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PROVINCIAL BOOKMAKERS

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PROVINCIAL BOOKMAKERS ASSOCIATIONS Submission to Portfolio Committee on Trade & Industry on THE FINAL REPORT OF THE GAMBLING REVIEW COMMISSION – PowerPoint PPT presentation

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Title: PROVINCIAL BOOKMAKERS


1
PROVINCIAL BOOKMAKERS ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
on THE FINAL REPORT OF THE GAMBLING REVIEW
COMMISSION CAPE TOWN 28 October 2011
2
PROVINCIAL BOOKMAKERS ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • INTRODUCTION
  • The KwaZulu-Natal, Gauteng and Western Cape
    Bookmakers Associations, which are voluntary
    associations not for gain representing the
    interests of licensed bookmakers in their
    respective provinces, have chosen to make a joint
    submission to the Committee, and will
    collectively be referred to as PBA for the
    purposes of this presentation.
  • PBA is grateful for the opportunity to make a
    presentation to the Portfolio Committee on the
    Final Report of the Gambling Review Commission
    (GRC).
  • PBA appreciates that the mandate of the GRC was
    particularly broad, and that, given the
    timeframes in which it was required to execute
    this mandate, it would not have been possible for
    the GRC to gain an in-depth understanding of the
    horseracing and betting sector, as only one of
    the numerous sectors, both legal and informal, to
    which it was required to give attention.
  • The GRC was thus able only to give scant
    attention to this sector in its Report.
  • Recently, a concerted campaign has been waged in
    various media, including platforms controlled by
    racing operators, to discredit and undermine the
    bookmaking sector, fuelled by unfounded
    allegations that its contributions to the sport
    of horseracing are negligible and
    disproportionate.
  • The aim of this presentation is to provide the
    Committee with accurate information regarding the
    manner of operation of this industry and the
    issues facing it, so as to remove any confusion
    regarding the vital contribution made by
    bookmakers to the horseracing and betting sector
    and to assist the Committee in its critical
    policy-making function.

3
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • THE HORSERACING INDUSTRY
  • Horseracing in South Africa dates back well over
    200 years.
  • Horseracing faces growing competition from other
    gambling industry sectors.
  • Unlike the vast majority of other sports on which
    betting is commonly offered, horseracing exists
    for the sole purpose of betting on the outcomes
    of races. The sport provides a platform to enable
    owners to compete for the stakes offered in
    respect of racing, which are generated by
    betting. Without betting, therefore, horseracing
    as a commercial activity would cease to exist.
  • Betting on horseracing takes two forms patrons
    may bet on the totalisator or with licensed
    bookmakers, or both.
  • The sport of horseracing is financed primarily by
    the betting public, rather than by totalisator
    operators or licensed bookmakers. This will be
    explained in fuller detail later in this
    presentation.
  • There are material differences between the manner
    in which a totalisator operates and the business
    of a licensed bookmaker. Understanding these key
    differences is crucial to the policy-making
    function.

4
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • HOW HORSERACING IS FUNDED
  • The money which sustains the sport of horseracing
    is provided primarily by the betting public in
    the following manner
  • In respect of totalisator betting each rand
    wagered by patrons is placed into a pool (e.g.
    win, place, swinger, trifecta, jackpot). Once the
    race has been run and the result is known, the
    totalisator operator deducts (a maximum of) 25
    from the total or gross pool wagered. These
    deductions are used by it to fund the sport of
    horseracing, as well as provincial betting taxes
    and VAT. The remainder (net pool) is paid out
    proportionately as winnings amongst the holders
    of winning tickets.
  • On its website, Phumelela provides the following
    breakdown for the post-race distribution of every
    R100 wagered by patrons

