International Agreements Committee
Tuesday 21st July 2026
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14:06
Speaker 1
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Speaker 1
Welcome to this meeting of the International Agreements Committee. Welcome to this meeting of the International Agreements Committee in the House of Lords. And I formally welcome Emma Floyd, director, Sport and Gambling at the Department for digital, culture, Media and Sport. And Simon Mason, Deputy director, sport at the Department for digital, culture, Media and Sport. And as ever, may I remind you that this session is on the record. It's broadcast and it is transcribed. This is our third and final public inquiry session on the Council of Europe Convention on the Manipulation of Sports competitions, known as the Mechelen Convention.
I shall ask the opening question, and after that I will defer to my colleagues, who will then go for ask questions, where they will go further and have more detailed questions to ask. First of all, though, I'd like to thank both witnesses for the department. Your department, at the time when you were the DCMs, so to speak, for giving us the written evidence that you did. First of all, I'd like to thank both witnesses for the Department. Your department and written evidence that you did.
First of all, though, I'd like to thank both witnesses for the department. Your department at the time when you were the DCMs, so to speak, for giving us the written evidence that you did. It was very helpful to have that as background before this, but also more generally for the work that we are doing. So my general question in starting, what is the government's assessment of the issue of sports manipulation and its impacts on the UK?And I don't know whether Emma would like to start first, but as you're answering questions, can you decide between you?Who goes first?
I shall ask the opening question, and after that I will defer to my colleagues, who will then go for ask questions, where they will go further and have more detailed questions to ask. First of all, though, I'd like to thank both witnesses for the department. Your department, at the time when you were the DCMs, so to speak, for giving us the written evidence that you did. First of all, I'd like to thank both witnesses for the Department. Your department and written evidence that you did.
First of all, though, I'd like to thank both witnesses for the department. Your department at the time when you were the DCMs, so to speak, for giving us the written evidence that you did. It was very helpful to have that as background before this, but also more generally for the work that we are doing. So my general question in starting, what is the government's assessment of the issue of sports manipulation and its impacts on the UK?And I don't know whether Emma would like to start first, but as you're answering questions, can you decide between you?Who goes first?
14:08
Speaker 2
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Speaker 2
Well, thank you chair. Thank you very much for having us today. So, um, you know, we see sports manipulation, you know, match fixing a very serious threat to the integrity of sport, to public confidence, fair competition, but also the integrity of the regulated betting market. And at a personal level, you know, vulnerable athletes is a threat to them to I expect the Gambling Commission would have spoken to you about the fact that incidents of reporting have gone up. Um, the Sports Betting Integrity Unit between 2004 and 2020.
Sorry, 2025. And let me get that right again, 2024 and 2025 reporting went up by 28%. In football, in tennis, which really reflects the global popularity and the volume of those sports happening, as opposed to systematic sort of corruptions in those particular sports and much increasingly happening in the lower tiers of sport. Uh, and one of the sort of challenges as well is the increasingly international nature of match fixing. So you can have your athlete from a particular country, the sporting event in a different country, the intermediary who approaches the player might be from yet another country where the betting takes place could be somewhere else.
The money can flow somewhere else, and ultimately the the person at the top orchestrating this, which could be organised crime, could be in yet another country. So working across jurisdictions makes this increasingly complicated. So I think the risk and complexities are increasing. And it's also getting increasingly sophisticated. And the speed at which actions can be taken is also continuing to increase. So very serious threat. I mean, in the UK, we do have strong existing safeguards.
So the Sports Basic Sport Betting Integrity Unit has existed since 2010, uh, governing bodies, law enforcement all take this very seriously as do betting operators. So there is the system within the UK is incentivised to work together to tackle this. However, as I've set out, given the inherently global nature of this, we need to work with other other countries and cooperate in order to really tackle this together.
Sorry, 2025. And let me get that right again, 2024 and 2025 reporting went up by 28%. In football, in tennis, which really reflects the global popularity and the volume of those sports happening, as opposed to systematic sort of corruptions in those particular sports and much increasingly happening in the lower tiers of sport. Uh, and one of the sort of challenges as well is the increasingly international nature of match fixing. So you can have your athlete from a particular country, the sporting event in a different country, the intermediary who approaches the player might be from yet another country where the betting takes place could be somewhere else.
The money can flow somewhere else, and ultimately the the person at the top orchestrating this, which could be organised crime, could be in yet another country. So working across jurisdictions makes this increasingly complicated. So I think the risk and complexities are increasing. And it's also getting increasingly sophisticated. And the speed at which actions can be taken is also continuing to increase. So very serious threat. I mean, in the UK, we do have strong existing safeguards.
So the Sports Basic Sport Betting Integrity Unit has existed since 2010, uh, governing bodies, law enforcement all take this very seriously as do betting operators. So there is the system within the UK is incentivised to work together to tackle this. However, as I've set out, given the inherently global nature of this, we need to work with other other countries and cooperate in order to really tackle this together.
14:10
14:10
14:10
Speaker 1
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Speaker 1
Thank you very much indeed. And I'm just about to go to Lord Stevenson for his question. What I should explain to you is that you can see that online. Uh, our chairs name is there, Dominic Johnson. I'm standing in for him at the moment, quite rightly, with his with his family and not here at the moment. Um, but Dominic is going to take part on occasions during the course of this, so I shall be watching that in case he wants to ask a question as well.
Anyway, well over to you, Lord Stevenson.
Anyway, well over to you, Lord Stevenson.
14:11
Speaker 3
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Speaker 3
Thank you very much. And thank you also for your written your written evidence, which was very helpful. Um, the. You've already explained that this is a very complicated and international, not just a national issue. And much of the work that you will have to do will have to involve other parties not based in this country, other organisations, but it will also depend on the work that's being done inside the UK by the various bodies that are actually directly involved in it.
So could you perhaps explain what other measures you think might be necessary or speculating what might other measures might be necessary to get this fully in place as we move forward?
So could you perhaps explain what other measures you think might be necessary or speculating what might other measures might be necessary to get this fully in place as we move forward?
