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Our Submission to Government

Who we are

Gambling Act Review Submission by the Horseracing Bettors Forum

The Horseracing Bettors Forum was formed in 2015 with the assistance of the British Horseracing Authority (BHA) as an official body to represent the interests of horseracing bettors in Britain.

The current forum consists of nine volunteers from all walks of life, including a solicitor, journalists and keen racegoers.

The forum meets every quarter and liaises regularly with the British Horseracing Authority, Horserace Betting Levy Board (HBLB), Gambling Commission (GC), Starting Price Regulatory Commission (SPRC) and other stakeholder groups in racing. The HBF has progressed a variety of horseracing related issues, the priority being to put forward the views of the average bettor and their day-to-day issues.

Our voluntary status provides an independence by which we are able to put forward arguments for and against various issues, in what we believe to be a sound and logical way. This allows the HBF to be seen as an authoritative organisation that represents the viewpoint of the horseracing bettor.

Introduction

The HBF represents horseracing bettors of which the vast majority (99.5%) bet responsibly and within their means and enjoy betting on horseracing as a pastime. However, we believe that increasingly bettors are being treated unfairly by large off-course bookmaking organisations. We believe that the balance between their corporate responsibility to clients and a drive towards profitability is now skewed, and that those who choose to bet are being treated in a manner which suggests that additional regulatory mechanisms are needed to be put in place to protect those who bet responsibly.

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1. Horseracing Betting Levy (Q10)

Funding for horseracing is provided from a number of sources. However, most of horseracing’s prize money is funded through the Horserace Betting Levy which is paid from profits of bookmakers from their horseracing markets. This current arrangement being based on profit encourages a number of behaviours in bookmakers, namely a loss-leading approach to horseracing through concessions for new players and offers for existing players (including best odds guarantee, faller insurance, extra place each way betting etc.). It also encourages bookmakers to restrict players who are winning and show skill, and of more concern, it focuses bookmakers’ attentions on increasing revenue from players who often lose by promoting them to play on non-horseracing related gambling products which are considered more profitable. It can be argued that moving to a Levy based on turnover would reverse these behaviours. However, HBF believes that moving to a funding model where the Levy is based on a combination of a turnover and profit based model would be of benefit: such a scheme would allow a percentage of all horseracing bets that are taken provided to the Levy as well as a percentage (less than currently taken) of profits from horseracing bets taken. This best of both worlds approach would ensure that bookmakers are not entirely focused on gaining business from losing bettors and that growing betting on horseracing would provide additional funds for the Levy.

In February 2021 there was a gamble on three horses where bets were placed in accumulators at long odds the evening before the race. Two horses won, however if the third horse had also won the pay outs would have been substantial (reportedly costing the bookmakers millions of pounds) such a sum would have dented bookmaker profits and as a consequence could have impacted the Levy.

The HBF believe that there needs to be a shift from a solely profit-based Levy to one that embraces both a profit and a turnover based levy. This would allow the horseracing industry to promote betting on racing with the knowledge that every extra pound bet is of benefit to the industry, and that where bookmakers are making profit from the sport they make a contribution as well. However, to do so there is a need to ensure that those who bet and win even relatively small amounts, are still able to maintain their accounts and enjoy betting on horseracing. Betting must continue to be an aspirational pastime. Once a bettor sees that any additional work or effort is likely to ensure they will have their account restricted they will be much less likely to participate in sports or horseracing betting.

2. Minimum Bet Liability (Q10)

Horserace betting is for many a recreational pastime and that while it provides considerable pleasure it is a losing pursuit. For the majority these losses are an affordable cost of their hobby. Flutter recently indicated that on average their clients spend £10 a week on gambling. For some, especially for those that put additional effort into their horseracing betting, to find that after winning a few bets and making a profit their accounts become restricted is discouraging. Account closures are not new but were previously reserved for successful professional bettors.

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Today the off-course bookmakers have sophisticated systems that will automatically highlight even bettors that bet to small stakes and who show a profit after a few months.

