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Annual Report 2008 - 2009 - European Pari Mutuel Association

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					 Annual Report
  2008 - 2009


From Stockholm to Paris
2
                                                      Table of content

FOREWORD FROM THE CHAIRMAN............................................................................................... 4
1.          GAMBLING IS BACK ON THE EUROPEAN POLITICAL AGENDA .............................................. 5
     EUROPEAN WHITE PAPER ON SPORT – LINK MADE BETWEEN FUNDING AND SPORT ................................. 5
       Debate and vote in the European Parliament in May 2008 ................................................ 5
       Studies on the funding of sport............................................................................................ 6
     THE EUROPEAN COMMISSION HAS JUST LAUNCHED A CALL FOR TENDER MARKT/2009/04/E: "STUDY ON
     INTERNAL MARKET BARRIERS TO SPORT FUNDING" ........................................................................... 6
     EP OWN-INITIATIVE REPORT ON THE INTEGRITY OF ONLINE GAMBLING .................................................. 7
       Debate and consultation from September 2008 to March 2009......................................... 7
       Alternative report and vote in plenary ................................................................................ 8
     COUNCIL WORKING GROUP ON GAMBLING AND BETTING ................................................................... 8
       French Presidency meetings from September to December 2008....................................... 8
       Progress Report validated by Competitive Ministers on 1st December ............................... 9
2.          EPMA INCREASED VISIBILITY AND INTENSE ACTIVITY........................................................ 11
     WHITE PAPER ON SUSTAINABLE FUNDING OF THE EUROPEAN HORSERACING SECTOR THROUGH PARI MUTUEL
     BETTING ................................................................................................................................... 11
       The work of the editing committee – summer 2008 ......................................................... 11
       Final version published beginning of October ................................................................... 11
     EPMA CONFERENCE – THE PARI MUTUEL MODEL FOR THE FUNDING OF RACING AND SPORT.................. 13
       The objectives and the Preparation from the end of September 2008 ............................. 13
       The speakers, the event, the follow-up.............................................................................. 13
3.          LIFE OF THE ASSOCIATION ............................................................................................... 15
     BOARD MEETINGS ...................................................................................................................... 15
     EXCHANGE OF BEST PRACTICES AND NETWORKING ........................................................................... 16
       Meetings and presentation of EPMA................................................................................. 16
       Conference attendance ...................................................................................................... 17
     LAUNCH EPMA WORKING GROUPS.............................................................................................. 17
       Communication Working Group ........................................................................................ 17
       IT/Technology Working Group........................................................................................... 18
     MARKETING GROUP – TOWARDS A NEW STRATEGY CONFIRMED BY THE COMMINGLING ROUND TABLE – 3RD
     OCTOBER 2008......................................................................................................................... 19
       Objectives........................................................................................................................... 19
       Summary of Findings ......................................................................................................... 19
ANNEXES.................................................................................................................................... 21
     1 – EPMA MEMBERS – 2008 FIGURES.................................................................................... 21
     2 - EPMA POSITION ON THE EUROPEAN PARLIAMENT BRIEFING ON ONLINE GAMBLING. .......................... 33
     3 - POSITION OF 3 EUROPEAN ASSOCIATIONS ON SCHALDEMOSE REPORT .............................................. 35
     4- PRESS RELEASES ..................................................................................................................... 36
     5 - PRESS ARTICLES ON EPMA CONFERENCE – JANUARY 2009 ........................................................... 38




                                                                                                                                                 3
                                      Foreword from the Chairman


                                      After setting the foundations in 2007, we have
                                      considerably increased our visibility in 2008 through
                                      two major events, the publishing of the White Paper
                                      and the organisation of EPMA Conference in
                                      Brussels.

                                     The White Paper was the occasion to describe the
                                     benefits of the Pari Mutuel model and point out the
key figures of our market and the recommendations of our members. Such document
released at the autumn, was well timed to contribute to the Parliament and Member States’
discussions on gambling. Our messages were further emphasized during EPMA conference
organised on 22 January, a real success in the number of participants and the quality of
speakers.

To achieve this, the Board members have worked continuously throughout the year. Many
meetings were organised with European decision makers to present and comment our White
Paper. We have not only been heard, we have been understood as the latest political papers
adopted by the European Parliament, the Schaldemose report and the Council of Ministers,
progress report on gambling, were granting the right to the Member States to regulate and
control their gambling markets in accordance with their traditions and cultures and
recognizing that profits from gambling should be used for the benefit of society, including
funding for education, health, professional and amateur sport and culture.

Although non legislative, such political documents are a sign for the Member States to
continue their common discussion on the subject (during the Swedish Presidency from July
2009).

In 2009, the economic and financial crisis starts to impact our sector in many ways and
EPMA provides a forum to develop our business and strengthen our market position. The
Association has also been created to exchange best practices through the working groups
activities and following the success of the Commingling Round table.

With the importance of European issues ahead of us, EPMA is more than ever, a valuable
tool to vehicle our messages and develop our common strategy.


Bertrand Bélinguier
EPMA Chairman




                                                                                         4
   1. Gambling is back on the European political agenda
Since May 2008, the debate on gaming and gambling at EU level moved from the legal side
to the political side: the European Commission has “frozen” the infringement cases and did
not bring any Member States before the Court during the infringement the period.

The Member States represented inside the Council working groups, have decided to launch
a common discussion on the gaming and gambling issue: meetings were organised in
September and October 2008 in order to validate a progress report presented to the
Ministers at the end of 2008.

The European Parliament after having amended the White Paper on Sport before the
summer 2008 approved the idea of an initiative report on online gambling in September. Mrs
Christel Schaldemose, a Danish Member of the European Parliament, as the rapporteur for
the Socialist Party on this issue, wrote a document adopted on 10th March 2009.


European White Paper on Sport – link made between funding and sport


       Debate and vote in the European Parliament in May 2008


Many historic operators such as the European Lotteries and EPMA, took the occasion of the
debate on the White Paper on sport to put forward two important issues linking gambling to
sport, integrity of competition and funding.