RETURNED TO PATRONS (by way of winnings) R76.00
PROVINCIAL TAX R 2.00
VAT R 2.80
STAKES R 6.00
STAGING RACE MEETINGS, BETTING OPERATIONS HEAD OFFICE EXPENSES R11.20
PRODUCT ROYALTIES R 1.50
PROFIT R 0.50
5
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • From the above, it is evident that the betting
    public, and not the totalisator operator, funds
    the costs of the sport of horseracing. It should
    be noted that this money represents an average of
    24 of each and every bet taken by patrons on the
    totalisator, irrespective of whether it is a
    winning or a losing bet.
  • From the perspective of bookmaking operations,
    bookmakers do not engage in pool betting. Each
    bet represents a potential liability in its own
    right. Bookmakers lay bets on several horses and
    attempt to spread their risk. Once the race has
    been run and the result is known, the bookmaker
    must pay the holders of winning tickets. In
    respect of each and every winning ticket in
    relation to horseracing, the bookmaker retains 6
    of the winning amount, of which half (or 3) goes
    to the provincial fiscus and the remaining half
    (or 3) is paid over to the totalisator operator,
    as a contribution towards the funding of the
    sport of horseracing.
  • Therefore, the sport of horseracing is primarily
    funded from
  • all persons who have placed bets (whether winning
    or losing bets) on the totalisator (to the extent
    of a maximum of 25 of betting turnover), and
  • all persons who have placed winning bets with
    bookmakers (to the extent of 3 of the amount won
    in each case).

6
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • It is also clear that the totalisator operator
    takes no risk by virtue of its betting
    operations, i.e. it cannot make a loss on any
    betting transaction. It is the public that
    generates the betting pools, and also the public
    that funds the distributable pool to winners, as
    well as the administrative costs of horseracing.
    And, of course, it is also the public that pays
    the taxes.
  • The business of licensed bookmakers, on the other
    hand, is entirely dominated and defined by risk.
    Bookmakers strive to lay as many bets as possible
    on different horses participating in the same
    race, and in the process are obliged to assume
    certain corresponding liabilities, so that, in
    many cases, profits may be significantly eroded
    or even entirely sacrificed.
  • Therefore, there is, in most cases, no
    correlation between the levels of betting
    turnovers generated by bookmakers, which may be
    high, and profits generated.
  • Typically, the profit margins attained by
    bookmakers range between 6 and 8.
  • While the totalisator traditionally accepted
    betting only on horseracing, in recent years this
    has changed dramatically, so that the totalisator
    currently competes directly with bookmakers by
    offering betting on a variety of other sporting
    events. Bookmakers have not formally objected to
    this trend to date, despite the persistent
    objections of the totalisator to the open bet,
    which will be discussed below.

7
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • Bookmakers are legally entitled to offer fixed
    odds and open bets in terms of the National
    Gambling Act. The open bet is a bet in respect
    of which the odds are not set at the time that
    the bet is struck, but in respect of which the
    bookmaker agrees to pay the same dividend as that
    declared by the totalisator, in the event that
    the bet is a winning one.
  • The totalisator has for many years campaigned
    vigorously against the open bet, on the basis
    that, in offering it, bookmakers are feeding off
    the intellectual property of the totalisator. The
    argument of the totalisator is that
  • Bookmakers return less to the sport of
    horseracing (by way of funding) than the
    totalisator does, and
  • If the open bets taken by the public with
    bookmakers were instead placed with the
    totalisator, more money would be returned to the
    sport of horseracing. In this way, totalisator
    operators such as Phumelela publicly encourage
    the betting public, as well as other industry
    stakeholders, such as owners, not to take open
    bets with licensed bookmakers.
  • In much the same way, Phumelela uses its website
    as a means of discouraging industry stakeholders
    from taking even fixed odds bets with licensed
    bookmakers.