Evidence: https://www.nytimes.com/2021/03/24/technology/gambling-apps-tracking-sky- bet.html

More concerning is that some bettors’ accounts are restricted after just one or two bets (see Appendix 5). As soon as this occurs then they are shown the “winners not welcome” sign and have their accounts restricted.

The HBF have been provided with numerous examples of where winning bettors have had their accounts restricted, and for many maintaining an account that can used to bet at reasonable levels (£20-50 stakes) is an ever increasing challenge. However, as an example, one of the HBF forum members opened an account with Bet365 and after seven months they were informed they had been restricted, the profit on the account was £280. The largest bet struck was £3 each way (£6) with most bets being of £1. This bettor is now only able to bet a few pence on any horse above 20/1.

Examples of accounts with betting restrictions are shown in Appendix 6.

In 2016 the HBF undertook a survey of horseracing bettors, 878 responded and it showed that of those responding 46% had received notification that their at least one of their betting accounts had been restricted, unsurprisingly 59% stated that having their accounts restricted had reduced their interest in the sport. The survey also revealed that few bettors were given any substantive reason for the account to be restricted, most receiving an email stating this was a trader’s decision and that further correspondence would not be entered into. Full details of the survey results can be found here.

https://ukhbf.org/account-restrictionclosure-survey/further-details-of-hbfs-account- restrictionclosure-survey/

Betting markets that are offered only to those who lose, create a skewed market since it has eliminated those who are skilled and can see where a particular bet offers more value. As a consequence the odds being provided by the market makers (odds compilers) do not reflect the chances of the runners accurately and an increasing number of bettors are dragged into account restrictions as they have backed horses at longer odds than they start. It could also be argued that profit margin (or over-round) in betting markets will increase as bettors with less skill are unlikely to spot that a market is uncompetitive and will continue to bet when the odds are stacked against them. Betting has to have an aspirational aspect at its heart. If a bettor knows that by having a winning account they will no longer have bets accepted, or to only small stakes, then there is little incentive to continue developing skill and attempting to beat the bookmaker.

The HBF wish to see all off-course bookmakers in the UK operate a minimum bet liability where there is a requirement for bookmakers as part of their licence to lay horses to a minimum bet (currently only one UK bookmaker, Betfair Sportsbook offers this facility). Such a scheme already exists in the State of Victoria, Australia, where Racing Victoria has implemented a minimum bet liability (MBL) for all bookmakers that operate in that State

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since 2016. The MBL on Victorian horse racing applies from 9am for day meetings and 2pm for evening meetings and allows bettors to win up to $2000 (~£1100) on any one metropolitan win bet and $1000 (~£550) on any one non-metropolitan win or each way bet. HBF note that many of the UK Operators including Ladbrokes, William Hill and Bet365 all operate in Australia and comply with the requirement to stand a bet for a minimum liability.

To this end and following discussions between the HBF and bookmakers, HBF propose that off-course bookmakers lay to lose bettors £500 per selection per race minimum on the day.

At this time there is no requirement for operators to report to the Gambling Commission the number of accounts and the reasoning for closing or restricting them. The HBF believe that providing this information will result in greater transparency and provide evidence that a substantial number of bettors are having their accounts closed and restricted for the sole reason of making a small profit or showing skill.

At present, operators do not provide reasoning to bettors for closing or restricting accounts. While these are not required by their terms and conditions the HBF believe that, for greater transparency, reasons should be provided, which would then be recorded and provided to the Gambling Commission as part of the Operators’ annual return. The HBF wish to see a code of conduct developed that provides consumers with greater details of what leads to an account restriction which includes a warning to the bettor that restrictions are likely to be imposed should the bettor continue betting in this vein. We also believe that there should be a right of appeal through the new Gambling Ombudsman or Adjudicator who could assess if the restriction or closure was justified in accordance with a new code of conduct.