The European Parliament voted the White Paper on Sport on 8th May and many
amendments reflected the messages of historic operators:

   •   voices its concern at a possible deregulation of the market in gambling;
   •   considers it appropriate to use the profits derived from gambling operators and
       lotteries for purposes that are in the public interest, including the continuing financing
       for professional and amateur sport;
   •   calls on the Commission to carry out a study of the potential effects on society and
       sport of full deregulation of the market in gambling and lotteries, and of what types of
       control mechanisms could be used to protect consumers;
   •   asks the Commission to come forward with a proposal ensuring a clean sports betting
       sector in the Union, preventing misuse and corruption and respecting the sporting
       event organisers' rights; and asks the Commission and the Member States to explore
       with sports and betting operators the creation of a workable, equitable and
       sustainable framework to ensure that all sports in the European Union remain free
       from illegal betting practices and that public confidence in their integrity is retained;

The debate was the occasion for EPMA to approach Members of the Parliament to increase
their awareness on the uncontrolled introduction of gambling competition on horseracing.
Without any prior assessment or agreement of a sustainable and fair alternative to current
structures, the development of gambling would have a disastrous impact on horseracing
throughout Europe. EPMA reminded that these messages echoed the Common Motion of
European Horseracing Organisations which was presented during a conference at the


                                                                                               5
European Parliament in March 2008. This called for the European Parliament, the Council
and the Commission, to recognise urgently the need for a clear and coherent legal and
regulatory framework, guaranteeing a fair return from betting to the racing on which it is
promoted or offered, and the protection of the future integrity of the sport, whilst, at the same
time, taking into account the different systems of horserace betting operating in different
member states.
In line with the European White Paper on sport, the European Commission has just launched
a European wide study to understand the financing of sport.


       Studies on the funding of sport

Within the preparation of the French Presidency of the EU, a survey was conducted between
May and July 2008 among the Member States ministries in charge of sport to have a clear
picture of the funding of sport in Europe.
The results were presented to the European Ministers of sport in November 2008:




 The European Commission has just launched a call for tender
 MARKT/2009/04/E: "Study on Internal Market Barriers to Sport Funding"
 As a contribution to the reflection on the financing of sport, the Commission is
 launching an independent study on the financing of grassroots sport and sport
 for all in the Member States from both public and private sources, and on the
 impact of ongoing changes in that area.
 The Commission has launched an invitation to tender for this study, which will
 look into public and private sources of sport funding and into financial streams
 within particular sports. It will also address possible cross-border obstacles that
 could affect the financing of sport.
 Deadline for the receipt of tenders: 30 April 2009.
 Results should be available in June 2010




                                                                                               6
EP own-initiative report on the integrity of online gambling


         Debate and consultation from September 2008 to
         March 2009


In September 2008, the European Parliament nominated Mrs Schaldemose, a Danish
member, to conduct a report on the integrity of online gambling. From October, all
stakeholders in the sector were auditioned. EPMA was consulted and our White Paper
distributed to all relevant Members of the Parliament (MEPs).

A short study was conducted by Europe Economics (a London based consultancy firm)
on the online betting market following the terms of reference submitted by the Parliament
and the answers of gambling stakeholders to the following questionnaire:
1 - Is a "code of conduct" for licensed gambling operators an adequate measure to ensure the integrity of
operators? If yes, how (and by whom) could it be designed and effectively enforced? What consumer
detriment can be quantified and how can this best be tackled?
2 - Which (other) policy options are available to ensure the integrity of online gambling operators?

EPMA position on the questions submitted was sent to all the relevant Members of the
Parliament (see the position paper in annex 2).

The Briefing note was presented by Europe Economics on 5th November and was criticized
by many Members of the Parliament (MEP).

From the beginning, Mrs Schaldemose was not in favour of a code of conduct and was
looking for further study on players’ addiction in order to evaluate what specific rules were
needed to protect consumers. 149 amendments have been tabled in December to Mrs
Schaldemose report - many of them from more "liberal" MEPs to delete the word
“subsidiarity” inside the report or to delete the fact that "online gambling combines several
risk factors" - others have been tabled by Mrs Korhola and co-signed by Mr Toubon and by
Mrs Schaldemose in order to:

    •    Emphasise the concerns related to online gambling such as "lay bets"
    •    Emphasise that a pure Internal Market approach is not appropriate in this highly
         sensitive area and leaving at a national level the competence to rule on the number of
         license to be granted, the type of games allowed as well as the competence to collect
         taxes based on the country of consumption principle;
    •    Note that criminal activities such as money-laundering and black economies can be
         associated with gambling activities, and impact on the integrity of sports events; and
         that the threat to the integrity of sport and sporting competitions impacts heavily on
         grassroots participation, a key contributor to public health and social integration; and
         could result in a loss of public trust if a sport is perceived as the subject of
         manipulation for the financial gain of players, officials or third parties rather than
         played according to its values, rules and for the enjoyment of its fans
    •    Call on the Member States to ensure that sports competition organisers, betting
         operators and the appropriate regulators cooperate on measures to tackle the risks
         related to illegal betting behaviour and match-fixing in sport, and explore the
         establishment of a workable, equitable and sustainable regulatory framework for the
         financing of measures to protect the integrity of sports and ensure fair financial
         returns to the benefit of all levels of professional and amateur sport;
    •    Recommend that Member States protect sports competition organisers from any
         unauthorised commercial use of their competitions by a legal "competition organisers

                                                                                                            7
       right", notably requiring betting operators to reach agreement with competition
       organisers before taking bets on their competitions;

Those amendments were all adopted first inside the Internal Market Committee on 11
February 2009. 42 Members of the Parliament were present during the votes and the
majority (32 against 10) voted in favour of Mrs Schaldemose report.

However, a minority/alternative report was announced by Mr Harbour and other members of
the Parliament (UK and German members) in order to reflect the internal market principles of
cross-border services.


       Alternative report and vote in plenary

Just before adopting the report, Mrs Schaldemose was invited to EPMA Conference to tell us
about the “adventure” of the gambling report.

Despite the opposition of some MEPs and the attempt to submit an alternative report, Mrs
Schaldemose’s report was voted on the 10th March with a high majority of 544 votes in favour
and 36 against.
EPMA was active in its support of the document (see the position sent before the vote in
annex 2) as it confirms our line of action:
    • Member States have the right to regulate and control their gambling markets in
        accordance with their traditions and cultures,
    • Online operators must comply with the legislation of the Member State in which
        they provide their services and the consumer resides,
    • Self regulation from the industry is not sufficient. Self regulation/code of conduct
        can complement legislation but not replace it,
    • Profits from gambling should be used for the benefit of society, including rolling
        funding for education, health, professional and amateur sport and culture;
Although non legislative, such political document is a sign for the Member States to continue
their common discussion on the subject (during the Swedish Presidency from July 2009) - it
is also a political way to ask the European Commission to change its strategy and look at the
subject in a different way.
EPMA has fully participated to the debate and has invited the rapporteur to its Conference
last January. Members of the Parliament have shown great interest in the subject and have
increased their knowledge.


