Betfair - Department for Culture Media and Sport

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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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CONFIDENTIAL and not for reproduction without prior written consent © of The Sporting Exchange Limited

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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CONFIDENTIAL and not for reproduction without prior written consent © of The Sporting Exchange Limited