14:11
Speaker 2
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Speaker 2
Yes, very happy to thank you for the question. So, um, through our assessment of the convention and how it applies in the UK, we undertook a full compliance assessment to assess how it works within our existing arrangements and existing structures, and have concluded that our existing structures are sufficient to meet the requirements of the convention. I guess within that context, in terms of the wider support that we provide, um as government to the to the system to make sure that it operates effectively. There are a number of elements that we pulled out in that context.
And so fundamental to the, the support of our, our system in this space. And as we set out in article seven in the convention, is the support provided to sports bodies. So in our situation, sports governing bodies and national governing bodies of sports who play a vital and integral role in in the management of this kind of issue and in terms of tackling manipulation and corruption within sport, we have a as a number of areas through which we support them with. Most notably, I would say, the code for sports governance, which is co-owned by our arms length bodies, UK Sport and Sport England.
And through that code it provides advice, guidance but also sets requirements for any organisation in receipt of public funding and the specific areas that they need to be able to demonstrate that they are taking forward. Included within that are requirements around governance, but also financial probity, um as a key element of that work. And both UK Sport and Sport England do provide ongoing advice and guidance to, to sport governing bodies to support within that area. Within the specific context of how to manage and address sport, sport, match fixing issues, um, both the, the work of the sports Betting Intelligence unit, which is part of the Gambling Commission, as well as the Sport Betting Integrity Forum, provide vital structures through which it provides guidance, education, support to all organisations and sports organisations to ensure that they are able to to manage these kind of issues as effectively as possible.
Um, and I think within that context, any sports organisation is able to be part of that, that forum and to particularly have those ongoing conversations and have that ongoing support. And ultimately, through our assessment, we've concluded on that basis that the structures that we have in place do provide the requirements as set out through the convention. And it's something that we can we can therefore take forward within that context. I think just to build on Emma's earlier point as well, we entirely recognise that this is an international issue.
So through ratification and ongoing engagement with European and international partners, we can continue to build those international networks and support our sports organisations as well. Through those ongoing conversations.
And so fundamental to the, the support of our, our system in this space. And as we set out in article seven in the convention, is the support provided to sports bodies. So in our situation, sports governing bodies and national governing bodies of sports who play a vital and integral role in in the management of this kind of issue and in terms of tackling manipulation and corruption within sport, we have a as a number of areas through which we support them with. Most notably, I would say, the code for sports governance, which is co-owned by our arms length bodies, UK Sport and Sport England.
And through that code it provides advice, guidance but also sets requirements for any organisation in receipt of public funding and the specific areas that they need to be able to demonstrate that they are taking forward. Included within that are requirements around governance, but also financial probity, um as a key element of that work. And both UK Sport and Sport England do provide ongoing advice and guidance to, to sport governing bodies to support within that area. Within the specific context of how to manage and address sport, sport, match fixing issues, um, both the, the work of the sports Betting Intelligence unit, which is part of the Gambling Commission, as well as the Sport Betting Integrity Forum, provide vital structures through which it provides guidance, education, support to all organisations and sports organisations to ensure that they are able to to manage these kind of issues as effectively as possible.
Um, and I think within that context, any sports organisation is able to be part of that, that forum and to particularly have those ongoing conversations and have that ongoing support. And ultimately, through our assessment, we've concluded on that basis that the structures that we have in place do provide the requirements as set out through the convention. And it's something that we can we can therefore take forward within that context. I think just to build on Emma's earlier point as well, we entirely recognise that this is an international issue.
So through ratification and ongoing engagement with European and international partners, we can continue to build those international networks and support our sports organisations as well. Through those ongoing conversations.
14:14
14:14
14:14
14:14
Speaker 4
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Speaker 4
I'd like to look at the legislative base for, um the ratification and particularly in respect of of the devolved administrations and in particular about Northern Ireland, given that Northern Ireland has its own legislative base, but also the fact that some sports are done on an all island basis, and that regulation in Northern Ireland is complex, to say the least. And I use your words there. I wonder if you could, um, tell us what was your assessment in respect of Northern Ireland and also perhaps um what further information you've received from the devolved administrations um regarding their implementation measures.
Now I know this is a complex area and I've got a supplementary if I may, afterwards.
Now I know this is a complex area and I've got a supplementary if I may, afterwards.
14:15
Speaker 5
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Speaker 5
Okay, let me start with that one. So you're absolutely right. The convention applies UK wide and things are different in different sort of nations. Um so the Gambling Commission is clearly the regulator in England, Scotland and Wales and they have some enforcement powers and they're very experienced working across those different legal frameworks, including with Police Scotland. Um, and maybe we'll just touch on sort of Northern Ireland where there isn't the equivalent of the Gambling commission, the sort of regulation and sort of licensing is shared across the Department for communities, the courts and the district council.
So it is a different set. The convention doesn't require regulation to happen in a particular way within a jurisdiction to be part of it. So that is not an issue. Convention is very much about how do you coordinate and share information. So the Gambling Commission, Sibiu, is the the national platform and the Northern Ireland organisations were absolutely do provide information through that to go through the Copenhagen network. So there is no issue with sharing information. Um as part of the assessment, we talked with each of the devolved governments about what the convention requires, and they looked at how things were operating in their jurisdiction and in their area and their bodies.
And they, they were confident that they and we are confident that across the board, we are compliant with that. In terms of how we go about implementing things. This is where having things like the forum and the strong relationships really important to make sure that we do do this in a coherent and joined up way. And that information is being shared. So by having the intelligence unit at the heart of it, I think that's, that's a really important part. And there is no issues with that information being shared.
You also touched on the fact that a lot of the governing, some of the governing bodies are all Ireland, and again, they're quite experienced at having to operate across the different boundaries and often having to do different things if they are in Ireland or when it relates to the UK within Northern Ireland, and they certainly haven't raised any concerns with us about implementing this, because actually much of it's already in place already.
So it is a different set. The convention doesn't require regulation to happen in a particular way within a jurisdiction to be part of it. So that is not an issue. Convention is very much about how do you coordinate and share information. So the Gambling Commission, Sibiu, is the the national platform and the Northern Ireland organisations were absolutely do provide information through that to go through the Copenhagen network. So there is no issue with sharing information. Um as part of the assessment, we talked with each of the devolved governments about what the convention requires, and they looked at how things were operating in their jurisdiction and in their area and their bodies.
