This paper constitutes the response of Betfair Group plc to the Department for ....
Football. International. FIFA Early Warning System (EWS). 10 June 2010.
WRITTEN RESPONSE OF BETFAIR GROUP PLC TO THE DEPARTMENT FOR CULTURE MEDIA AND SPORT’S CONSULTATION ON THE PROPOSED AMENDMENTS TO SCHEDULE 6 OF THE GAMBLING ACT 2005 NOVEMBER 2011 Introduction 1. This paper constitutes the response of Betfair Group plc to the Department for Culture Media and Sport’s (‘the Department’) Consultation (‘the Consultation’) on the proposed amendments to Schedule 6 of the Gambling Act 2005. 2. This submission follows the structure of the Consultation’s four questions which the Department states it would like submissions to answer. As an online gambling company Betfair does not aim to have a view on all areas of the Consultation, only those relevant to Betfair’s work with sports. About Betfair 3. Established in 2000, Betfair Group plc 1 is one of the largest UK-headquartered betting companies operating purely online. The Betfair Group has three million registered customers worldwide, and processes more than seven million transactions per day, more than all the European stock exchanges combined. Betfair employs over 2,300 people worldwide, with over half of those jobs being located at our UK offices in London, Stevenage and Halifax. 4. Betfair’s core product is the world-leading online betting exchange, a concept which it pioneered. The exchange mechanism uses technology similar to a stock exchange allowing Betfair to offset its risk perfectly by exactly matching supply and demand in a way not possible for traditional bookmakers. 5. Betfair is a British internet success story, comparable with US brands such as Google, Amazon and Facebook. Betfair has twice been named the UK’s ‘Company of the Year’ by the Confederation of British Industry and is the only online betting company to have won a Queen’s Award for Enterprise. It was awarded its first in 2003 for innovation and its second in 2008 for international trade. 6. Betfair currently holds licences to operate betting products in Malta, Gibraltar, Italy, Australia, the UK 2 and the US (through it horseracing TV channel TVG). 7. Until 2011 Betfair was one of the few remaining online gambling companies licensed, and paying Betting Duty, in the UK. In March 2011 Betfair took the commercial decision to switch its betting exchange from operating under a UK licence to a Gibraltarian one. However, Betfair’s headquarters remain in the UK and is committed to meeting at least the same social responsibility standards as required by the UK regulator, the Gambling Commission (‘the Commission’). Betfair also continues to work with the Commission’s Sports Betting Integrity Unit (SBIU) including sharing information about unusual or suspicious betting activity. 8. Betfair is committed to maintaining the integrity of sport. Betfair pioneered Memoranda of Understanding (MoU) in order to allow it to share information with Sports Governing Bodies (SGBs). Since its first MOU in 2003 with the Jockey Club (now the British Horseracing Authority) Betfair has signed 47 further permanent MOUs with a variety of sports. 3 Once an MOU is in place SGBs have access free of charge to details of the bets placed on their sport, both in real time and retrospectively. SGBs can see specific bets being made but are only given customers’ identities if investigations make it necessary. As well as access to the information SGBs can liaise with Betfair’s 8-person Integrity Team whose skill sets include investigation and intelligence analysis, anti money laundering expertise and a full understanding and ability to participate in disciplinary proceedings.
Betfair became a public company in October 2010 entering the FTSE 250: http://corporate.betfair.com/ Betfair retains UK licence software development but is not transacting business under it. 3 A full list of Betfair’s current MoU partners is in the appendix of this document. 1
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Question 1: Do you agree that the International Olympic Committee should be added to Schedule 6, Part 3 of the Gambling Act 2003? Please provide reasons for your response. 9. Betfair agrees that the International Olympic Committee (IOC) should be added to Schedule 6, Part 3 of the Gambling Act 2003. Betfair has had MoUs in place with the IOC for the Beijing and Vancouver Games and also has one in place for London 2012. Betfair fully supports further co-operation between the Commission and IOC. Question 2: Do you agree with the bodies proposed to be added to Schedule 6, Parts 2 and 3 of the Gambling Act 2005? Please provide reasons for your response. 10. Betfair agrees that the bodies proposed should be added to Schedule 6, Part 3 of the Gambling Act 2003. Betfair already has MoUs in place with the BDO (British Darts Organisation), PSA (Professional Squash Association), IOC, ICC, UEFA, FIFA EWS, WPBSA and Tennis Integrity Unit 4. Betfair accepts bets on the sports governed by the IRB and so supports increased cooperation between the Commission and this SGB. Questions 3: In addition to the SGBs listed on Part 3 of the Schedule, are there any other bodies you think should be on the list? Please provide reasons for your response. 11. Betfair believes it is in the interest of the vast majority of sports to establish information sharing agreements with regulators and betting operators where possible. However, this is a decision for each sport to take and therefore not something Betfair wants to comment on at a specific SGB level. Question 4: Do you agree that the criteria requiring an impact assessment do not apply? If not, please explain why and include details of the burdens and/or costs that you believe will result from these proposals. 12. Betfair agrees the criteria requiring an impact assessment do not apply.
