Licensing

Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public APPLICATION FOR A NEW BINGO PREMISES LICENCE: ‘MERKUR SLOTS’, PART GROUND FLOOR, 62 STATION ROAD, HAYES, UB3 4DF Committee Licensing Sub-Committee Officer Contact Lois King, Principal Licensing Officer Papers with report  Appendix 1 – Application Form & Supporting Information  Appendix 2A – Representation from Christine O’Hara-Carnduff  Appendix 2B – Confirmation of date of receipt of Representation  Appendix 3 – Map showing Gambling Premises in Hayes Town  Appendix 4 – Relevant sections of Licence Conditions & Codes of Practice (LCCP)  Appendix 5 – Table of Categories of Gaming Machines Ward affected Hayes Town SUMMARY To consider representations in respect of a new bingo premises licence for the premises, ‘Merkur Slots’, part ground floor, 62 Station Road, Hayes, UB3 4DF . The application has attracted one representation from an interested party. RECOMMENDATION The Licensing Sub-Committee has the following options: 1. Grant the application for the premises licence subject to the mandatory conditions and default conditions (pursuant to sections 167 and 168 of the Act) or 2. Grant the application for the premises licence subject to the mandatory conditions but excluding specific default conditions and/ or attach additional conditions. 3. Reject the application. INFORMATION 1.1 An application for a new gambling (bingo) premises licence was received by the Licensing Service on 16 June 2025. The applicant is: Merkur Slots UK Limited Second Floor Matrix House North Fourth Street Milton Keynes MK9 1NJ A copy of the application form, the plans, their Local Area Risk Assessment, Form A Notice, Merkur Slots UK Limited’s Operational Standards document and Working Together document can be found at Appendix 1. 1.2 In accordance with the legislation, the application was sent to the responsible authorities: Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public  The Gambling Commission  The Metropolitan Police Service  H M Revenue & Customs  London Fire & Emergency Planning Authority  Child Protection Service, LBH  Environmental Health Authority, LBH  Planning Authority, LBH There were no representations received from the responsible authorities. 1.3 The application was advertised in accordance with the Gambling Act 2005 (Premises Licence and Provisional Statement) Regulations 2007 both on the premises and in the local newspaper. The 28-day consultation period started from the date the application was received. The application was also posted on the council’s website and in addition was sent to Ward Councillors. 1.4 Following the advertisement of the application, the following representations were received from Interested Parties:  Christine O’Hara-Carnduff, Local Resident – Appendix 2A 1.5 The period for consultation and the making of representations in respect of this application ended on 14 July 2025. 1.6 Although the date on the document in Appendix 2 A is given as 17 July 2025, it was confirmed by Riviane Araujo, Complaints and Enquiries Officer at the London Borough of Hillingdon, that the online submission was made on Sunday 13 July 2025 (Appendix 2B). The Council’s complaints team have five working days to claim and progress cases and in the case of Christine O’Hara-Carnduff’s representation, it was claimed and assigned on 17 July 2025. 1.7 The applicant has made a standard premises licence application for a bingo premises licence and is therefore applying for standard of times of operation for a bingo premises. 1.8 The applicant has an Operating Licence issued by the Gambling Commission. OFFICER'S OBSERVATIONS 2.1 This is an application for a new Bingo Gambling Premises Licence under Section 159 of the Gambling Act in respect of ‘Merkur Slots’ situated at part ground floor 62 Station Road, Hayes, UB3 4DF. The location is in Hayes Town centre, and the premises was previously a Barclays Bank. 2.2 A bingo premises licence allow s the holder of the licence to provide facilities for playing bingo on the licensed premises . Persons operating a bingo premises must hold a bingo operating licence from the Gambling Commission and must seek a premises licence from the licensing authority. 2.3 A bingo premises licence holder is entitled under the Act to make available for use a number of category B3 and B4 gaming machines not exceeding 20% of the total number of gaming machines which are available for use on the premises and any number of category C or D machines. The applicant’s legal representatives have stated that the machine plan included with the application ( Appendix 1 ) shows their clients intended Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public layout of the premises and the number and location of machines which their client expects to offer. It should be noted that t he machine plan is for illustrative purposes only , should not be attached to the bingo premises licence and is subject to change. The applicant’s legal representatives have stated that the number of machines offered will adhere to the permitted ratios as set out under the Gambling Act 2005 at all times. 