Council Working Group on gambling and betting

       French Presidency meetings from September to December 2008

From July, 2, Member States have agreed to discuss the gambling issue on the initiative of
the French Presidency (July to December 2008). In that context, the Presidency sent the
delegations a questionnaire on the rules and policies applied in each Member State. The
questionnaire (25 questions) dealt with the general organisation of the sector, the
cross-border aspects of gambling, and policy objectives and instruments. The discussions on
the basis of that questionnaire benefited from the delegations' very substantial contributions
(2 days meeting in September and a meeting in October were organised in 2008).




                                                                                            8
The Presidency's intention was for the discussions during its term in office to be without any
preconceived idea as to the outcome. They were conducted in a horizontal working party
specialising in matters relating to the internal market in services.

A Presidency report to inform the Council of the outcome of the discussions and to suggest
options for further proceedings was presented on 1st December.


       Progress Report validated by Competitive Ministers on 1st December

A progress report was validated by Ministers on 1st December and the document was very
clear regarding our sector:
“Gambling is an industry with major economic and social implications: whatever the exact
form of organisation used, another major similarity between almost all Member States is the
importance of the sector in funding certain activities in light of the general interest objectives
involved...gambling and betting very frequently contribute substantial amounts, totalling
billions of euros annually EU-wide, to numerous causes: social, charitable or cultural
activities, support for sport or equine organisations”.

The document also considers that there are grounds for seeking common approaches in
certain areas, such as the protection of minors, controls on the size of amounts bet and
transactions and advertising or even combating money laundering. They could in due course
lead to discussion of the usefulness of policy tools, be that legislative or non legislative
instruments.

Here again, the report calls for the Commission to conduct detailed studies and
consultations and possibly in due course make proposals to identify ways forward.

The Competitiveness Council on the 1st December:

          Took note of this progress report;
          Instructed to continue discussions on these issues.




         Each EU Presidency priorities are based on a common work programme initiated by 3 countries. For
       2008 and 2009, French, Slovenian and Swedish governments have a common programme to implement.




The Member States will probably continue to meet on this issue from July 2009.




                                                                                                       9
Reminder of the EU political agenda for 2009:
→      7 May - The European Parliament will shut down to campaign.
→      4-7 June - The election week all over the EU.
→      July/August – Names of new Commissioner and President will circulate.
→      July – Swedish Presidency starts.
→      September/October – Audition of new Commissionners by the European Parliament
→      1st November – New Commission starts working




                                                                                  10
      2. EPMA increased visibility and intense activity

       White Paper on sustainable funding of the European horseracing sector
       through Pari Mutuel betting


The objective was to write a reference document to spread EPMA messages and continue to
position the Association on the legal and economic scene of the gambling sector. EPMA
wanted to provide an overall understanding of the importance of the horseracing sector in
Europe, the way it operates through betting funding and demonstrate how Pari Mutuel has
become the most appropriate partner of the industry.



        The work of the editing committee – summer 2008

Summer was dedicated to the “making of” the White Paper. An editing committee was
nominated in June by the Board members. The framework of the document was validated
and many members of the Association have contributed.


        Final version published beginning of October

The publication of the White Paper was well timed during the autumn 2008 to back our
contacts with the European decision makers.


                                           White Paper European Key figures
  •    The document is easy to
       read, contains key figures
                                           € 30 billion for the total betting activity on
       and clear demonstrations.           horseracing:
                                           € 14 billion collected by EPMA Members:
  •    A   2    pages   Executive                 € 11 billion returned to the winning
       summary was translated in                  bettors
       French, German and Italian.                € 1.5 billion returned to the horse sector

  •    A press release was sent to         20 million bettors
       the press contacts all over
       EU.                                 100 000 horse owners
  •    The document was translated         40 000 breeders
       in 3 languages with the help
       of the members and widely
       disseminated.
                                           200 000 people directly employed

                                           500 racecourses

                                           80 000 horse races

                                           110 000 different racehorses involved


                                                                                       11
Contribution from EPMA’s members in 2007(from the White Paper)



        PARI MUTUEL        BETTING TURNOVER         RETURN TO HORSE
         OPERATOR                                       SECTOR
                                  € Million               € Million
     EPMA MEMBERS


  PMU                              8 842                   727.2

  UNIRE                            2 667                    395

  ATG                              1 284                    149

  NORSK RIKSTOTO                    395                      64

  FINTOTO                           209                     32.5

  UK TOTE                           484                     24.8

  TOTE IRELAND                       61                     10.6

  GERMAN TOTE + TRS                  85                      8.4

  LOTERIE ROMANDE                    73                      2*

  WIENER TRAB                       0.6                     0.12

  TOTAL                           14 100.6                1413.6**
 *In addition, more that €5 million are distributed to good causes through
 local non-profit associations (promotion of research, environment,
 associations to help youth, provide services for elderly and handicapped
 persons...).
 **operating cost included for 5 members (UNIRE, TOTE Ireland, German
 TOTE, TRS and Wiener TRAB)




                                                                             12
       EPMA Conference – The Pari Mutuel model
       for the funding of racing and sport




        The objectives and the Preparation from the end of September 2008

Many options were evaluated by the Board members: Co-sponsorship of a global conference
on gambling with the risk to represent a small part of the content, an event focussing on
horseracing with the risk to attract few participants...
A clear position was adopted in September to set up the conference in Brussels on our own
focussing on the main benefits of the Pari Mutuel model. EPMA was helped by an adviser
with a good knowledge of the gambling market and the experience in organising
conferences.

A first outline of the day was presented in October stating clearly the objectives of the event:
European Pari Mutuel Association wants to demonstrate that Pari Mutuel system is fully
developed and perfectly adapted to horseracing and also to other sport competitions. EPMA
is inviting other Pari Mutuel operators with products on sport betting to demonstrate that they
are guided by the same objectives: long-term funding and integrity.
The day is therefore focussing on two major topics: Funding and integrity of sports. Both
should point out the benefits of the Pari Mutuel model. The morning is on funding (return to
racing, to sport and future policy regarding funding – at EU level, with elements from the
study on sport funding by EU Commission and at national level with presentations relating
the ongoing reforms in Member States). In the afternoon, speakers should point out the
attitude to observe to respect integrity (operators’ attitude, betting patterns, definition of
ethical betting).