Please note that the Consultation refers to International Tennis Federation when the correct reference would be Tennis Integrity Unit (TUI) as it is the body charged with the responsibility of ensuring the integrity of the sport. 4
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CONFIDENTIAL and not for reproduction without prior written consent © of The Sporting Exchange Limited
Appendix Betfair’s Memoranda of Understanding (as of November 2011) Sport
Country
Governing Body
Date Signed 16 February 2011
Horse Racing
Australia
Victoria Racing
Squash
International
Professional Squash Association
7 February 2011
Horse Racing
New Zealand
Racing New Zealand Board (NZRB).
21 January 2011
Horse Racing
Australia
Racing Queensland Limited
12 July 2010
Football Greyhound Racing
International
FIFA Early Warning System (EWS)
10 June 2010
Australia
Greyhound Racing Victoria(GRV)
01 January 2009
Tennis
International
Tennis Integrity Unit (TIU)
01 January 2009
Horse Racing
Australia
Harness Racing Victoria
11 November 2008
Snooker
Global
World Snooker Ltd
03 October 2008
Ice Hockey Greyhound Racing
USA
National Hockey League (NHL)
01 October 2008
Australia
Greyhound Racing New South Wales (GRNSW)
08 September 2008
Horse Racing
Australia
Racing New South Wales (RNSW)
08 September 2008
Horse Racing Greyhound Racing
Australia
Harness Racing New South Wales (HRNSW)
08 September 2008
Australia
Greyhound Racing SA Limited (GRSA)
30 July 2008
Horse Racing
Australia
Thoroughbred Racing South Australia (TRSA)
30 July 2008
Horse Racing
Australia
Harness Racing SA
30 July 2008
General
Global
International Olympic Committee (IOC) - only during the Olympics itself
28 July 2008
Horse Racing
Australia
Racing and Wagering Western Australia (RWWA)
04 April 2008
Rugby Union
Australia
Australian Rugby Union (ARU)
04 April 2008
Tennis
Deutscher Tennis Bund
04 February 2008
Soccer
German Republic of Ireland
Football Association of Ireland (FAI)
04 October 2007
Soccer
Australia
Football Federation of Australia (FFA)
10 September 2007
Rugby League
Australia
National Rugby League (NRL)
22 May 2007
Tennis
Australia
Tennis Australia
15 January 2007
Golf
PGA Tour of Australasia
15 November 2006
Horse Racing
Australia Republic of Ireland
Irish Turf Club (ITC)
10 October 2006
Soccer
Northern Ireland
Irish Football Association (Irish FA)
01 September 2006
Horse Racing
Australia
Racing Victoria Limited (RVL)
7 July 2006
Horse Racing
Australia
Racing Service Tasmania
5 July 2006
Soccer
Belgium
Royal Belgian Football Association (RBFA)
14 February 2006
Darts
International
British Darts Organisation (BDO)
04 February 2006
Rugby Union
England
Rugby Football Union (RFU)
31 January 2006
Australian Rules
Australia
Australian Football League (AFL)
26 October 2005
Tennis
International
Womens Tennis Association (WTA)
25 October 2005
Tennis
Great Britain
Lawn Tennis Association (LTA)
03 October 2005
Tennis
International
International Tennis Federation (ITF)
27 September 2005
Tennis
International
Grand Slam Committee
19 September 2005
Horse Racing Greyhound Racing
USA
18 February 2005
Great Britain
The Thoroughbred Racing Protective Bureau (TRPB) Greyhound Board of Great Britain (GBGB - formerly the National Greyhound Racing Club)
Soccer
European
Union of European Football Associations (UEFA)
19 January 2005
Rugby League
Great Britain
Rugby Football League (RFL)
07 December 2004
Horse Racing
South Africa
National Horseracing Authority
22 September 2004
Cricket
Australia
Cricket Australia
30 April 2004
Soccer
England
Football Association (FA)
25 March 2004
Cricket
International
International Cricket Council (ICC)
24 January 2004
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CONFIDENTIAL and not for reproduction without prior written consent © of The Sporting Exchange Limited
26 January 2005
Darts
International
Darts Regulation Authority (DRA)
18 December 2003
Tennis
International
Association of Tennis Professionals (ATP)
01 October 2003
Horse Racing
Great Britain
British Horseracing Authority (BHA)
16 June 2003
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