And they, they were confident that they and we are confident that across the board, we are compliant with that. In terms of how we go about implementing things. This is where having things like the forum and the strong relationships really important to make sure that we do do this in a coherent and joined up way. And that information is being shared. So by having the intelligence unit at the heart of it, I think that's, that's a really important part. And there is no issues with that information being shared.
You also touched on the fact that a lot of the governing, some of the governing bodies are all Ireland, and again, they're quite experienced at having to operate across the different boundaries and often having to do different things if they are in Ireland or when it relates to the UK within Northern Ireland, and they certainly haven't raised any concerns with us about implementing this, because actually much of it's already in place already.
14:17
Speaker 4
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Speaker 4
Two things. First of all, um, the relationship between the Irish Republic and Northern Ireland is always been difficult. Um, let's put it that way. And given that the um, the oversight here we're talking about, you know, the police on both sides of the border, we're talking about the governments of both sides of the border. Um, I, the information sharing is that certainly the case with the police forces of both countries in Northern Ireland and the Irish Republic. Is it certainly the case on on the government agencies in the Republic of Ireland who are sharing that information?And my second.
Supplementary is that it may be slightly confusing to me, but in your, um report, in your submission, you said the devolution landscape is complex across the government structures and devolved governments. Devolved governments were consulted during the ratification process, concluding that existing legislative and administrative agreements across arrangements across the UK are sufficient to meet the convention's requirements. The interesting thing that I found about that sentence is that that you consult and the consultation concluded. It doesn't tell me whether it was concluded by your department or whether it was concluded by everyone in general.
And if it is the latter, then I think we ought to be clear on that, that each of the parts of the United Kingdom have concluded that they have the right legislative arrangements, but it still doesn't. It still leads me to be concerned about the level of cooperation that there might be in Northern Ireland across the border with the Irish Republic.
Supplementary is that it may be slightly confusing to me, but in your, um report, in your submission, you said the devolution landscape is complex across the government structures and devolved governments. Devolved governments were consulted during the ratification process, concluding that existing legislative and administrative agreements across arrangements across the UK are sufficient to meet the convention's requirements. The interesting thing that I found about that sentence is that that you consult and the consultation concluded. It doesn't tell me whether it was concluded by your department or whether it was concluded by everyone in general.
And if it is the latter, then I think we ought to be clear on that, that each of the parts of the United Kingdom have concluded that they have the right legislative arrangements, but it still doesn't. It still leads me to be concerned about the level of cooperation that there might be in Northern Ireland across the border with the Irish Republic.
14:19
Speaker 5
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Speaker 5
Yes. Um, so let me answer your second one first. So the Who concluded that it was actually for the devolved administrative devolved devolved administrations concluded they were the ones who ultimately made the judgment that their, uh, what they had in place met the convention to provide us with assurance on that basis. So that was their judgment. Um, so when I said about information sharing, I just to clarify, I meant between the parts of the UK that I guess I was trying to highlight that there was no issue with the fact that the gambling Commission doesn't have a Northern Ireland jurisdiction, with the platform being able to use by Northern Ireland.
So between Northern Ireland and Ireland is a different matter. Ireland aren't in the same place with the UK on the convention at the moment. They're not sort of signed up in sort of at the same the same point we are. So they wouldn't have the same legal requirement from this convention to share information as other countries who would have ratified it. Um, I do believe there is information sharing going on, but clearly, if Ireland were also ratified this convention, that would be stronger.
So between Northern Ireland and Ireland is a different matter. Ireland aren't in the same place with the UK on the convention at the moment. They're not sort of signed up in sort of at the same the same point we are. So they wouldn't have the same legal requirement from this convention to share information as other countries who would have ratified it. Um, I do believe there is information sharing going on, but clearly, if Ireland were also ratified this convention, that would be stronger.
14:20
Speaker 4
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Speaker 4
Uh, sorry to come back to you, but where you've got an all island sport, then you're going to need that cooperation in order to be able to ensure that you're able to deal with it. If they with corruption, if you if you if you can, if you seek if you find it. So, um, are you actually saying that there is no hunt going on to try and do to try and make sure the relationship with the Irish Republic is in place?Or is it simply that they're just behind the curve and that they will catch up?But it does strike me having, you know, major sports which are on an all island basis that, um, you know, the border is non-existent as far as those sports are concerned.
And therefore the, um, the, the regulation, which is part of this would also have to be fairly seamless. And, and what you described to me just then was that it's actually in place in Northern Ireland, but not in the Republic and not. And really the question I want to know is whether there is um whether there has been work to ensure that, that the regulatory authorities in both parts of the border, both sides of the border, have been working closely and will work closely on this matter.
And I wonder if you could reassure us about that work going on, or whether it's something to be had in the future.
And therefore the, um, the, the regulation, which is part of this would also have to be fairly seamless. And, and what you described to me just then was that it's actually in place in Northern Ireland, but not in the Republic and not. And really the question I want to know is whether there is um whether there has been work to ensure that, that the regulatory authorities in both parts of the border, both sides of the border, have been working closely and will work closely on this matter.
And I wonder if you could reassure us about that work going on, or whether it's something to be had in the future.
14:22
Speaker 2
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Speaker 2
So I suppose just on a one comment, I would say in the context of, um, the sports governing bodies, as you touch on a number of them are on an all island basis, and there are a number of elements where they obviously work across, across all across the whole of the island of Ireland to, to manage and deliver various different policy interventions, policy areas and spaces in that space. So there is we have got a lot of confidence that they're able to work across different jurisdictions within that context and within that space.
And the other point I say is that I suppose it comes back to the overall objective of the convention is to improve international engagement and international operations of these kind of functions. And this kind of, um, and addressing this kind of challenge. So from my perspective, there is a strong opportunity in that space for that continued international cooperation with partners, including including Ireland, to continue those conversations. Clearly, it was a matter for the the devolved government in Northern Ireland to continue the conversations from the specific kind of nature of the the gambling regulatory regime that exists across those two countries.