3 key messages needed to be promoted through the speakers chosen:
    • Demonstrating that funding is essential for the sustainable development of racing and
       sport,
    • Insisting on strict regulation to be maintained at national level to take into account
       local specificities and coherent taxation,
    • Asking the European Union to strive for a high level of consumer protection and sport
       integrity.
300 invitations were sent at the end of November.

        The speakers, the event, the follow-up

EPMA Conference was a success:

   •    by the attendance – 100 participants
   •    by the quality of speakers – high level and interesting content
   •    in the visibility of the Association

It was an important event to relay the main messages of the Association and to point out our
contribution, with the White Paper to the European debate on gambling. The Pari Mutuel
model was fully described and explained and compared with the other betting model.
European Institutions and Member States were represented in the audience and they
commented the conference as particularly interesting.

                                                                                             13
Main statements of the day:

-   Gambling is back on the European political agenda
-   Convergence between the European Parliament and Member States to ask the
    Commission to change its strategy
-   2009 will probably develop the dialogue between Member States on how to tackle the
    issue in a coherent and efficient way although no new regulation is planned for the years
    to come.
-   Need for more knowledge on the gambling sector – probably economic studies launched
    in 2009/2010
-   Taxation is of course the core issue in the gambling battle between the Member States
-   A code of conduct for responsible gaming is not sufficient to protect the consumers at EU
    level

The event was commented by the specialised press (Sweden, Norway, France, UK, Italy)
(see the articles in annex 4)




                                                                                          14
   3. Life of the Association




       2008 General Assembly was organised in Stockholm hosted by ATG on 23rd April

       Board meetings

11 June 2008 – Dublin
The content and messages of the position paper of EPMA which became EPMA White paper
was the main item on the agenda:

   •    to educate and explain what Pari Mutuel is,
   •    Demonstrate the economic impact of breeding and racing in Europe and how it is
        funded,
   •    Describe the context situation and its uncertainty,
   •    Outline the future challenges,
   •    Position our strategy – respond to the funding needs of horseracing industry,
   •    Explain the benefits of common pool.

11 September 2008 – Paris
During that meeting, the outline of the conference was discussed:
   • Demonstrate the specificities of the sector in the global gambling arena,
   • Assess the economic impact of the system put in place for horseracing,
   • Clearly evaluate the possible link between Pari Mutuel and other sport betting issues
       to see if the model can be promoted by other European Sport Federations
       representatives (Rugby, tennis, football, Olympic Committee)
The date and the profile of speakers were validated:
   • October was too early as Sport Federations were not available to discuss during
       summer and Olympics competitions – January 2009 was more appropriate
   • Sport Federations were contacted and discussing internally the need to prohibit
       certain betting model and betting partners…so were willing to speak on the subject

26 November 2008 – Brussels
The setting up of the conference was presented and commented by the Board members:

                                                                                       15
   → Content defined without forgetting our primary objective and message
   → Strong interest and involvement from the European Parliament
   → Good timing regarding the adoption of important report at EU level and reforms at
      national level.
The choice of speakers was discussed and validated.

26 March 2009 - Brussels
Board members prepared the General Assembly meeting and exchange views on future
actions for the Association.


     Exchange of best practices and networking


     Meetings and presentation of EPMA

COPA/Horse Group/Horse Foundation – 26 June 2008


                     EPMA met the Chairman of the Horse Working Group inside COPA
(Agriculture lobby in Brussels). The group gathers participants from 18 countries eager to
defend horse breeding as an environmental and sustainable way to develop regional
activities. Camilla Linder, Swedish representative very active in the group, also participated
to the meeting as well as Elisabeth Backteman from the Horse Foundation in Sweden (The
Foundation as well as the Swedish government are preparing a European Horse
Conference).

Presentation of EPMA activities during the annual meeting of the European Small
racing countries – October 2008

Belgium politician and decision makers – 6 November 2008 – EPMA White Paper was
presented to the representative of the Belgian government in charge of the reform of the
national gambling legislation.

Belgium/Switzerland meeting hosted by EPMA – 1December 2008 – The Swiss
Horseracing Federation Chairman, Mr Jean-Pierre Kratzer welcomed his Belgian
counterparts and representatives of the Wallonie Region to present the PMU/Loterie
Romande agreement.

Tucson Racing Symposium – 10 December 2008 - EPMA was invited to present its
activities during the symposium. The Symposium annually attracts 1,000 attendees from
racing and breeding interests from across the United States and internationally. Topics to be
presented include trends of importance to the pari mutuel industry including simulcasting,
account wagering, marketing, new technologies and regulation.

European Parliament seminar on the future of gambling – 3rd March 2009 - EPMA was
invited to speak at a seminar organised by Maurio Mauro, Vice-President of the European
parliament and Lottomatica: "THE FUTURE OF GAMBLING IN EUROPE: COULD A
COMMON SOLUTION BE FOUND AT EU LEVEL?" in the European Parliament.
The event welcomed 50 participants for a discussion among institutions and stakeholders on
the perspectives for the European gambling sector and on what solutions could be applied
to regulate it at EU level.


                                                                                           16
       Conference attendance

Madrid Gambling Conference – July 2008 - EPMA attended the Gaming Executive
Summit in Madrid: New and historic gaming and gambling operators attended the 2 days
conference. The legal debate between Thibault Verbiest (lawyer of online operator) and
Philippe Vlaemminck, lawyer of European Lotteries) gave an update of legal and political
discussions at EU level. They both feel that mutual recognition will not apply in this sector
and States will adopt a local licensing system.

Zurich Sport integrity Conference - 10 November 2008 – EPMA attended the
conference organised by FIFA and met Sport Federations to gain their support to participate
to EPMA Conference.