3. Betting Exchange Premium Charges (Q10)

When bettors have their accounts restricted with the off-course bookmakers the only mechanism that remains is to bet using the Tote or the betting exchanges. Back in 2000 the betting exchange model changed sports betting forever. It is free of risk from skilful bettors beating the book in the traditional bookmaking sense, because the owners of the exchange simply take a commission of between 2-8% on winning bets. In 2008 Betfair introduced a Premium Charge for some users, this involves comparing a user’s gross profits with the total charges they have paid. Premium Charge effectively means a user pays 20% commission on their Betfair Exchange earnings either during the span of one week or during the lifetime of the account.

This proved so lucrative for company profits that Betfair introduced Premium Charge 2 in 2011, increasing the charge up to 60% of weekly profits. This was enabled by what, in effect, was a monopoly position as Betfair’s liquidity is so much stronger than the other betting exchanges.

However, other betting exchanges operate a similar model. Smarkets have a Pro Tier system which imposes higher rates for select customers, Matchbook has a revenue share charge up to 60% and Betdaq implement a very high base rate on higher value customers. While these

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fees are levied on a very small percentage of customers who don’t lose, successful bettors are effectively banned again.

As part of this review, we urge the Government to consider the fairness of these additional charges for certain exchange bettors, so that they can be protected against very high commission fees especially where companies operate in a near monopoly position.

4. White Label Arrangements (Q8)

On 18th October 2018 Viking Hoard ran in a race at Tramore, Ireland. The horse performed poorly and it transpired that Viking Hoard’s urine sample showed he was 100 times over the international screening level for ACP (a horse sedative).

One lay bet placed had a liability of €34,889 to win €3,200 on the defeat of Viking Hoard, who drifted from 4-1 to a starting price of 8-1. The investigation found that all the bets were traded on Betfair, but were initially placed with a limited liability company, which placed them in turn with Betfair. It was noted that those involved used an intermediary third party, or a white label company. The HBF was extremely concerned to read that the investigation could not therefore uncover who had been involved in this race fixing and for that reason calls for an end to white label arrangements for horserace betting.

5. Decouple sports and horseracing betting from casino gaming (Q10)

HBF believe that there needs to be a demarcation between betting on horseracing (and other sports) and online casino gaming, i.e. games of chance (roulette, slots, virtual racing etc.). Gambling on games of chance and betting on horseracing and sports are two very different disciplines. For a horse or sports event the odds vary and depend on the opinion of the bookmakers’ odds compiler, whereas casino gaming is fixed odds betting in which the house has a built-in advantage. The horseracing bettor operates under a different risk framework to the gaming customer who is focused on the quick adrenaline buzz of the spin of a slot or the turn of the roulette wheel. Also, horseracing and sports betting are event based and as such allow the bettor to watch the live action before considering their next bet. Horseraces take place at each racecourse every 30 minutes, so for racegoers attending a meeting there are six or seven events on which to place a bet. On Saturdays there are usually seven races screened on ITV for bettors to have an interest. In total on a busy Saturday there are likely to be 36-45 races to bet on in Britain and Ireland. This is markedly different to how casino gaming operates in which a player can literally gamble every few seconds.

As the UK’s off-course bookmakers have slowly transformed themselves to a lesser or greater extent into online casino operators, the difference between skill-based betting and gambling has been lost. As noted there continues to be cross selling of casino style games to horseracing and sports betting (see examples in Appendix 2), some bookmakers advertise slots and casino games on horseracing betting shows, and regularly send emails offering

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free spins on slot machine games. Examples are shown in Appendix 3. It is the opinion of the HBF that players who wish to bet on horse and sports racing should have a separate account to those who wish to play on casino and other games of chance. This would allow the regulatory regime for each of these activities to be separated, such that gambling (i.e. games of chance) could be regulated more closely due to the higher risk of problem gambling. This would reflect the position when High Street bookmakers took bets and casinos provided the opportunity for players to gamble.