And the other point I say is that I suppose it comes back to the overall objective of the convention is to improve international engagement and international operations of these kind of functions. And this kind of, um, and addressing this kind of challenge. So from my perspective, there is a strong opportunity in that space for that continued international cooperation with partners, including including Ireland, to continue those conversations. Clearly, it was a matter for the the devolved government in Northern Ireland to continue the conversations from the specific kind of nature of the the gambling regulatory regime that exists across those two countries.
14:23
Speaker 1
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Speaker 1
Is there something that you may pursue later?I think yes, I appreciate you're trying. You're doing everything that is diplomatic in what is often a very. It's, as Lord chairman has said, a sensitive situation. But clearly what we're concerned about is that, um, we have. Not only carried out a proper scrutiny of our current situation, but how that's going to happen when we get if the government does ratify the convention itself. But but thank you for that stage so far.
I now turn to Lord Harney, please, for the next question.
I now turn to Lord Harney, please, for the next question.
14:23
Speaker 6
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Speaker 6
Yes. Well, the question I want to put to you runs rather against quite a lot of the evidence you've given in answering the previous questions, which in which you said and others of our witnesses have said that to that the international dimension of the manipulation of sports competitions is on the rise and is a very big part of the problems that you face and we face together because. The committee understands that only 17 member states of the Council of Europe have ratified the convention to date, while a further 25 have signed but not ratified, and presumably therefore don't apply it in legal terms.
And what is your understanding of why such a large number of member states are not ratified?I have not yet ratified the agreement. Do you think they're on the way to get there?Uh, and, uh, to. What extent did that international dimension, uh, influenced the British government's decision to now go ahead and ratify, which, after all, we've taken quite a bit of time to do.
And what is your understanding of why such a large number of member states are not ratified?I have not yet ratified the agreement. Do you think they're on the way to get there?Uh, and, uh, to. What extent did that international dimension, uh, influenced the British government's decision to now go ahead and ratify, which, after all, we've taken quite a bit of time to do.
14:24
Speaker 2
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Speaker 2
Yes. So I suppose just as a as a point of clarification for the committee, we understand it is 26 countries, including ourselves, who are yet to formally sign, as it were. So it's 43 countries in total who are signatories, of which 17 are have ratified. Um, but I think I think to the, to the wider point, I think it's a, it's a really important question in the context of how much we want to continue to drive international cooperation on this, on this issue. And it's something that we as, as the UK really see ourselves taking a leadership leadership role in.
And I can touch a little bit on that. And as you. I can't obviously speak to the individual circumstances of each nation who has signed and not yet moved to ratification. Within that context, I think we are aware that the constitutional arrangements of different countries are quite challenging and can be quite complex in this area. Um, and therefore moving to ratification has required some kind of detailed work. And certainly on our side, it has required quite a lot of detail work to ensure that we are aligning and can deliver and deliver against the requirements of the convention in that space.
And we are aware that there are some there have been some specific issues in the context of the EU's ratification in relation to, um, some specific circumstances in the context of Malta. Um and I believe that has come up to, to the committee before we can potentially touch on that in slightly more detail. Um, but within that context, um, we're aware that a number of EU nations have obviously now moved to be able to ratify, which we see as positive progress within that context and good positive developments in that space.
Um, I think the other space we touch on is we've been really encouraged to see that the convention is being signed by nations who aren't core members of the Council of Europe as well. So we're aware that both Australia and Morocco have now signed the convention as well, which we think is another positive step forward in that in that wider context. So I think overall, our sense is that, um, the more countries that ratify the convention, the better from our perspective, and as the UK, we want to really maintain a core leadership role, both now, but also into the future.
Um, as we continue to kind of challenge this overall question.
And I can touch a little bit on that. And as you. I can't obviously speak to the individual circumstances of each nation who has signed and not yet moved to ratification. Within that context, I think we are aware that the constitutional arrangements of different countries are quite challenging and can be quite complex in this area. Um, and therefore moving to ratification has required some kind of detailed work. And certainly on our side, it has required quite a lot of detail work to ensure that we are aligning and can deliver and deliver against the requirements of the convention in that space.
And we are aware that there are some there have been some specific issues in the context of the EU's ratification in relation to, um, some specific circumstances in the context of Malta. Um and I believe that has come up to, to the committee before we can potentially touch on that in slightly more detail. Um, but within that context, um, we're aware that a number of EU nations have obviously now moved to be able to ratify, which we see as positive progress within that context and good positive developments in that space.
Um, I think the other space we touch on is we've been really encouraged to see that the convention is being signed by nations who aren't core members of the Council of Europe as well. So we're aware that both Australia and Morocco have now signed the convention as well, which we think is another positive step forward in that in that wider context. So I think overall, our sense is that, um, the more countries that ratify the convention, the better from our perspective, and as the UK, we want to really maintain a core leadership role, both now, but also into the future.
Um, as we continue to kind of challenge this overall question.
14:27
14:27
Speaker 2
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Speaker 2
Uh, very much so. In terms of continuing the conversation with other partners to understand what challenges that they've got in that space, clearly, we will not have a direct role in the specific, uh, specific framework arrangements of, of another nation, but we do have a really strong and important role in terms of supporting that conversation. I think we also would become part of the, the follow up committee. Um, so we will continue to then. And the Gambling Commission especially will be involved in those future conversations as the nature of this challenge and the nature of this question changes.
And I think that's a really important part of that, that ongoing engagement that we would continue to have with with nations in this space. So, yes, it would be something that we would be continuing to work with other partners to understand how they can continue to do more in this area.
And I think that's a really important part of that, that ongoing engagement that we would continue to have with with nations in this space. So, yes, it would be something that we would be continuing to work with other partners to understand how they can continue to do more in this area.
14:28
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14:28
Speaker 7
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Speaker 7
I was a little late. I was chairing two other meetings and I tried to finish them as quickly as I could. But you're limited when there are guests. And now we have heard during our evidence sessions, um, very much support for the treaty and Britain um, ratify. However, I would like just to ask a contrarian point, which is. Yes. Is the value to Britain given that or to the UK, given that we already are in compliance with the treaty and given that um we are one of the leaders in sport as we see, but.