EPMA was invited as observer to IFHA General Assembly in October 2008 and to
UET General Assembly – January 2009

EGBA Integrity and sport conference – 17 February 2009 - Around 150 participants
attended the EGBA’s ‘Responsible Gaming Day: “Integrity & Sport” event at the European
Parliament. All relevant sports stakeholders stressed the need for greater cooperation and
shared responsibility.
Responsible gaming debate - Knowledge regarding online gambling addiction is insufficient.
UK Gambling Commission announced the creation of an Independent Research Advisory
Board to launch further studies with the funding of RIGT (mandatory levy decided recently by
UK government).
Risks for sport integrity issues - European Commission Sport Head of Unit, Mr Michal Krejza,
recalled that sport is not a European policy although a White Paper was adopted in July 2007
to drive the European activities in this area. From this document, working groups and studies
will be launched, notably on the funding of sport (results available in June 2010). He
encouraged stakeholders to launch economic impact studies in order to provide the
Commission and other decision makers with key figures.
EGBA Chairman, Norbert Teufelberger, suggested the idea of funding and taxation as topics
to be discussed at the next Conference.


       Launch EPMA Working groups

       Communication Working Group

Main objectives of the group:
   • An overall objective: Improve internal (knowledge of EPMA inside members’
      companies) and external communication of the Association. This group is closely
      linked to the other WGs of the Association (particularly the Marketing Group).

   •  Exchange information and best practices on various subjects listed by the members:
           → the evolution of national press positions about our sector
           → List of national events (conferences and political declarations) - describe the
               event and report to the other members – coordinate our promotion activities to
               avoid conflicting messages
           → how to improve the information to various media
           → Joint communication on Responsible Gaming issues
    • Initiate and prepare EPMA’s events:

                                                                                          17
Members agree to work on the following priorities during the kick-off meeting in June 2008:
  • advices on format and dissemination tools of EPMA White Paper
  • Evaluate the motivation of sport Federations to participate to our conference (July +
     meeting on August, 28 to prepare the content)
  • Improve format/template and access to information in the context of commingling –
     contact EU media (Press and TV Channel)– Organise a joint Media/EPMA/IFHA
     meeting on 3rd October 2008 in Paris
  • Exchange on Responsible Gaming policy




                                                               Web site statistics – Our visitors
                                                               have increased from an average of
                                                               400 in April 2008 to an average of
                                                               1000 in March 2009




       IT/Technology Working Group

Ambitious objectives were set for the group:
  • Mutual understanding of members’ architecture and ongoing projects,
  • Evaluate all existing protocol - benefits and limits,
  • Explore the concept of an open standards gateway providing a range of services
       related to horse race betting,
  • Develop scenario around efficient connectivity and transactional issues that need to
       be solved/improved,
  • Influence the harmonisation of data exchange (racing rules) to facilitate the access
       and exchange of information,
  • The group to meet every 3 months.

2 meetings have been held since the inception of the group.




                                                                                        18
      Marketing Group – towards a new strategy confirmed by the Commingling
      Round Table – 3rd October 2008

In June 2008, the Marketing Group decided to change its strategy for the following reasons:
    • Euromillion model non transferable to the horseracing paradigm. Need to be an
       endemic product.
    • No room for 2 Super bets: European bet = Global Bet
    • But no 100% consensus on parameters nor clear market acceptance
    • Global betting experience slowed by technical, commercial and legal barriers (Global
       Trifecta)

The group initiated the Round Table on commingling with IFHA Tote Group.

        Objectives

The purpose of the Round Table was to describe the achievements in commingling, the
opportunities foreseen, its common barriers and prepare the next steps. EPMA and IFHA
coordinated the event, hosted by the PMU in Paris.

50 representatives from 21 countries represented a significant attendance and demonstrated
the interest for the development of International racing. The assistance gathered Pari Mutuel
operators, Racing authorities and media representatives. The opportunities of the session
were to improve the information in relation with international racing in the presence of Media
and for small and big size operators to exchange on technical and commercial constraints as
well as real opportunities. Bertrand Bélinguier as Chairman of EPMA and leading the IFHA
Tote Group, introduced the day by describing the previous progress. Although the
discussion on commingling started to emerge 8 years ago, it was only 2 years ago that
expertise was put together inside specific working groups in order to work on technical,
commercial and political matters facilitating mediation and common projects.




     Summary of Findings


Key factors to attract foreign punters:

→    Liquidity – larger dividends and steadier winnings
→    Variety of bet types, including the most exotic
→    Attraction of foreign race

Attractions of commingling:

→    Incremental profit for both guest and host (win-win)
→    Instrument against illegal betting
→    Tool for inter-tote cooperation
→    Promotion of (international) racing

Factors that hinder commingling:

→       Legal restrictions
→       Double taxation (tax levied by both host and guest nation)
→       Inter-tote connectivity (for some totes a big issue, for others less)


                                                                                           19
→       Scheduling and time zone differences
→       Rights holders issues
→       Currency conversions
→       Variation in bet rules (take out, types, refunds,..)
→       Non-harmonised racing rules (interference rules, medication, …)
→       Lack of data, knowledge and familiarity with foreign races

Internet is generally considered an ideal distribution channel for cross-border betting as it is 24/7 in all
time zones

Bettors need information, analysis and opinion for them to bet in sizeable numbers. Without
explanation and/or data, there is no market.

A second Round Table is under preparation for October 2009.




                                                                                                         20
Annexes
      1 – EPMA MEMBERS – 2008 FIGURES

AAMS - UNIRE
Sport statistics – 2008
Racecourses          Number of races              Number of starting horses         Person employed




                 Trotting   Gallop   Total       Trotting     Gallop   Total        Direct        Indirect
Trotto            13.684    4.620    18.304      135.525      39.124   174.649       NON            CIRCA
20                                                                               DISPONIBILE        50.000
Galoppo     12
+6


Betting Figures (in €)
  Pari Mutuel     % of overall               % on domestic races                 % on foreign races
betting turnover    national
                     betting


2.206.311.300         97,00 %                     89,15 %                             10,85 %

Bet types
         Rete ippodromi e agenzie                             % degli utili derivanti dalle scommesse
VINCENTE                                                                       27,68 %
PIAZZATO                                                                        26,99%
ACCOPPIATA                                                                      15,77%
TRIO                                                                            29,56%
          Rete ippica nazionale                               % degli utili derivanti dalle scommesse
VINCENTE                                                                        9,35%
ACCOPPIATA                                                                      8,33%
TRIS                                                                            71,26%
QUARTE’                                                                         7,45%
QUINTE’                                                                         3,61%