6. Publish Overrounds on betting shows (Q10)

All bookmakers’ betting shows include an overround, a theoretical built-in profit margin, which, were bets to be struck in strict proportion to each horse’s odds, would provide a profit on the race. The overround gives an indication of how competitive the bookmakers’ odds are as the closer they are to 100% the more likely that the bettor will be able to find a bet which offers them value, i.e. greater odds than the chance of the selection winning. We believe that by publishing the overround bettors would have greater transparency on how large the overround is and allow them to decide if the odds being offered are worthy of a bet. Having this information easily available would allow comparisons between different sports and indicate how competitive the different markets are.

The HBF has been analysing horserace betting overrounds for a number of years (links to studies for previous years are shown in Appendix 1). The work to produce and collate this information has fallen to a voluntary group and the HBF believe that work to produce, publish and make the betting public aware of horserace betting overrounds should be undertaken by a new Gambling Ombudsman or Adjudicator.

It is concerned the Starting Price Regulatory Commission (SPRC) in fact has no regulatory powers and is merely a vehicle for determining a mechanism to derive the starting price, and gathering and publishing the current odds from bookmakers to produce a starting price (SP). As shown in the graphic below, overrounds are now lower than they have been when SPs were derived from the on-course bookmakers, however this is as a result of offering much longer odds for outsiders (which rarely win) and reducing the odds of those at the head of the betting market.

The SPRC itself points out that it has no power or regulatory function that can protect the consumer per se and exerts punters concerned about the integrity of an event to go elsewhere,

“If you have any concerns about the integrity of the races themselves these should be shared with the British Horseracing Authority. If you have evidence of any form of price fixing by bookmakers this should be reported to the Gambling Commission and/or the Competition and Markets Authority”.

Ref: http://www.thesprc.org/faq/

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We therefore call for the establishment of a single body that ensures that horseracing betting is adequately regulated both in terms of the current work of the SPRC but also ensuring the integrity of the market, such that the market remains competitive both on and off-course, as well as providing a single point of recourse for the consumer, with powers that join up the current disparate bodies, which inevitably ensure that no one body is accountable for the integrity of the market or the protection of the punter.

7. Affordability checks (Q4)

The HBF responded to the Gambling Commission’s recent consultation on Remote Customer Interaction. (See Appendix 7). We noted that while the intentions of affordability checks are noble, there are numerous ways in which consumers can relatively easily avoid them: for example, by opening several accounts across different online bookmakers, by opening proxy accounts via friends and family, by betting on the high street and on the racecourse in anonymity, and by betting with illegal bookmakers online and/or unregulated overseas operators. We also maintain that the current checks that are being required by the Gambling Commission for Anti Money Laundering (AML), Know Your Customer (KYC) and to become or maintain involvement with VIP schemes, are overly intrusive and time consuming and often require bettors to provide substantial evidence that they are able to afford to gamble. These may include providing bookmakers with income information, including pay slips, pension information, savings details etc. as well as bank statements

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indicating spending. The HBF is aware that some bettors are already having to provide this type of information to satisfy current regulations: many have said they have refused to undertake these and closed their accounts, as a consequence ceasing to bet on horseracing. There is also concern that Operators do not have sufficient knowledge to make decisions about what bettors can afford, we have heard from bettors who have provided the same information to two different companies with one company imposing a deposit limit and the other none. Another concern is that private and sensitive information about someone’s finances will not be stored adequately and that any data breach will allow this information to be stolen.

The Tote have asked that all customers that have deposited more than £750 since becoming a customer to answer a questionnaire relating to their financial status (see Appendix 4). To put this in perspective the Racing Post newspaper now costs £3.90 Sunday to Friday and £4.20 on Saturdays. An annual sum of £1,435.20 and a season ticket at Chelsea FC ranges from £750-£1200. We urge the Government to take a proportionate approach to affordability checks whereby the vast majority who do not bet very large amounts of money and have a proven record of betting on horseracing responsibly should not have to undergo intrusive checks.