Is there any practical value other than voting rights, voting representation. And, and some sort of leadership, given that we've got by without doing it. And some people would regard signing up to conventions and treaties as yet another encumbrance, which though it doesn't now and I recognise that is true, will bring its own bureaucracies and will bring its own um, demands, which may not be our priorities. It hasn't been our priority to put it first for some time, and yet there seems to be a push.
Now, I'd like you to make the case against signing up though. I know, um, there is a broad consensus in favor. And tell me what would be the disadvantages of signing up. Or not signing up but ratifying. Yes.
Is there any practical value other than voting rights, voting representation. And, and some sort of leadership, given that we've got by without doing it. And some people would regard signing up to conventions and treaties as yet another encumbrance, which though it doesn't now and I recognise that is true, will bring its own bureaucracies and will bring its own um, demands, which may not be our priorities. It hasn't been our priority to put it first for some time, and yet there seems to be a push.
Now, I'd like you to make the case against signing up though. I know, um, there is a broad consensus in favor. And tell me what would be the disadvantages of signing up. Or not signing up but ratifying. Yes.
14:30
14:30
14:30
14:30
Speaker 2
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Speaker 2
So should I, um, um, so I think, I mean, it's a really interesting question. I think, um one of, as you say, from a fundamental how our frameworks operate in the United Kingdom, signing up to the convention doesn't shift our operational model for the regulation of this kind of activity. So therefore, there is a, an additional burden that that potentially, uh, means in that we are moving to having more international engagement through this process. I suppose what we would say and what we would reflect on is that the nature of the challenge is shifting and becoming more international within that very context.
So, um, one of the big benefits of signing up is, is being part of those follow on committees, follow up committees being part of that ongoing conversation. Um, I think the other area we would, we would obviously reflect on is that, uh. It is a, a, you know, 43 nations have signed up to the UN convention. That's really positive. There's also an awful lot of nations that aren't part of that, that collective group. Um, so I think from our perspective, ensuring that our focus is fully international and not just on our Council of Europe partners and people who are signed up to the convention, because clearly these issues are go to other, other parts of the world where, um, where, who aren't necessarily members of the convention.
And we would, you know, support that wider engagement. So I think there's a, there's a couple of challenges, I would say in that space to make sure that we are very much continuing to look at this as a fully international issue and are engaging with different types of markets. And we know across the, the wider, um, gambling space that clearly different markets are emerging in different parts of the world with different regulatory structures.
So, um, one of the big benefits of signing up is, is being part of those follow on committees, follow up committees being part of that ongoing conversation. Um, I think the other area we would, we would obviously reflect on is that, uh. It is a, a, you know, 43 nations have signed up to the UN convention. That's really positive. There's also an awful lot of nations that aren't part of that, that collective group. Um, so I think from our perspective, ensuring that our focus is fully international and not just on our Council of Europe partners and people who are signed up to the convention, because clearly these issues are go to other, other parts of the world where, um, where, who aren't necessarily members of the convention.
And we would, you know, support that wider engagement. So I think there's a, there's a couple of challenges, I would say in that space to make sure that we are very much continuing to look at this as a fully international issue and are engaging with different types of markets. And we know across the, the wider, um, gambling space that clearly different markets are emerging in different parts of the world with different regulatory structures.
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Speaker 7
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Speaker 7
But given that and given that this convention really will not tackle the very big international problems, such as the betting markets in Asia over which we have no control, and some of the other, um, Asian markets, isn't it?A very limited convention, which may apply. Um. Here locally as it were, but not globally. And isn't that a real problem.
14:32
Speaker 5
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Speaker 5
I. You're right. Sort of. You need broad participation for this to sort of be as successful as possible. And there's a question about how far do you try and how far you don't. It also depends, and I've had time to think. It does depend on robust national implementation as well, because your effectiveness is always going to be the lowest common denominator of who's doing least well, sort of nationally. So those are some of the things.
And then there are sort of evolving threats. So so you know, there are arguments. You could say that, you know, why would we put our time and effort into this doing it this way?If there's only, you know, potentially another 40 countries, there's a lot more countries in the world, but this is probably the best international agreement that is out there. And, you know, given what we have been doing, this seems like a really good way of working together more collaboratively getting I think one of the practical benefits is the the speed at which people are required to give us information as opposed to at the moment it is done on goodwill.
Um, so I think that's, that's a sort of practical benefit for the sort of gambling commission in particular, um, the enforcement arm that I think that that is one of the most tangible things. I think it gives you.
And then there are sort of evolving threats. So so you know, there are arguments. You could say that, you know, why would we put our time and effort into this doing it this way?If there's only, you know, potentially another 40 countries, there's a lot more countries in the world, but this is probably the best international agreement that is out there. And, you know, given what we have been doing, this seems like a really good way of working together more collaboratively getting I think one of the practical benefits is the the speed at which people are required to give us information as opposed to at the moment it is done on goodwill.
Um, so I think that's, that's a sort of practical benefit for the sort of gambling commission in particular, um, the enforcement arm that I think that that is one of the most tangible things. I think it gives you.
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14:34
Speaker 8
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Speaker 8
Yes. Thank you for your evidence. Um, Miss Floyd, your director of sport and gambling within the department. I should declare my interest as a vice president of the Lotteries Council. And the World Lottery Association has said that the manipulation of sports competition undermines not only the integrity of sports, but also the credibility and reputation of the lottery and betting sectors worldwide. You yourself listening to evidence, have made a compelling case for broad participation within the convention. Help us then understand um, given the delay due to due to competing priorities of our government in ratifying the.
The the convention. Help us to understand what the particular reasons for moving forward with ratification are for us at this time. You've pointed to broad participation, and yet we haven't ratified. The arguments for ratification that hopefully, you've also given to ministers.
The the convention. Help us to understand what the particular reasons for moving forward with ratification are for us at this time. You've pointed to broad participation, and yet we haven't ratified. The arguments for ratification that hopefully, you've also given to ministers.