Taxes and Funding - 2008
                                                 Total in €                       % of turnover
To winning punters
                                               1.152.129.286                         71,75%
                                                367.770.292                          61.25%
Operating cost
                                                     -
To the horse industry
Ippica in agenzia e ippodromi                           193.791.498
Ippica nazionale                                117.023.923                          12.07%
                                                                                     19,49%
Ad altri (prego precisare se si
tratta di agenzie pubbliche,
ministeri, altre organizzazioni
sociali).
Ippica in agenzia e ippodromi                             71.004.838                               4,42%
     - Imposta                                  188.899.656                          11,76%



                                                                                                         21
   -   Agenzie e ippodromi   36.029.161     6%
                             40.038.882     8%
Ippica nazionale             12.284.346   2,05%
    - Imposta                19.339.418   3,22%

   -   Punti vendita

   -   AAMS

   -   Concessionari




                                                  22
ATG - AB Trav och Galopp
Sport statistics - 2008
  Number of           Number of races              Number of starting horses         People employed in the
 racecourses                                                                        horseracing and breeding
                                                                                             sector

                   Trotting   Gallop    Total     Trotting     Gallop    Total          Direct          Indirect
37 (32 trotting    9051       650       9 701     11 000       14 00     12 400    10 000               18 000
and           5
thoroughbred)

Betting figures - 2008
Pari Mutuel % of overall                % on domestic races                       % on foreign races
  betting        national
 turnover         betting
                               Separate pool       Common Pool          Separate pool            Common Pool

SEK 11 972        33%                              98,3%                                         1,7%
€ 1 246

Bet types
                        Bet name                                         % of betting income

V75                                                     35,6%

Daily Double                                            17,9%

Win/Show                                                13,6%

V64                                                     7,3%

V65                                                     9,8%

Quinella                                                6,6%


Trifecta                                                3%

V4                                                      2,5%


V5                                                      2,3%

Exacta                                                  0,7%

V3                                                      0,6%




Taxes and Funding – 2008

                                                 Amount in €                          % of turnover
To winning punters/customers           € 872,5                             70%
Operating fees                         € 74,78                             6%


                                                                                                                   23
To the horse racing industry       € 162,03   13 %
To others (please precise if       € 137,10   11%
Public Agency, Ministries, other
social organisation)




                                                     24
Fintoto Oy Finland
Sport statistics - 2008
  Number of           Number of races              Number of starting horses         People employed in the
 racecourses                                                                        horseracing and breeding
                                                                                             sector

                 Trotting   Gallop     Total      Trotting   Gallop    Total           Direct          Indirect
43               625        0          625        8651       0         8651         5.000              10.000
                 (6.377)               (6.377)

Betting figures
Pari Mutuel % of overall               % on domestic races                     % on foreign races
  betting       national
 turnover       betting
                                Separate pool      Common Pool        Separate pool             Common Pool

€       212,7   9,08 %          99 %               1%                 2%                        98 %
million

Bet types
                 Bet name                                              % of betting income
Win                                                      4%
Show                                                     3%
Quinella                                                 47 %
Trifecta                                                 16 %
Daily Double                                             6%
V4                                                       24 %
Does not include V5 and V75 pools totalling €            55,9 million in 2008 and organized by another
state company Veikkaus Oy.




Taxes and Funding – 2008

                                             Amount in € million                      % of turnover
To winning punters/customers         157,4                                 74,0 %
Operating fees                       14,2                                  6,7 %
To the horse racing industry         27,2                                  12,8 %
To others (please precise if         13,9                                  6,5 %
Public Agency, Ministries, other
social organisation)




                                                                                                                  25
Loterie Romande
Sport statistics - 2008
  Number of           Number of races             Number of starting horses        People employed in the
 racecourses                                                                      horseracing and breeding
                                                                                           sector

                 Trotting    Gallop    Total      Trotting     Gallop    Total          Direct       Indirect
                 197         217       414        297          398       695      1000               500

Betting figures – (in CHF)
Pari Mutuel % of overall               % on domestic races                       % on foreign races
  betting        national
 turnover        betting
                              Separate pool        Common Pool          Separate pool            Common Pool

114’552’441   100%            None                0.12%                 None                     99.88

Bet types
                   Bet name                                             % of betting income
Simple                                                  28.8%

Couplé                                                  24.6%

2 sur 4                                                 3.2%

Trio                                                    5.8%

Quadrio                                                 0.3%

Multi                                                   4.0%

Tiercé                                                  2.9%

Quarté+                                                 6.8%

Quinté+                                                 23.5%




Taxes and Funding – 2008

                                              Amount in CHF                          % of turnover
To winning punters/customers          85’325’782                           74.49%
Operating fees
To the horse racing industry          3’270’786                            12.75% (sales minus player
                                                                           winnings)
To others (please precise if          8’857’921                            35% for win > 50 Swiss francs
Public Agency, Ministries, other
social organisation)




                                                                                                                26
Norsk Rikstoto
Sport statistics - 2008
  Number of           Number of races          Number of starting horses          People employed in the
 racecourses                                                                     horseracing and breeding
                                                                                          sector

                 Trotting   Gallop     Total   Trotting   Gallop    Total           Direct         Indirect

12               4652       280        4932    5836       565       6401         750               5000

Betting figures – fiscal year 2008 – NOKx000
Pari Mutuel % of overall           % on domestic races                      % on foreign races
  betting       national                 86,6 %                                  13,4 %
 turnover       betting *
                             Separate pool    Common Pool          Separate pool             Common Pool
 NOKx000

3 710 061     13,7 %           95,3%           4,7%                2%                        98%
                                                          st
* Norway introduced a total ban for VLT’s from July 1 2007. Total estimated registered gaming
marked in Norway are down from NOK 32 billion in 2007 to NOK 27 billion in 2008.
Bet types – 2008
                  Bet name                                    % of betting income
V75                                               25,5 %
V65                                               11,9 %
DD (Daily Double)                                 8,7 %
V5                                                27,0 %
TRIO                                              11,6 %
WIN                                               6,5 %
PLACE                                             2,1 %
STRAIGHT FORECAST                                 3,3 %
V4                                                3,4 %

Redistribution/Contribution – 2008
                                           Amount - NOKX000                        % of turnover
To winning punters/customers         2 495 800
                                                                        67,2 %
To the horse racing industry         579 871                            15,7%
To others
Government(Fiscal fee)               137 272                            3,7%
Agents(Agents fee)                   202 092                            5,4%




                                                                                                              27
   PMU
   Sport statistics - 2008
 Number of           Number of races                    Number of starting horses         People employed in the
racecourses                                                                              horseracing and breeding
                                                                                                  sector