8
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • There are however fundamental flaws in these
    arguments.
  • As has already been demonstrated, neither racing
    operators nor licensed bookmakers fund the
    industry per se. The bulk of the funding for the
    sport of horseracing, including the funding of
    the National Horseracing Authority, which polices
    the sport of horseracing (and which Phumelela now
    suggests should be carried to a greater extent by
    bookmakers), emanates from the betting public. It
    is therefore inaccurate (and disingenuous) to
    allege that totalisator operators fund the
    industry to a greater degree than licensed
    bookmakers do, or that the contributions made by
    bookmakers should be increased.
  • The arguments raised by totalisator operators
    also ignore the fact that the open bet is
    completely legal. The National Gambling Act
    expressly provides that licensed bookmakers may
    offer the open bet.
  • In addition, the issue of whether bookmakers may
    lawfully offer the open bet has been fully
    canvassed with all appropriate decision-making
    authorities on a number of previous occasions,
    has been assented to by the National Parliament
    itself and has been tested and upheld by the
    highest Courts in the country. Both the Supreme
    Court of Appeal and, more recently, the
    Constitutional Court (unanimously) found that
    there was no legal basis for the arguments
    (advanced by the totalisator) that the use of the
    open bet by bookmakers amounted to unfair or
    unlawful competition with the totalisator. The
    issue raised has therefore been conclusively
    disposed of.

9
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • Despite the well-established legality of the open
    bet, Phumelela continues to use every means at
    its disposal to discourage the betting public
    from betting with bookmakers. On its website, it
    openly does so in the following terms
  • Assuming that fixed-odds betting turnover in
    Phumelela territory is R1.4 billion (50 of the
    tote betting turnover), its easy to calculate
    what would happen if that money was wagered on
    the tote instead. Horseracing would get some R280
    million annually, instead of the R38 million it
    receives from fixed-odds betting currently, and
    stakes at Phumelela racecourses would rocket by
    some R80 million- a 50 increase!
  • What is even more damaging for horseracing
    currently is that many bookmakers are laying the
    open bet. Given the average return of R76 for
    every R100 wagered on the tote, a bookmaker
    retains R24 of every R100 in open bets. Of the
    R76 left over, R71.44 is returned to punters with
    R2.28 for provincial tax and R2.28 to
    horseracing, which would get R17.72 more if the
    R100 had been wagered on the tote.
  • The message is clear owners seeking higher
    prize money and those who love the sport need to
    think twice before betting fixed odds or taking
    open bets with fixed-odds operators.
  • Source http//www.phumelela.com/BetTABBackRacing
    /tabid/67/Default.aspx

10
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • PBA submits that the conduct of Phumelela in
    openly inciting the public not to engage in a
    lawful betting activity which is competitive to
    its own offering is unconscionable, if not
    unlawful, and directly undermines established
    governmental policy.
  • Effectively Phumelelas approach advocates the
    demise of the bookmaking industry, by suggesting
    that the public should place neither fixed-odds
    bets nor open bets with bookmakers.
  • This approach is also contradictory, in that
    through its own subsidiary, Betting World,
    Phumelela itself has a 20 footprint in the
    bookmaking market, and, based on the
    announcements of its 2011 results, is looking to
    grow and expand this presence in the market. The
    dramatic loss in betting revenues to bookmakers
    which it advocates would therefore have a
    substantial negative impact on Phumelela itself.
  • Furthermore, the ongoing campaign against the
    open bet also disregards the fact that
  • The betting public has a democratic right to
    choose between lawful betting options
  • Bookmakers do not openly promote the open bet
  • The costs of horseracing are subject to the
    direct, overall control of the racing operator,
    and
  • Inasmuch as racing operators now offer betting on
    sports other than horseracing, they expect to be
    able to trespass on the traditional territory of
    bookmakers with impunity, but continue to object
    when bookmakers offer a form of betting which
    they regard as being their property, despite
    the fact that the Constitutional Court itself has
    rejected this argument outright.