8. Illegal Betting Sites (Q16)

An increasing concern is the ease by which bettors can now have access to overseas betting sites that are set up illegally, these sites often run by criminal gangs have the potential to undermine both the integrity of horseracing in Europe and the safety of those betting on it. The HBF is concerned that there are increasing number of gangs who are illegally targeting UK betting customers. The HBF wishes to see that the Gambling Commission is adequately resourced to ensure that these gangs are not able to break further into the UK market.

Evidence – https://www.gamblinginsider.com/news/11001/new-bgc-research-shows- number-of-customers-using-black-market-sites-has-more-than-doubled

9. Increasing operators’ responsibilities towards problem gambling (Q24)

HBF believe that operators should take greater responsibility for ensuring that levels of problem gambling are reduced as much as possible.

One aspect that we would like to see is greater responsibility placed on operators’ senior managers as part of the operators’ Personal Management licence. This would involve named individuals having responsibility for checks that take place in Anti Money Laundering (AML), Know Your Customer (KYC) and VIP schemes and being therefore personally accountable. A similar scheme operates in the aviation industry under the banner of Accountable Manager where each organisation appoints a manager that is solely responsible for nominating key post holders to deliver specific functions in relation to the management of the organisation’s approval activity.

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Operators should include increased monitoring of player activity and intervention when they exhibit known markers of harm. There should be greater checks of new players, who may be unknown to the operator especially those who are younger and for whom financial loss would be more harmful. For players that are well known and have been customers for many years the level of checks could be reduced, except when a player demonstrates unusual behaviours e.g. increased deposits, chasing losses etc. Finally, there is a need for a stop-loss facility to be introduced which can only be removed once additional checks have been undertaken. We see that these checks are the final stage, we also urge that any checks that are required should not be intrusive, time consuming and are proportionate to the level of deposit being made, i.e. the minimum needed to gain a sufficiently accurate financial view of a player

10. Requirement for Gambling Commission to undertake additional tasks (Q10)

HBF believe that there is need for the creation of a Gambling Ombudsman or Adjudicator. We see this organisation has having a number of roles;

  • Responsible for collation of all gambling related industry data. Currently all operators provide the Gambling Commission with a number of statistics that enable them to report on the size and shape of the gambling industry in Great Britain along with an overview of Gross Gambling Yield (GGY) by sector, as well as details of the numbers of licensed operators and premises.
  • Ensuring that player related information is collected in a fair, standardised and transparent manner. At present each operator is responsible for collating player information using a variety of means.
  • At present, betting disputes and complaints are undertaken by an approved alternative dispute resolution (ADR) provider who is chosen from a list provided by the Gambling Commission on behalf of operators. However, we believe that many of the ADRs have little knowledge of horseracing and find adjudicating on these complaints difficult. For that reason, having an independent betting dispute organisation that can access a range of industry related information would be of benefit to consumers. We believe that this service should work in a similar way to the Financial Ombudsman Service, where if an FCA regulated entity does not resolve a complaint to the satisfaction of the customer, the customer can take this to the FOS.
  • The HBF is also concerned that players’ funds in some bookmakers’ accounts are not adequately protected. In March 2020 the HBF surveyed 67 bookmakers that operate in the UK and provide horseracing markets. https://ukhbf.org/betting-charter/hbf- register-of-protection-of-funds/ The Gambling Commission allow operators to mark their protection in three categories; High, Medium and Not Protected. Of these eight offered High protection, 35 Medium and 24 No protection. In March 2021 there are still 21 bookmakers that offer no protection to their customers’ funds. Furthermore 21 of these operators with ‘Medium’ protection state in their T&Cs that they ‘cannot absolutely guarantee that all funds will be repaid’.