               Trotting     Gallop   Total       Trotting      Gallop       Total                  Direct
    248        10 984       6 854    17 838      150 071       75 891       225 962                69 000

   Betting figures (in € millions)
              Pari Mutuel       % of               % on domestic races                % on foreign races
                betting        overall
               turnover       national
                                              Separate        Common Pool      Separate        Common
                              betting
                                              pool                             pool            Pool
     PMU       9 261,8 m€       97,2%               -              99,2%            0,6%              0,2%
     PMH        202,8 m€         2,2%               -              100%               -                 -

   Bet types
                                      Bet name                % of PMU’s betting
                                                               turnover (handle)
                               QUINTÉ+                      22,15%
                               QUARTÉ+                      3,18%
                               TIERCÉ                       3,49%
                               QUADRIO                      0,45%
                               SIMPLE                       30,63%
                               COUPLE                       22,53%
                               TRIO                         5,34%
                               MULTI                        8,69%
                               2sur4                        3,54%



   Taxes and Funding – 2008

                                               Amount in € or national                % of Turnover
                                                      currency
   To winning punters/customers                      6 923,6 m€                            74,8%
   Net Operating fees*                                483,8 m€                              5,2%
   To the horse racing industry                       736,4 m€                             8,0%
   To others (please precise if                   State : 943,0 m€                         10,2%
   Public Agency, Ministries, other           Social duties : 153,2 m€                      1,7%
   social organizations)                     Foreign partners : 21,7 m€                     0,2%
   Total                                             9 261,8 m€                            100%
   * operating fee – other revenues




                                                                                                             28
Tote Ireland Limited
Sport statistics - 2008
  Number of           Number of races            Number of starting horses           People employed in the
 racecourses                                                                        horseracing and breeding
                                                                                             sector

                 Trotting   Gallop    Total     Trotting      Gallop    Total          Direct         Indirect
26                          2,454                             9,042                 16,000            9,000


Betting figures – (in €)
Pari Mutuel % of overall              % on domestic races                       % on foreign races
  betting       national
 turnover        betting
                             Separate pool       Common Pool           Separate pool            Common Pool

€55.06        1.2%           67%                 17%                   0%                       16%
Million


Bet types
                     Bet name                                           % of betting income
Win Pool                                               46.6%
Place Pool                                             25.8%
Exacta Pool                                            11.0%
Trio Pool                                              2.3%
Jackpot Pool                                           6.0%
Placepot Pool                                          8.3%




Taxes and Funding – 2008

                                                Amount in €                           % of turnover
To winning punters/customers         €46.33 Million                         84.0%
Operating fees                       €8.90 Million                          16.1%
To the horse racing industry         €0.55 Million                          1.0%
To others (please precise if         None
Public Agency, Ministries, other
social organisation)




                                                                                                                 29
UK TOTE
Sport statistics - 2008
  Number of           Number of races               Number of starting horses       People employed in the
 racecourses                                                                       horseracing and breeding
                                                                                            sector

                 Trotting    Gallop    Total       Trotting   Gallop    Total          Direct     Indirect
60               4           9,503     9,507       47         98,115    98,162

Betting figures – £ British Pounds (Sterling)
  Pari Mutuel       % of           % on domestic races                           % on foreign races
betting turnover   overall
                  national
                             Separate pool    Common Pool              Separate pool         Common Pool
                  betting
                         1
£375 million       0.45%       82.81%           15.38%              1.76%                0.05%
1
  Based on total national betting within the gambling industry in Great Britain of £84.2 billion in 2006/07
(Source: Report of the Gambling Commission 2007/08)
Bet types
                                                                                           2
                      Bet name                                       % of betting income
Win                                                  29.58 % (10.31 %)
Place                                                12.58 % (4.39 %)
Exacta                                               11.61 % (4.05 %)
Trifecta                                             30.03 % (10.47 %)
Jackpot                                              4.00 % (1.40 %)
Placepot                                             7.02 % (2.45 %)
Quadpot                                              0.72 % (0.25 %)
Scoop6                                               1.90 % (0.66 %)
Super7                                               0.15 % (0.05 %)
Swinger                                              2.40 % (0.84 %)
2
  The first figure shown is the percentage of all pool betting (so those total 100%). The second figure
shown is the percentage of all betting income (excluding FOBTs).

Taxes and Funding – 2008

                                       Amount £ British pounds sterling                % of turnover
To winning punters/customers          £ 291,562,880                        77.76 %
Operating fees
To the horse racing industry

 Sponsorship and Donations
                                       £m 4,450
 Payments to racecourses
                                       £m 6,855
 Betting Levy
                                       £m 9,204
Total                                  ______
figures extracted from the year        £m 20,609
ended 31 March 2008 financial
accounts




                                                                                                             30
WIENER TRABRENNVEREIN
Sport statistics - 2008
  Number of           Number of races           Number of starting horses       People employed in the
 racecourses                                                                   horseracing and breeding
                                                                                        sector

                 Trotting   Gallop   Total     Trotting    Gallop    Total          Direct       Indirect
                 873        74       947

Betting figures – (in €)
Pari Mutuel % of overall             % on domestic races                     % on foreign races
  betting       national
 turnover        betting
                             Separate pool      Common Pool         Separate pool            Common Pool

10,537.394                                      5,456.220                                    5,081.174

Bet types
                   Bet name                                         % of betting income
WIN                                                 22%
SHOW                                                6%
EXACTA                                              21%
TRIFECTA                                            44%
PIK 6                                               5%
PIK 3                                               2%




Taxes and Funding – 2008

                                        Amount in € or national                  % of turnover
                                             currency
To winning punters/customers                                           73%
Operating fees                                                         Technic 3,2%
To the horse racing industry                                           20%
To others (please precise if                                           3,8%
Public Agency, Ministries, other
social organisation)




                                                                                                            31
German Tote
Sport statistics - 2008
  Number of           Number of races            Number of starting horses    People employed in the
 racecourses                                                                 horseracing and breeding
                                                                                      sector

                 Trotting   Gallop     Total    Trotting   Gallop   Total       Direct     Indirect
      41                       1573     1573               2772                 6000           1000

Betting figures – (in € or national currency – please indicate)
 Pari Mutuel    % of overall         % on domestic races            % on foreign races
   betting         national
  turnover          betting
                                Separate pool   Common Pool Separate pool      Common Pool

63.970.865,05                                         61,25%                              38,75%
Gallop/GT

Bet types
                   Bet name                                         % of betting income
Win                                                                       15,00 %
Place                                                                      8,00 %
Exacta                                                                    16,00 %
Trifecta                                                                   54,5 %
Superfecta                                                                 5,00 %
Swinger                                                                    1,5 %




Taxes and Funding – 2008 on domestic turnover

                                         Amount in € or national               % of turnover
                                               currency
To winning punters/customers               29.392.378,50 €                       75,00%

Operating fees                                4.310.882,18 €                     11,00%
                                      TV/SciGames/Commission
To the horse racing industry                  5.224.005,41 €                     13,33%
                                      Racetracks/DVR
To others (please precise if                   262.571,91 €                       0,67%
Public Agency, Ministries, other      TAX
social organisation)




                                                                                                      32
       2 - EPMA position on the European Parliament Briefing on online gambling.




