind regards, Lewis Lewis Aldous Licensing Manager Community Safety & Business Regulations REDe Civic Centre Lampton Road Hounslow TW3 4DN 020 8583 2465