11
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • THE REAL PICTURE
  • The National Gambling Board (NGB) has provided
    the following official statistics in relation to
    the turnovers, net win figures and taxes paid by
    the totalisator and bookmaking sectors during the
    2010/2011 fiscal year

BOOKMAKERS BOOKMAKERS BOOKMAKERS TOTALISATOR TOTALISATOR TOTALISATOR COMBINED
HORSERACING (R 000 000) HORSERACING (R 000 000) HORSERACING (R 000 000) HORSERACING (R 000 000) HORSERACING (R 000 000) HORSERACING (R 000 000) (R 000 000)
Turnover 4,028 45.90 Turnover 4,748 54.10 8,776
Net win 419 26.45 Net win 1,167 73.55 1,586
Taxes 136 64.30 Taxes 75 35.70  
SPORTS BETTING (R 000 000) SPORTS BETTING (R 000 000) SPORTS BETTING (R 000 000) SPORTSBETTING (R 000 000) SPORTSBETTING (R 000 000) SPORTSBETTING (R 000 000)  
Turnover 3,570 94.70 Turnover 199 5.30 3,769
Net win 298 87.57 Net win 42 12.43 341
Taxes 13 81.78 Taxes 2.9 18.22  
BOOKMAKER TOTALS (R 000 000) BOOKMAKER TOTALS (R 000 000) BOOKMAKER TOTALS (R 000 000) TOTALISATOR TOTALS (R 000 000) TOTALISATOR TOTALS (R 000 000) TOTALISATOR TOTALS (R 000 000) COMBINED
Turnover 7,598 60.56 Turnover 4,948 39.44 12,546
Net win 718 37.26 Net win 1,209 62.74 1,927
Taxes 149 65.53 Taxes 78 34.47 228
3 to totalisator 68.3          
12
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • It is clear from the data provided by the NGB
    that licensed bookmaker operations generate
    21.12 more in betting turnover than the
    totalisator, and contribute 65.53 of the total
    taxes paid in respect of betting, on horseracing
    and on sportsbetting combined.
  • Despite this, the net win position of bookmakers
    is 25.48 less than that of the totalisator. The
    reason for this is that the bookmaker business is
    a high risk business with high turnovers and low
    profit margins, generating significant taxes,
    while the totalisator business is a no-risk
    business which delivers a significant net win to
    the totalisator, but markedly less taxes to the
    fiscus. It should be noted that, by Phumelelas
    own admission, for every R100 wagered on the
    totalisator, an average of only R2.00 is returned
    to the fiscus by way of betting taxes. From this
    perspective, the Phumelela lobby can be seen for
    what it is a concerted drive to augment profits
    for its shareholders at the expense of the
    superior betting tax revenue generated by the
    bookmaking industry.
  • If the public were to abandon fixed-odds and open
    betting, as advocated by Phumelela, and instead
    place these bets with the totalisator, more
    (public) money would certainly be available to
    fund the sport of horseracing, to the benefit of
    the stakeholders of racing operators, but the
    betting taxes generated (on horseracing alone)
    would plummet by an estimated minimum of 45.

13
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • Whereas the profits made by bookmakers are just
    over 10 of the net win figure, in the case of
    the totalisator, profits account for more than
    25 of the net win figure.
  • While the percentage of tax to turnover in the
    case of totalisator betting on horseracing is a
    mere 15.6, in the case of the bookmaking
    industry the taxes generated in respect of
    betting on horseracing amount to 33.7 of the
    turnover generated by betting on horseracing.
  • The contribution of licensed bookmaker operations
    to the horseracing industry and to the fiscus
    in South Africa is therefore indisputably an
    enormous one.
  • Moreover, the bookmaking industry has never
    benefited from the range of previous tax breaks
    repeatedly extended to racing operators over the
    past decades. Unlike the totalisator, its
    operations are not subsidised to any extent by
    government.
  • The call for the playing fields to be levelled,
    inter alia by the imposition of higher taxes in
    respect of bookmaker operations not only ignores
    the vast operational differences (particularly as
    to risk) between the totalisator model and the
    bookmaking model, but would drive away the
    betting public to the marked detriment of the
    sport of horseracing.