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It is HBF’s belief that customers should be provided with clearer information so that can understand how their funds are protected as the current three levels do not adequately explain their protection. We have highlighted this to the Gambling Commission who inform us that they continue to review their policy in this area. We believe that greater powers should be provided to the Gambling Commission to ensure players are not at risk of losing their funds that are deposited with a bookmaker, especially considering the recent case of the failure of Football Index.

  • At present there is no one body that has the interests of the horseracing bettor at heart. Horseracing has a complicated governance structure and is heavily dependent on Horseracing Betting Levy Board funding which is derived from bookmakers. However, bookmakers provide their Levy funding on the basis of profit, which encourages bookmakers to offer concessions, special offers to reduce profits from horseracing betting and incentivise bettors to open accounts (See Mansion Bet case study in Appendix 5).
  • HBF believe that the current function of the Starting Price Regulatory Commission should be subsumed into a wider role of the Gambling Ombudsman or Adjudicator and be provided with a legislated regulatory role to ensure that horseracing betting is adequately regulated both in terms of the current work of the SPRC but also ensuring transparency and integrity of the market, such that the market remains competitive both on and off-course, as well as providing a single point of recourse for the consumer, with powers that join up the current disparate bodies, which inevitably ensure that no one body is accountable for the integrity of the market or the protection of the bettor.11. Summary
  • HBF believe that a move to a Levy funded from bookmaker profit as well as some element of bookmakers’ horseracing turnover would be beneficial to horseracing bettors. This may reduce the off-course bookmakers’ desire to use horseracing as a loss leader and as a vehicle to cross-sell bettors to other more profitable gambling products such as slots and casino games which have higher rates of problem gambling associated with them.
  • Bookmakers operate under a licence to take bets. HBF believe that bookmakers should accept bets from all their account holders and not just those who the operator believe are losing bettors. HBF wish to see that all bookmakers, like those in Australia, provide a Minimum Bet Liability. This would ensure that betting on horseracing would once again be an aspirational activity, as at present many bettors who make even a small profit have their accounts restricted. HBF also calls for greater transparency around account restrictions and closures, with a betting code of conduct established and a right to appeal through the proposed Gambling Ombudsman or Adjudicator. HBF also calls for an investigation into the equitability of premium charges on betting exchanges especially at Betfair since they have the leading market share and much greater liquidity in their betting markets.

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  • Sports and horseracing betting should have a different regulatory regime to casino- style gambling where the house has a built-in edge. Sports and horseracing betting is a very different activities to casino gambling and notably have much fewer instances of problem gambling.
  • Bookmakers should be required to publish over-rounds on betting shows to allow greater transparency of the betting market and to allow bettors to make more informed choice on whether to bet into these markets and with which bookmaker.
  • Affordability checks should only be applied when absolutely necessary and should only follow after all other methods of checks have been undertaken i.e. a players’ betting history, deposit history, etc. The current requirements for affordability checks require bettors to carry out intrusive and time-consuming checks. We call for more reasonable checks that are proportionate to the level of gambling that is being undertaken.
  • HBF are concerned that increased regulation of the UK horseracing betting market will drive bettors to use unauthorised bookmakers, including those that operate offshore and which reduce income to the Treasury and puts bettors’ funds at risk.
  • Considerable work has been undertaken by bookmakers to reduce problem gambling. However, there is more to be done and the HBF encourages bookmakers to use their sophisticated systems to identify those who may be at risk so that they can be helped and encouraged to gamble responsibly.
  • The Gambling Commission should be provided with additional resources through the creation of a Gambling Ombudsman or Adjudicator that will act as a centralised organisation ensuring all aspects of horserace betting are in the interests of the consumer.Response DetailsThis response is sent on behalf of Horseracing Bettors Forum (HBF).
    The HBF would welcome the opportunity to discuss this submission more fully. Contact Details:
    Colin Hord Chair Horseracing Bettors Forum
    Email chair@ukhbf.org

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Appendices

Appendix 1 Horseracing Betting Overrounds and SP Comparisons

2017 Horserace betting overrounds study

https://ukhbf.org/where-to-bet-and-where-not-to-bet-a-study-into-2017-starting-prices-in- british-horseracing/

