William Hillhas a strong centralised process to ensure regulatory compliance and the delivery of a responsible gambling agenda.
We operate on a principle of senior management responsibility with all key senior managers (down to Area Manager level) carrying personal licences granted by the Gambling Commission.
We currently carry out around 3500 responsible gambling interactions (RGIs) a month and 500 self-exclusions.
RGIs are recorded in narrative form which facilitate quality assurance and management follow up.
We carry out periodic offsite training and issue workbooks to all shop based colleagues which covers all aspects of regulatory compliance (Gambling Act, Health and Safety etc.).
The policies and procedures we follow are set out in a comprehensive compliance manual - which is used as the basis of our training. This contains comprehensive coverage of problem gambling indicators and also issues around age verification, integrity in sports betting, the identification of suspicious activity (potential criminal spend). Any high street retail business carries risk and the important thing is to manage that risk to the lowest practicable level.
Self-exclusion (which is an option for customers subject to an RGI) works for many and we estimate that around 80% of self-excluders are prevented from gambling during their exclusion period (minimum 12 months). The Gambling Commission figures on self-exclusion breaches are misleading as they include people who re-enter but are prevented from gambling.
All aspects of regulatory compliance, health and safety and shop security are closely linked. For example the enforcement of age verification provisions or upholding standards of behaviour can cause flash points.
That is why we have focussed on conflict management training for vulnerable colleagues; as well as ensuring, through risk assessment, that all shops have appropriate security measures. Many of our shops now deploy "staff safe" which is a third party monitoring system.
We have over 70 security colleagues including anti money laundering specialists and those focussed on preventing crime. Each time an incident occurs, the shop's security level is reassessed.
Gaming machines have anti-fraud software which, for example, highlights cash in and out with minimal play. In the New Year we will be implementing additional statutory and voluntary gaming machine controls.
Robbery rates are consistently being driven downwards (around 60% in London), cash loss is minimal and the introductions of safe havens means when robberies occur, colleagues are able to retreat from the counter; leaving would be robbers staring at an unmanned security screen.
Finally we run a series of shop exception reports to identify at risk customers or unusual customer activity which means that management are not solely reliant on shop colleagues to report upwards.
We are becoming increasingly sophisticated in how we capture, analyse and utilise management information to protect the three Licensing Objectives.
The debate around betting shops and gaming machines remains relatively unsophisticated, mainly because people do not understand (or do not want to understand) the complexities that surround the issue of problem gambling.
There will always be narrative stories about people who have had their lives severely impacted by pathological gambling. We sympathise and recognise that all gambling products have the capacity to cause a minority of individuals significant harm; which is why we are focussed on responsible gambling. Pathological gamblers need counselling and treatment and they will always find ways to gamble. In betting shops there is a signposting opportunity and the betting industry provides the majority of treatment funding.
However, policy should be based on proportionality and empirical evidence; not on isolated emotional narrative. The hard facts are that the retail betting industry supports 40,000 direct jobs and a further 60,000 indirect jobs. Many colleagues build long term careers in a great socially responsible and community based industry.
One matter that is often forgotten is our millions of customers like visiting the betting shop. They value the entertainment and mental stimulation it provides, the interaction with other customers and the sense of belonging to a community engendered by the welcome and consideration they receive from shop colleagues.