2.4 The applicant has not specified the hours for trading in their application, but their legal representatives have confirmed that they are applying for the default hours u nder the Gambling Act 2005 which are to provide bingo facilities between 09:00 hours and midnight. There are no restrictions on access to gaming machines in bingo premises, even outside bingo operating hours. 2.5 Other Licensed Gambling Premises nearby (shown on a map appended as Appendix 3) Premises Address Type Operating times 1.Ladbrokes Boleyn Court 9 Botwell Lane Hayes UB3 2BL Betting Shop Mon-Sat: 07:30-22:00 Sun: 08:30-22:00 2.William Hill 2 Botwell Lane Hayes UB3 2AA Betting Shop Mon-Sat: 07:30-22:00 Sun: 08:00-22:00 3.Admiral 32-36 Station Road Hayes UB3 4DD Adult Gaming Centre 24 hours , 7 days a week 4.William Hill 57 Station Road Hayes UB3 4BA Betting Shop Mon-Fri: 07:30-22:00 Sat: 07:30-22:00 Sun: 09:00-22:00 5.Paddy Power 39 Station Road Hayes UB3 4BE Betting Shop Mon-Fri: 07:30-22:00 Sat: 07:00 – 22:00 Sun: 07:30-22:00 6.Jennings Bet 19b Station Road Hayes UB3 4BD Betting Shop Mon-Sat: 08:00-22:00 Sun: 09:00-22:00 7. Little Vegas Part of 14/16 Station Road Hayes UB3 4DA Adult Gaming Centre 24 hours, 7 days a week CODES OF PRACTICE 3.1 The Licence Conditions and Codes of Practice (LCCP) sets out the Gambling Commission’s general licence conditions and associated codes of practice provisions under the Act. The codes of practice are set out within the second part of the LCCP. Appendix 4 details the relevant Social Responsibility and Ordinary Codes relevant to bingo premises and access to gambling by children and young persons. Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public GUIDANCE ISSUED BY THE GAMBLING COMMISSION 4.1 The Gambling Commission has produced the ‘Guidance for Local Aut horities’ in relation to the 2005 Act. The information in this section of the report relates to the relevant points within the Guidance which members may wish to consider. Objective 1 – Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime. 4.2 At Paragraph 5.3 it states: “ Among other matters, licensing authorities may need to consider the location of premises in the context of this licensing objective. For example, in considering an application for a premises licence or permit that is in an area noted for particular problems with disorder, organised criminal activity etc, the licensing authority should think about what, if any, controls might be appropriate to prevent those pr emises being associated with or used to support crime. That might include conditions on the premises licence, such as a requirement for door supervisors. The requirement for conditions might be determined by the operator’s own risk assessment or the local area profile carried out by the licensing authority.” 4.3 At Paragraph 5.5 it states: “In the context of gambling premises licences, licensing authorities should generally consider disorder as activity that is more serious and disruptive than mere nuisance. Factors to consider in determining whether a disturbance was serious enough to constitute disorder would include whether police assistance was required and how threatening the behaviour was to those who could see or hear it. There is not a clear line between nuisance and disorder and the licensing authority should take the views of its lawyers before determining what action to take in circumstances in which disorder may be a factor.” 4.4 At Paragraph 5.8 it states: “In relation to preventing disorder, licensing authorities have the ability under s.169 of the Act to attach additional conditions to premises licences, and are entitled to include a requirement for door supervision, as provided for in s.178 of the Act.” 4.5 At Paragraph 5.10 it states: “Licensing authorities do not need to investigate the suitability of an applicant for a premises licence, including in relation to crime. The issue of suitability will already have been considered by the Commission, because any applicant (except occupiers of tracks who do not propose to offer gambling themselves) will have to hold an operating licence from the Commission before the premises licence can be issued. However, if the licensing authority receives information during the course of considering a premises licence application or at any other time, that causes it to question the suitability of the applicant to hold