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Speaker 5
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Speaker 5
Yes, absolutely. And perhaps one of the other things it's worth talking about in terms of why has ratification taken a while and Simon mentioned this earlier, but there is the example of the Malta case, whereby Malta, um, sort of challenged the definition of illegal sports betting within the convention. They would withdraw that. But there was this, this question about what, what what is the definition?Because, uh, most countries like the UK, the definition is based on point of consumption, i.e. where is the person who makes the bet place?Whereas in Malta, um, they, uh, they, they, their, their license is based on the point of supply.
So they have a sort of, their view is there should be a passport model whereby you license someone in Malta and they should be able to provide betting products to anybody, anywhere in the single market. Now subsequently, the European Court of Justice has determined that that doesn't trump an individual country's laws. So that's that's there's been quite a bit of debate around that. And having sort of clarity on that has been, uh, where the, where the European Court of Justice come down has been helpful to be sort of clear about that.
So that that was an important bit of clarification in order to be able to ratify, in terms of your point about why now and what's the value?Um, so there would be a danger that if we didn't proceed with ratifying all of the work that people currently do with us on a goodwill basis because they understand it's our intention to ratify, they can see us working towards it. They could, they could choose to stop doing that whether they would or not, I don't know. But that that at the moment they believe we're on the bus, on the bus with them, and therefore they are sharing with us.
Um, so if we stopped, if they could see us sort of taking a different path, for whatever reason, we may lose some of that. So we may lose some of that information, whereas ratifying means it would be a legal requirement that they must share it with us. And we've talked quite a bit about how sophisticated the market is and how it's evolving. And this voting seat on the follow up committee is not it's not just a governance thing. It's really important because that gives us the ability to sort of shape the strategy about how we respond to these evolving threats and how we share information together.
And we work on the implementation across. And there's a lot of value to be had in that as well, because this is a fast moving, changing market. So having that voting seat and that voice at the table so we can learn together and we can shape, I would argue is very important.
So they have a sort of, their view is there should be a passport model whereby you license someone in Malta and they should be able to provide betting products to anybody, anywhere in the single market. Now subsequently, the European Court of Justice has determined that that doesn't trump an individual country's laws. So that's that's there's been quite a bit of debate around that. And having sort of clarity on that has been, uh, where the, where the European Court of Justice come down has been helpful to be sort of clear about that.
So that that was an important bit of clarification in order to be able to ratify, in terms of your point about why now and what's the value?Um, so there would be a danger that if we didn't proceed with ratifying all of the work that people currently do with us on a goodwill basis because they understand it's our intention to ratify, they can see us working towards it. They could, they could choose to stop doing that whether they would or not, I don't know. But that that at the moment they believe we're on the bus, on the bus with them, and therefore they are sharing with us.
Um, so if we stopped, if they could see us sort of taking a different path, for whatever reason, we may lose some of that. So we may lose some of that information, whereas ratifying means it would be a legal requirement that they must share it with us. And we've talked quite a bit about how sophisticated the market is and how it's evolving. And this voting seat on the follow up committee is not it's not just a governance thing. It's really important because that gives us the ability to sort of shape the strategy about how we respond to these evolving threats and how we share information together.
And we work on the implementation across. And there's a lot of value to be had in that as well, because this is a fast moving, changing market. So having that voting seat and that voice at the table so we can learn together and we can shape, I would argue is very important.
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Speaker 5
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Speaker 5
So I think sort of historically, you know, the government had. Very many things that were happening. So clearly, we had the pandemic for a number of years, which took up a lot of activity. There was, uh, leaving the European Union, which again took up a lot of activity. So I think that's part of the backdrop as to just the capacity within government in order to be able to bring forward something that's very important. But as always, there is a there is a capacity limit.
And there has been some unusual circumstances over the recent years.
And there has been some unusual circumstances over the recent years.
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Speaker 2
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Speaker 2
Yeah, I think, I think so. And um, alongside various other competing priorities that we can obviously always go into, but I think within that context, as you touched on the, the complexity that sits within the regime working across across the nations as well to make sure we have that clear understanding of what, of ensuring that we are compliant as a nation before ratification.
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Speaker 1
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Speaker 1
Just before I go to Lord Anderson, can I just continue on that theme of the competing priorities?I do appreciate that all departments have significant priorities. They have to try to sort out. And with regard to the national convention, clearly there is an issue of international justice matters. And how much work have you been able to do with other departments in the last two years?Because it has been a very busy two years. We've seen that in legislation here, but has it been possible to be able to work with them in order to be now in the position where you feel you've cleared the ground and can move forward?
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Speaker 5
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Speaker 5
So I think my take on that would be that I think we are in a good place on the sort of intelligence sharing information aspect of things and that sort of thinking about prevention. I think if I'm frank, where I think we've got more to do is on the enforcement side and sort of working through together, uh, what, what, what that looks like going forward. And, you know, there's a lot of work that national governing bodies are doing, but that often means you're, you're sort of catching perhaps the poor athlete who's probably been exploited in some way and actually getting to the people at the top of the tree is much more challenging.
So that how we how we sort of work together on enforcement to really make sure we're getting after the real really bad guys, I think is an area where, if I'm frank, I think we've still got more work to do off the back of ratifying the convention.
So that how we how we sort of work together on enforcement to really make sure we're getting after the real really bad guys, I think is an area where, if I'm frank, I think we've still got more work to do off the back of ratifying the convention.
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Speaker 3
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Speaker 3
Further reform that in your opening, Miss Floyd, you mentioned the increasing scale of the problem, the complexity and, um, the way in which I suppose the the malefactors are becoming more devious. Um, the. Convention was launched, concluded in 2014, 14 years ago. Um, concluded in 2009, 2019. Has is it showing its age a bit given these, the problems that you mentioned, what are the prospects of further reform?When we asked one earlier witness about further reform or change, she said that she thought the convention, given its global reach, should have been a UN convention rather than a European plus um.
The Council of Europe and various observer status nations. Do you agree?And do you what further reforms do you think are in prospect?
The Council of Europe and various observer status nations. Do you agree?And do you what further reforms do you think are in prospect?
