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At the request of the Ministers of Justice and of Finance we investigated whether Holland Casino, the government monopolist casino operator, complied with government policy. The audit concentrated on marketing and promotion costs, the remuneration and allowances paid to directors, and measures to prevent gambling addiction and money laundering. We found that the structure and operation of Holland Casino's policies complied with applicable regulations and were consistent with the government's policy on gambling.
Holland Casino's revenue has fallen sharply since 2007. The
company wants to attract more visitors by broadening the casino
concept. The impact of the new strategy on Holland Casino's
responsibility to prevent gambling addiction may differ from one
target group to another and cannot be predicted in advance. It is
also uncertain where the line is between what is permitted under
European law and what is not. The ministers and state secretaries
concerned have agreed to the revitalisation of the casino concept.
Holland Casino is currently carrying out a more restrained
marketing policy than in the past. The marketing budget declined by
more than a third between 2005 and 2009. Marketing activities are
targeted at promoting the new casino concept. Holland Casino
operates in accordance with Dutch policy on gambling and with the
regulations and codes of conduct in place for marketing and
advertising. Management of the marketing budget is orderly and
auditable.
Management of the expense, travel and entertainment allowances
paid to the executive and supervisory directors of Holland Casino
is in order. On the whole, internal procedures are observed,
although compliance with a number of specific points could be
improved.
Holland Casino fulfils its responsibility to prevent gambling
addiction. In broad lines, the policy is carried out in accordance
with internal procedures. It is people work that is driven chiefly
by the staff's subjective opinions and intrinsic motivation.
People who are barred from entering Holland Casino's premises
may continue to visit slot machine halls because the law does not
yet allow people to be barred from them.
Holland Casino's policy to combat money laundering and the
financing of terrorism complies with statutory requirements.
Holland Casino has designed its procedures so that money that is
changed into gambling chips and then changed back again cannot be
passed off as winnings and therefore 'laundered'. Holland
Casino carries out its anti-money laundering policy in accordance
with its internal procedures. It is possible, however, to play with
'black' money at Holland Casino.
Since it is uncertain how far the casino concept can be
broadened under European law, we recommend that the State
Secretaries for Security and Justice and for Finance closely
monitor the implementation of the new strategy.
We recommend that the management of Holland Casino strengthen
internal control of compliance with the procedures in place for
expense claims and record departures from internal regulations more
clearly.
We recommend that the State Secretary for Security and Justice
consider creating an option to bar visitors from slot machine halls
in the forthcoming revision of the Betting and Gaming Act.
The State Secretary for Security and Justice responded to our
report on behalf of himself and the State Secretary for Finance. He
will willingly adopt our recommendation to create an option to bar
and restrict visitors to slot machine halls. A provision to this
end will be included in the forthcoming proposal to revise the
Betting and Gaming Act. According to the state secretary, the other
matters will be raised in the regular talks that he and the State
Secretary for Finance hold with Holland Casino. Holland Casino also
responded to our report and agreed with our conclusions. It
observed that our recommendations would lead to further
improvements in a number of internal procedures in 2011.