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Holland Casino: compliance with government policy

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.

 

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