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Speaker 5
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Speaker 5
Thank you. Um, so I think I said earlier, I do think this is the best available international agreement that is out there at the moment. And the best framework. Um, and, you know, the Copenhagen network platform information sharing is really positive and the speed that that brings and the common expectations it sets. Um, I would also say that whoever wrote this was very smart about making it technology neutral. So however people go about placing the bets, whether that in the sort of more modern prediction products, they're all caught by it.
So there's a reasonable amount of future proofing that's gone into the drafting, which I think is really positive. There's. I don't see immediate issues with the drafting of the convention that need updating for the modern day. I think it's about how we implement it. Um, because how we then go about making sure there is the robust national implementation and we learn about the evolving threats and share information and do that together. I think it's much more the implementation where we need to keep agile.
I don't think any of the wording and convention prevents that. On your point about, um, what kind of a convention?I mean, clearly, as we've already talked about, the more countries that are signed up to working together and cooperating, the stronger this is, um, the fact that we have Australia, Morocco and also Brazil are looking at it now is very promising. There's obviously still many other parts of the world as well to cover. So I think I think this is a very important platform to be building from.
So there's a reasonable amount of future proofing that's gone into the drafting, which I think is really positive. There's. I don't see immediate issues with the drafting of the convention that need updating for the modern day. I think it's about how we implement it. Um, because how we then go about making sure there is the robust national implementation and we learn about the evolving threats and share information and do that together. I think it's much more the implementation where we need to keep agile.
I don't think any of the wording and convention prevents that. On your point about, um, what kind of a convention?I mean, clearly, as we've already talked about, the more countries that are signed up to working together and cooperating, the stronger this is, um, the fact that we have Australia, Morocco and also Brazil are looking at it now is very promising. There's obviously still many other parts of the world as well to cover. So I think I think this is a very important platform to be building from.
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Speaker 5
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Speaker 5
Uh. Yes, absolutely. I'm sure the Council of Europe would be happy for us to sign up to it. But but you're right. This is this is not saying this is going to solve all the problems, but it's certainly a very positive start. Um, I personally don't know whether if it had been a UN convention, it would have been more likely to sign up or not.
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Speaker 9
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Speaker 9
Yes. Thank you very much. Apologies. I'm travelling at the moment so I wasn't able to join you. But I greatly appreciate you both coming. Giving evidence to the committee. Um, I have sort of two questions which follow on from the theme that we've been discussing around enforcement and how the market has changed. Um, prediction markets and markets are now enormous markets, not so much in the UK, but to some extent here. But of course around the world.
And that makes it harder to track in terms of illegal gaming or betting, because it's not through the single points of reference, which could be the gaming industry. Maybe you could talk a bit about how we're dealing with that new threat, an ever growing threat. And the second part, which is, I think, really an important strand that's come through in this discussion and previous discussions, which is we can sign as many treaties as we like, but unless we have proper enforcement in the UK, it's not going to make a great deal of difference.
And I haven't really managed to get a handle on how much we're investing in enforcement, in enforcement, and how much resources we're dedicating to making sure that we can actually track these, um, international match fixing issues.
And that makes it harder to track in terms of illegal gaming or betting, because it's not through the single points of reference, which could be the gaming industry. Maybe you could talk a bit about how we're dealing with that new threat, an ever growing threat. And the second part, which is, I think, really an important strand that's come through in this discussion and previous discussions, which is we can sign as many treaties as we like, but unless we have proper enforcement in the UK, it's not going to make a great deal of difference.
And I haven't really managed to get a handle on how much we're investing in enforcement, in enforcement, and how much resources we're dedicating to making sure that we can actually track these, um, international match fixing issues.
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Speaker 5
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Speaker 5
Thank you. Um, so as I'm sure, you know, in order to sort of offer a product in the UK, you need to have a licence issued here. And if people aren't don't have that, then they're operating illegally. But clearly there will be people out there testing that. Perhaps, you know, the gambling commission are I'm sure they will have talked about this themselves. You know, they are very alive to how markets are evolving, products are evolving, and the pace of change and working with colleagues across the world and within the country to try and keep abreast of those threats and trying to work out the best ways to target them at different points as you learn them.
So it's not enough to just block a website. You have to look at other ways of tackling people's ability to acquire customers, um, their ability to advertise, their ability to receive payments. So the sort of financial system in the UK is very supportive around how we try and block those such things happening. Um, ability to maintain UK facing relationships. Um, perhaps on your point about um sort of enforcement on that side of things. So the gambling commission, uh, there's a range of measures, not just sort of prosecution.
So they offer cease and desist disruption notices, 3140 of those done in the last year. We've got data for about 450 000 URLs referred to Google and Bing, um to be investigated, which 65% then went on to be removed. So there is a lot of activity happening there. Uh, the national governing bodies also have taken, you know, got a lot of examples of banning people from sports either for short term or long term. There's probably not so many prosecution cases. Some of that is because of the complexity of meeting the high threshold.
Uh, with that and as you rightly say, as, as people continue to get more sophisticated, that will continue to be a challenge. And why actually enforcement agencies and all bodies working together to try and tackle this is really, really important to have that intelligence gathering, prevention, information sharing as well.
So it's not enough to just block a website. You have to look at other ways of tackling people's ability to acquire customers, um, their ability to advertise, their ability to receive payments. So the sort of financial system in the UK is very supportive around how we try and block those such things happening. Um, ability to maintain UK facing relationships. Um, perhaps on your point about um sort of enforcement on that side of things. So the gambling commission, uh, there's a range of measures, not just sort of prosecution.
So they offer cease and desist disruption notices, 3140 of those done in the last year. We've got data for about 450 000 URLs referred to Google and Bing, um to be investigated, which 65% then went on to be removed. So there is a lot of activity happening there. Uh, the national governing bodies also have taken, you know, got a lot of examples of banning people from sports either for short term or long term. There's probably not so many prosecution cases. Some of that is because of the complexity of meeting the high threshold.
Uh, with that and as you rightly say, as, as people continue to get more sophisticated, that will continue to be a challenge. And why actually enforcement agencies and all bodies working together to try and tackle this is really, really important to have that intelligence gathering, prevention, information sharing as well.