14
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • GENERIC CHALLENGES FACING THE HORSERACNG
    INDUSTRY
  • The proposed withholding tax of 15 on all
    gambling winnings of or above the threshold of
    R25 000 is a major threat to the industry and the
    sport.
  • There are a huge number of offshore online
    betting providers which would enable patrons to
    place bets on horseracing in South Africa without
    being subject to a withholding tax of any kind.
    The betting industry is extremely competitive,
    and patrons will inevitably seek out providers
    offering the greatest potential return on any
    amount staked. A withholding tax by its very
    nature depletes the return to patrons.
  • Horseracing, which employs thousands of people,
    has shown a gradual decline over the past years,
    with a corresponding reduction in profits. As
    patrons migrate their custom to betting providers
    which are not subject to a withholding tax,
    betting turnovers will drop further, leading to a
    corresponding drop in stakes, which in turn will
    further discourage participation in the industry,
    through breeding and ownership and by way of
    betting by the public. As the industry becomes
    increasingly less sustainable, the primary
    operational expenses, in the form of jobs, will
    be the first to be cut. As job creation is at the
    forefront of the government agenda, the
    implementation of a withholding tax would
    ultimately prove to be entirely at odds with
    national policy.

15
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • RECOMMENDATIONS OF THE GRC
  • We welcome the recommendation of the GRC that,
    from the perspective of B-BBEE compliance, it is
    necessary to develop an evaluation or measurement
    tool which recognises the challenges faced by
    bookmakers in the context of complying with the
    Codes of Good Practice, given the nature of the
    business conducted by them and the fact that
    notwithstanding high turnovers, profit margins
    are consistently low.
  • We look forward to interacting with the relevant
    decision-makers to craft an appropriate strategy
    regarding B-BBEE compliance for bookmakers, which
    will include appropriate provision for CSI
    contributions by this industry sector.
  • The GRC has further recommended that licensed
    bookmakers should contribute to the funding of
    the other sports on which bookmakers lay bets, on
    the basis that it is unequitable that (a
    portion of) the taxes derived from betting with
    bookmakers are selectively channelled to the
    totalisator alone.
  • We disagree with this recommendation. It is
    pointed out, in this regard, as previously
    mentioned, that the sport of horseracing exists
    solely for the purpose of betting, and that this
    is not the case in relation to the other sporting
    codes on which betting is offered by licensed
    bookmakers, which are sustainable in their own
    right and do not in themselves owe their very
    existence to betting. There is therefore no
    persuasive rationale for the funding of these
    sports by betting operators, and no call for any
    such funding has previously been made.

16
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • The most concerning of the recommendations made
    by the GRC is however, its firm proposal that
    person-to-person betting exchanges should be
    brought into the regulatory framework.
  • South African gambling legislation is (quite
    rightly) predicated on acceptance of the policy
    proposition that, in order to ensure a publicly
    acceptable and credible gambling industry, at
    least one of the parties to any gambling or
    betting transaction should be licensed. Licensing
    implies by its very nature that the suitability
    and integrity of one of the parties to every such
    transaction has been positively established.
  • In person-to-person (P2P) betting exchanges,
    NEITHER of the parties to ANY betting transaction
    is licensed.
  • P2P betting exchanges merely match opposing
    bets on the same event and at the same odds
    between ordinary members of the public, against
    payment of a commission to the P2P betting
    exchange. These entities therefore simply provide
    a platform for persons wishing to bet, and are
    not themselves parties to such bets.

17
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • In essence, P2P betting means that if Player A
    wants to bet R20, at odds of 20 to 1, that Horse
    X will win the third race at Kenilworth, Player A
    will only have a bet if the P2P betting exchange
    identifies another person, say Player B, who
    wishes to bet at the same odds against that
    outcome.
  • Therefore, the P2P betting exchange is not a
    party to the wager, but merely provides the
    platform for the matching of two parties with
    directly opposing view regarding the result of
    the event on which the betting is to be struck.
  • Player A therefore bets, not against the P2P
    betting exchange, but against Player B. Player
    Bs bet is accordingly that, Horse X will NOT win
    the third race at Kenilworth on the day in
    question, and Player B will therefore win only
    if Horse X does NOT win. Therefore, in each and
    every case, one of the players will always be
    betting on the non-materialisation of the result.
    If, in each and every case, there are people
    betting on losing outcomes, this incentivises
    cheating and manipulation.
  • International examples of cheating in sports on
    which betting is struck abound.

