Mr. Graham Ross:

I thank the Chairman, members and secretariat for the invitation to partake in the discussion on the proposed gambling regulation Bill. I will take a few moments to explain who Lottoland is as a company and set out our initial views on the proposed approach to the Bill. Lottoland has been a licensed remote bookmaker in Ireland since April 2016. We also operate across 15 markets globally, with licences held in key markets, including Gibraltar, the UK and Malta, supported by a global workforce of more than 400 employees, serving more than 15 million customers worldwide.

For those who are not necessarily familiar with the Lottoland brand, as a relatively small operator within the Irish market, we offer a wide range of online gaming and gambling products, including lottery betting, sportsbook, online casino, bingo and charity products, including our Win-Win charity lotto and scratch cards, which directly support our Irish charity partners, the Irish Red Cross and the Dublin Society for Protection against Cruelty to Animals, DSPCA.

With regard to today’s discussion, gambling is a long-standing feature of Irish culture and a popular form of entertainment but it has been clear for some time that a modern, sustainable and sector-wide regulatory regime, with a single oversight body, is required in this country. Progress on these reforms, while overdue, is in the best interest of not only the tens of thousands of Irish consumers who safely participate in and enjoy gaming, gambling and lottery activities each week but also, importantly, for the smaller numbers of customers at risk of problem gambling, in addition to the wider general public and the sector itself. In this regard, we believe the proposed general scheme, while largely positive, risks not fully delivering on the consistent, comprehensive and consumer-centred approach that will be required. Ensuring the sector as a whole, that is, all gaming, gambling and lottery operators, including the national lottery, are included within this one regulatory framework will be key to providing for a level playing field and implementing adequate safeguards for consumers across all products and services in the market.

In a jurisdiction the size of the Irish one, we query the effectiveness and cost efficiency of potentially having two separate regulatory frameworks for the gambling sector - one in this newly established authority and the other in the existing national lottery regulator. We cannot afford a lack of alignment around key regulatory provisions moving forward if we are to achieve the goals set out by Government. Therefore, we seek confirmation that all operators across the sector will be included within this proposed legislation.

It is also our experience from other markets that by providing for and establishing clear, fair and streamlined processes founded on open consultation between a well resourced regulatory function and operators from the off, we will be able to deliver an appropriately regulated environment here in Ireland. To this end, we also recommend that provisions be made for the proposed authority to consult regularly and effectively with the sector, particularly on the formation, governance and ongoing operations of any social impact fund introduced.

We thank the committee for the invitation to provide our views as an existing operator on the draft Bill and we firmly believe such co-operation with the sector will be pivotal to informing the necessary robust and sustainable policy on an ongoing basis. I look forward to responding to any queries members may have and providing clarifications on our submission throughout this session.