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14:48
Speaker 2
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Speaker 2
Your colleague, the only thing I'd also add to that in terms of your specific question in relation to, to funding is that, uh, we are providing additional funding to the Gambling Commission as part of the Illegal Gambling Task Force to address these kind of issues. So we're providing an additional 26 million in funding to the to the commission to support this, this very work. And we have very active and live conversations with the Commission about resourcing and any pressures they feel in this space to to manage that.
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Speaker 6
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Speaker 6
I just want to be clear about this, because it seems to me that there's something of a false alternation here, because there is nothing stopping us joining a UN convention. If one day all the countries in the world wished to have a convention to deal with this international problem, we could join that just as at the same time as being in Marceline. So they're not an either or. And if we had expressed a overriding preference for the UN one, we'd probably end up for a very long time with nothing at all.
14:49
Speaker 5
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Speaker 5
I think that's a very fair comment. And more people involved. The more complexity, the harder it is to kind of get over the line, isn't it?And you're absolutely right, by signing up to this, it doesn't exclude us from being able to do anything different. If there's opportunities elsewhere, I completely agree.
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14:49
Speaker 8
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Speaker 8
I mean, I have to look at the figures and the government has announced a 25% increase to annual operator licence fees to help the Gambling Commission. The commission is drawing on 26 million in extra Treasury funding over three years. Again specifically to scale up operations against unlicensed black market operators. But and I wonder if this isn't where the problem is, despite all of that, despite the fee increases, the regulator still has an estimated £4 million annual deficit and needs to find at least 8 million in efficiency savings.
Now, I've been around a bit, and when I hear the word efficiency savings, that tends to mean cuts. So is it not actually the reality that part of the problem in relation to ratification is that there's going to have to be found more money from somewhere, actually to, to. Pay for enforcement. Because without enforcement, as all the evidence shows, uh, ratification isn't worth literally the paper it's printed on.
Now, I've been around a bit, and when I hear the word efficiency savings, that tends to mean cuts. So is it not actually the reality that part of the problem in relation to ratification is that there's going to have to be found more money from somewhere, actually to, to. Pay for enforcement. Because without enforcement, as all the evidence shows, uh, ratification isn't worth literally the paper it's printed on.
14:50
Speaker 5
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Speaker 5
Well, I mean, as I said earlier, it it's not just about enforcement. It's also about that sort of prevention, intelligence gathering, info sharing. So I think there are more tools in the framework than just the sort of enforcement side of things. So so your figures are correct about the Gambling Commission, and they do have that, um, challenge about, you know, what they forecast they might need versus what, what, um, what.
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Speaker 5
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Speaker 5
What, what the, yes, what the consultation sort of led to, um, being able to sort of justify giving them in the end. So they are currently working through exactly how they're going to live within their budget. Um, and sort of kind of for the gambling commission to sort of answer on that. But I sort of take your point that, that there's only ever going to be a finite amount of money. And therefore there is something about what are your sort of priorities for your regulator to, to, to focus on that we'll need to work through with them.
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Speaker 11
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Speaker 11
Thank you, Lord chair. I have a rather technical question to finish with. Um, in your written evidence, you confirm that all amendments will be subject to ratification and therefore to scrutiny under crack. But you also say that if there is provision for amendments elsewhere in the treaty, the position may be different. So my question is, are there provisions for amendments elsewhere in the treaty?And if so, what is the position on scrutiny in relation to these?
14:55
Speaker 5
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Speaker 5
Um, apologies. Our response there was not as clear as it could have been. So just to clarify, article 38 is the sole mechanism in the treaty for amendments. There are no provisions anywhere else in the convention which relate to its amendment, and therefore anything through article 38 amendments would require parliamentary scrutiny via a process before ratification. So apologies, we weren't clear on that in our written evidence.
14:56
14:56
Speaker 1
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Speaker 1
We have just a little bit of time left. I would like to go back to something Lord German raised with the issue of Northern Ireland. And, uh, I do have a. Question for follow up. It's something. Perhaps you might like to go back to the department and consider and then respond to us so that we can see it, because I appreciate the sensitivity throughout all this, but we heard from the Gambling Commission that Northern Ireland's statutory offence of cheating could benefit from.
Review by the Northern Ireland Assembly to ensure it would sufficiently address the issue of cheating in gambling, as indeed required by the convention itself. So our question would be is the government aware of this issue?And if so, can they tell us what their overall view is?So we will provide that wording to you. But I appreciate you may have to go to other departments to let them consider the response as well.
Review by the Northern Ireland Assembly to ensure it would sufficiently address the issue of cheating in gambling, as indeed required by the convention itself. So our question would be is the government aware of this issue?And if so, can they tell us what their overall view is?So we will provide that wording to you. But I appreciate you may have to go to other departments to let them consider the response as well.
14:57
Speaker 5
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Speaker 5
Yes. Thank you. Might I say a few, few things here, because I have have been in contact with colleagues in Northern Ireland before coming to talk to you to make sure I was abreast of their latest situation. So it's quite you know, the Minister for Communities in Northern Ireland, you know, absolutely agrees that the legislation is out of date and needs reform, and that's a matter of public record that they have said that. What they have also said is that.
14:57
Speaker 7
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Speaker 7
Scrutiny of that under the current mandate that they have, that is their view. Um, their officials are continuing to sort of monitor and scope out the issues, um, to inform any future gambling legislation that might be brought forward in their sort of next. Um, and that they're working really hard on consumer protection within what they have today. So that's, that's their current position. Um, so perhaps I'll just leave it there for today.
14:58
Speaker 1
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Speaker 1
Thank you very much. And our clerk will be in touch with you with regard to that. I am aware in asking that question, of course, that there is a new Secretary of State for Northern Ireland, so it wouldn't have been proper to expect a full answer today. But on behalf of the Committee, thank you very much indeed for your contribution today. And we expect to be able to publish our inquiry by the autumn. I know governments use words like autumn being very extensive, but I think we're going to do it as soon as we can.
Thank you very much indeed. I hereby close this broadcast session.
Thank you very much indeed. I hereby close this broadcast session.