     Briefing Paper from Europe Economics to IMCO Committee (European Parliament)
                                         Consultation of EPMA
Reminder of the terms of reference:
Which policy options are available to ensure a reliable and transparent online gambling market, where public
interests and consumer interests are safeguarded?
1.    Is a "code of conduct" for licensed gambling operators an adequate measure to ensure the integrity of
operators? If yes, how (and by whom) could it be designed and effectively enforced? What consumer
detriment can be quantified and how can this best be tackled?
2.   Which (other) policy options are available to ensure the integrity of online gambling operators?
The briefing note shall draw on experiences from a representative selection of Member States, focusing on
effects of different regulatory models and possibly include best practises relating to consumer protection and
prevention of fraud.

We take integrity to mean a responsible attitude towards the minimisation of consumer detriment. Consumer
detriments that we see as relevant are fraud, money laundering, misleading advertising, addictive gambling
and access to gambling by “vulnerable” people.

Preliminary remarks from EPMA:

On the definition of Integrity:

Integrity of operators should be defined in a non restrictive way. Gambling operators have many
responsibilities in the economic sector in which they operate: a responsibility towards customers,
partners (sport and horseracing authorities) and society as a whole.

EPMA’s members take advantage of Pari Mutuel for the benefit of punters and the sport of
horseracing. Beyond national legal obligations, EPMA’s members are committed to maintaining a
balance between their economic objective and social responsibility and are therefore promoting
responsible gaming behaviour and the funding of racing.

Many newcomers on the market, on the contrary, have a tendency to exploit loopholes in legislation.
Furthermore, many online operators are not taking into account the economic responsibility and have
settled their activity where they could lower their cost and maximise their profit and dividends to
punters by minimising levies and paying no return to the sport. Taxation in Malta corresponds to 0.5%
of turnover compared to Sweden 11.4% and France 12.6%. This strategy enables them to propose
attractive (up to 95% in pay-out rate) betting offers on national markets for horseracing or other sports
which unfairly compete with historical ones and threaten the funding of the horseracing sector from
which it benefits.
Some operators maintain that they are eager to contribute to sport funding but in practice, they don’t
do it and none of them is ready to pay the level of contribution paid by EPMA members which is totally
incompatible with their current business model. Only a national regulation can ensure a fair return to
sport and horseracing industry.




EPMA position on the questions submitted:




                                                                                                                 33
     1- A Code of conduct is considered as an important tool for cross-border operators. It has to
        define all requirements in a transparent way applicable to all and address fraud, money
        laundering, misleading advertising, addictive gambling and access to gambling by “vulnerable”
        people and should also include taxation issues and sports organisers rights. However, many
        Members States have or are in the position to reform their national licensing system adapted
        to national requirements pointing out the social and economic attitude that all operators on the
        market must adopt. A code of conduct at EU level will not be sufficiently precise for Member
        States to approve it and to implement it.

          Member States are meeting this autumn to discuss a possible Paper of common interest, to
          be presented at the beginning of December 2008, only then, we will know if a set of common
          rules are possible in this sector.

          EPMA is pointing out that a Code of conduct cannot solve the issue of the fair return to the
          sport (European Horseracing authorities and sport federations are asking for the recognition of
          the fair return from betting on competitions on which it is promoted). Such attitude is an
          important part of the integrity that gambling operators have to demonstrate.

          Therefore, a Code of conduct will not in any case replace national gambling legislations in
          which each Member State is to define the betting model corresponding to public order,
          domestic taxes and funding priorities.


     2- Before looking for the best policy option, a thorough knowledge of the market is essential. Any
        policy option is to be based on significant economic data. European Pari Mutuel operators are
        asking for:

                         •    clear assessment of the impact of opening up of the market in Europe through
                              an independent impact study with a genuine debate on the social and
                              economic commitment of all gambling operators,
                         •    Build up indicators to follow the market evolution and learn from experience.

          Such assessment will help to define the efficiency of future policy but today, as numerous
          criteria, adapted to national requirements, have to be taken into account when controlling
          online operators, a strict national licensing system is the only possible option currently
          implemented.



The European Pari Mutuel Association brings together leading operators present in 10 countries. As historically experienced
actors in the gambling sector, they are entitled to submit their views and position on the development of the gambling sector.
As betting operators, Pari Mutuel organisations have a dual objective, offering the best entertainment value to
bettors in a fair and moderate way and serving the European horseracing industry in its long-term development. A
large majority of horseracing organisations have acknowledged the benefits of the Pari Mutuel model as the best
tool to preserve and develop their industry.
Members: AB Trav. Galopp (ATG), Sweden - Amministrazione Autonoma Dei Monopoli Di Stato (A.A.M.S.), Italy - Fintoto Oy,
Finland, German Tote GmbH, Germany - Société de la Loterie de la Suisse Romande Suisse - Foundation Norsk Rikstoto, Norway
- Pari Mutuel Urbain (P.M.U.), France - Horserace Totalisator Board, Great Britain - Tote Ireland Limited, Ireland - Trab Renn Sport
AG (TRS), Germany - Unione Nazionale Incremento Razze Equine (U.N.I.R.E.), Italy, Wiener Trabrennverein, Austria.



Brussels
15/10/2008




                                                                                                                                34
3 - Position of 3 European Associations on Schaldemose report




                                                                35
4- Press releases




                    36
37
5 - Press articles on EPMA conference – January 2009




                                                       38
39
     Square de Meeûs, 40
       B - 1000 Brussels
     Tel +32 2 401 61 65
contact@parimutuel-europe.org
  www.parimutuel-europe.org




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