Mr. Kevin Murphy:

Bet Beware Limited is a not-for-profit organization established by a group of concerned individuals with backgrounds in the betting and gambling businesses. It has the objective of focusing on the very real issues of a social and economic nature associated with all forms of betting and gambling activity that impact on individuals and society in general. While the organisation neither condones nor condemns betting or gambling, it holds the opinion that betting and gambling, contrary to industry spin, is not entertainment or fun. In the vast majority of cases, individuals participate with the real or imagined expectation that they will win. Most lose and many experience anxiety and varying degrees of depression as a consequence of their losses.

This presentation, coupled with our response document, is an attempt to present our views to the persons responsible for the drafting of the legislation for eventual presentation to the Oireachtas. In the main, the response focuses on the off-course betting industry, an industry where certain members of our group have extensive business experience. It is however the intention of Bet Beware to engage with the Office of Gambling Control Ireland, OGCI, when it is established, in an effort to influence various aspects of the regulatory framework. However, to use a phrase borrowed from head 33, page 43 of the general scheme document, there is a serious disparity in the matter of “equality of arms” for organisations such as ours in engaging with Government on this issue in comparison with the vast resources that the off-course betting industry has up to now committed, and will continue to commit into the future, in its efforts to ensure that legislation is structured in a way that favours the profit and greed driven objectives of most, but not all, of its members, to the detriment of not only the poor and vulnerable members of society but of society in general.

The off-course betting industry would like to think of itself as well regulated. However, one of its most senior executives and founder of a major bookmaker enterprise has stated that over the years it has been able to drive a coach and four through the Betting Act 1931, helped in no small measure by the inability of an unresourced Garda Síochána to monitor and enforce the 1931 Act. Bet Beware believes that unless the legislation is rigid in structure and the OGCI monitors the industry in a comprehensive and detailed manner, a coach and four will be driven through this new legislation by the off course betting industry.

I would like to comment on some of the heads of the Bill. Head 1 deals with the definition of a bet. "Bet" needs to be defined in more precise detail for the protection of users of betting services and, in particular, in the interests of fairness and transparency. The definition could be: “a bet is a wager made on an event to be decided in the future”. It is important that “decided in the future” should be part of the definition. It is universally accepted that a bet is a wager made on an event that is decided in the future rather than commenced or started in the future.

Furthermore, the definition of “betting” should exclude any reference to virtual events. Serious doubts exist about the integrity and fairness of virtual events. The result is known before the event takes place, that is before the event is concluded or finished. There have been instances in the past year alone where results of these virtual events have been shown on television screens in betting shops, before the advertised time of the event. Bet Beware believes that there should be a prohibition on virtual events in the new legislation and that this prohibition should not be considered for repeal until such time as the OGCI has undertaken a detailed investigation into all aspects of virtual events.

The definition of “fixed odds betting terminals” needs to be examined specifically so as to eliminate all possible loopholes.