2018 Horserace betting overrounds study

HBF Study into 2018 Starting Price Overrounds by Course

2019 Horserace betting overrounds study

HBF Annual Overround Survey – January 2020

Recent comparisons of overrounds on horseracing betting shows Comparison on overrounds as of November 2020https://ukhbf.org/hbf-news/hbf-starting-price-analysis-november-2020/ Comparison of on-course and off-course starting prices March 2021 https://ukhbf.org/hbf-news/hbf-starting-price-analysis-march-2021/

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Appendix 2 Screenshots of horserace betting shows showing cross selling of casino games

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Screenshot of PaddyPower horseracing betting show with casino games advertised alongside

Screenshot of Betvictor horseracing betting show with casino games advertised alongside

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Appendix 3

Extract of email to horseracing bettor advertising free spins on slot machine game

Extract from email sent to horseracing player advertising free spins on a PaddyPower slot game.

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Appendix 4 Tote Affordability Check Questionnaire

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Hello

Thank you for providing the documents requested. These have now been reviewed and your account updated.

Here at the +o+e we are determined to make gambling not only fun but also affordable for all our customers. Not only is this a condition of our UK licence but it is also part of our mission to make the Tote a safe place to have a bet.

We know that customers come in different shapes and sizes so to ensure you Tote safely, we wondered if you could reply to this email with an answer to these questions:

Steven,

1.Are you comfortable with your current levels of wagering with the Tote? 2.What is your current employment status i.e. FT/PT/Contracted etc? 3.What is your job title/area of occupation?
4.How much do you earn PA gross?

5.What is your net monthly income?

What are your total monthly outgoings, this should include rent/mortgage and other substantial regular outgoings?

7.What is your monthly budget for gambling?

8.Would you consider using deposit limits to manage your spend? If yes, what would be a suitable weekly/monthly limit for you?

9.Do you currently bet with any other providers if so how many in total and to what sort of level i.e. similar to your levels with Tote?

10.Do you use any other source of income for your gambling?

We realise that these questions are personal and the information sensitive, so we’d like to reassure you that:

•We’ll only use this information to check on your spend level to help you manage your gambling.

•This information will be securely held on our systems.
•This information will not be used for marketing purposes.
•We’ll only keep this information for as long as we are required to by law.

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Kind regards,

Emily

KYC Team

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Appendix 5 Mansion Bet Case Study

For the Cheltenham festival in 2021 Mansion Bet offered a concession of paying out as a winner if the horse backed finished second (or first) on the first race of each day of the festival.

This was a generous offer and could be argued that it was unsustainable. Due to the offer the company provided extremely poor odds compared to other bookmakers and it appears then restricted substantial numbers of bettors who realised how generous this offer was.

Here is the experience of one better who opened an account with Mansion Bet on Tuesday

16th March 2021 in order to avail of themselves of their ‘Cheltmas’ offer, paying 2nd as a winner in the opening race each day.

They had ten pounds on Ballyadam in the Supreme Novice’s Hurdle, who was fortunate to finish 2nd due to last flight departure of Blue Lord, this bet paid £65.

On Wednesday they had £10 on Bob Olinger, who won, so Mansion Bet paid out accordingly. On Thursday they tried to have £10 win on Chantry House at SP –because they were offering extremely low win odds due to Envoi Allen’s win price due to the fact that Mansion Bet had made a unsustainable offer

The bettor was offered £8, which was taken. Chantry House won and was paid out however that has now rendered the bettor ineligible for any other offers and Mansion Bet has restricted their account.

It appears that this bookmaker has made a financially irresponsible offer and has had to resort to restricting bettors, this one after just 3 bets.

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Appendix 6 Example betting account screen shots showing restrictions

A Bet365

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B SportingBet

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Appendix 7

HBF_GCRemoteCust omerInteractionConsultation Response.pdf

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