18
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • The P2P model therefore conflicts fundamentally
    with the core premise on which the gambling and
    betting industries have been legalised in this
    country (and internationally) namely that the
    licensing process provides the essential
    assurances that the industry will be honestly
    operated. This can be achieved only if at least
    one party to every betting transaction has been
    probed and found to be fit and proper to
    participate in the industry.
  • This is not possible in the context of P2P
    betting exchanges.
  • Although the Final Report of the GRC suggests
    that certain forms of betting exchanges are
    already licensed in South Africa, it is important
    to recognise that the existing licensed model is
    not a P2P exchange, because in terms of that
    model, bets may be struck only as between
    bookmakers and other bookmakers, on the one hand,
    or bookmakers and members of the public, on the
    other. In the current model, therefore, at least
    one party to every betting transaction is
    licensed.
  • The P2P betting exchange potentially transforms
    each and every member of the public into an
    unlicensed bookmaker.
  • Betting on losing outcomes induces cheating,
    inasmuch as persons betting on these outcomes
    have a clear financial incentive to ensure that
    the (losing) outcome materialises. This is
    particularly dangerous (and deceptively simple to
    achieve) in the context of horseracing.
  • P2P exchanges by their very nature can also be
    expected to bring about the proliferation of a
    host of unlicensed persons endeavouring to make
    their living by acting as bookmakers.

19
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • ALL SECTORS of the licensed horseracing and
    betting industry in South Africa have
    consistently registered their vehement opposition
    to the legalisation of P2P betting exchanges in
    this country. Traditional bookmakers, the
    National Horseracing Authority (NHRA) (formerly
    the Jockey Club of Southern Africa) and both
    currently licensed totalisator operators (Gold
    Circle and Phumelela) are united in their stance
    in this regard.
  • The Asian Racing Federation, which represents all
    horseracing controlling bodies in Asia and
    Arabia, as well as the NHRA in South Africa and
    the national controlling bodies in Australia and
    New Zealand, as well as the International
    Federation of Horseracing Authorities (which
    represents the global racing industry) have
    similarly expressed their unqualified opposition
    to the proposed legalisation of P2P betting
    exchanges, for reasons which are similar to those
    given herein. It is suggested that the confluence
    of views on the subject by the overwhelming
    majority of first level horseracing countries
    throughout the world should give pause for
    careful and sustained reflection on the matter
    before any decision to introduce betting
    exchanges is taken.

20
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • CONCLUSION
  • The licensed bookmaking industry has the
    interests of the sport of horseracing at heart,
    recognising that the promotion of these interests
    is fundamental to the survival of ALL industry
    stakeholders, and not merely its own.
  • The Gambling Review Commission has itself
    suggested that
  • What is required is a more complete review of
    the horseracing sector, particularly the
    integration of the ownership of the tracks and
    the tote, as well as the competitive challenges
    of the future, and an appropriate industry and
    regulatory structure should be researched and
    developed.
  • The licensed bookmaking sector firmly agrees with
    the proposition that a more comprehensive review
    of the sector is called for, thanks the
    Commission for the opportunity to present its
    views on the current state of the industry and
    looks forward to making a constructive
    contribution to any further review process in the
    future.
  • It is hoped that this presentation has succeeded
    in providing the Committee with a clearer picture
    of the horseracing and betting industry, the
    challenges facing it, and the operations of its
    various stakeholders, and as such, will assist
    the Committee in reaching informed conclusions
    regarding the way forward.

21
PROVINCIAL BOOKMAKERS' ASSOCIATIONSSubmission to
Portfolio Committee on Trade Industry
  • Thank you.
  • Questions?
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