an operating licence, these concerns should be brought to the attention of the Commission without delay.” Objective 2 – Ensuring that gambling is conducted in a fair and open way. 4.6 At Paragraph 5.11 it states: “ Generally, the Commission would not expect licensing authorities to find themselves dealing with issues of fairness and openness frequently. Fairness and open ness are likely to be a matter for either the way specific gambling products are provided and therefore subject to the operating licence or will be in relation to the suitability and actions of an individual and therefore subject to the personal licence. However, if licensing authorities suspect that gambling is not being conducted in a fair and open way this should be brought to the attention of the Commission so that it can consider Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public the continuing suitability of the operator to hold an operating licence o r of an individual to hold a personal licence.” Objective 3 – Protecting children and other vulnerable persons from being harmed or exploited by gambling 4.7 At Paragraph 5.13 it states: “In exercising their powers under s.153, licensing authorities should consider whether staff will be able to adequately supervise the gambling premises, as adequate staffing levels is a factor to consider regarding the prevention of underage gambling. The Commission would expect the operator and the licensing authority to work together to consider how any impediments to the supervision of premises might be most appropriately remedied. Supervision also applies to premises that are themselves not age restricted (for example bingo and family entertainment centre (FEC) premises) but which make gambling products and facilities available.” 4.8 At Paragraph 5.17 it states: “The Act does not seek to prohibit particular groups of adults from gambling in the same way that it prohibits children. The Commission does not seek to define ‘vulnerable persons’ but it does, for regulatory purposes, assume that this group includes people who gamble more than they want to, people who gamb le beyond their means and people who may not be able to make informed or balanced decisions about gambling due to, for example, mental health, a learning disability or substance misuse relating to alcohol or drugs.” 4.9 At Paragraph 5.18 it states: “Licensing authorities need to consider, in relation to particular premises, whether any special considerations apply in relation to the protection of vulnerable persons. This could be a local risk that is reflected in the licensing authority’s policy statemen t. Any such considerations need to be balanced against the authority’s objective to aim to permit the use of premises for gambling.” Section 153 principles 4.10 At Paragraph 5.19 it states: “S.153 of the Act provides that, in exercising its functions under Part 8 of the Act, a licensing authority shall aim to permit the use of premises for gambling in so far as it thinks it is:  a. in accordance with any relevant code of practice under s.24 (the LCCP)  b. in accordance with any relevant guidance issued by the Commission under s.25 (this guidance)  c. reasonably consistent with the licensing objectives (subject to a and b above)  d. in accordance with the licensing aut hority’s statement of licensing policy (policy statement) (subject to a to c above).” 4.11 At Paragraph 5. 20 it states: “Whilst there is a presumption in favour of permitting the relevant premises to be used for gambling, the licensing authority may not do so unless satisfied that such use would be in accordance with this guidance, any relevant Commission code of practice, its own statement of licensing policy, and the licensing objectives.” 4.12 At Paragraph 5.22 it states: “In determining applications for premises licences, the Act explicitly sets out two principles that licensing authorities should not have regard to:  s.153 makes it clear that in deciding whether or not to grant a licence, a licensing authority must not have regard to the expected demand for gambling premises that are the subject of the application Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public  s.210 (1) of the Act states that ‘in making a decision in respect of an application...a licensing authority should not have regard to whether or not a proposal by the applicant is likely to be permitted in accordance with law relating to planning or building’.” Premises Licence conditions 4.13 At Paragraph 9.3 it states: “Conditions on premises licences should relate only to gambling, as considered appropriate in the light of the principles to be applied by licensing authorities under s.153. Accordingly, if the Commission’s Licence conditions and codes of practice (LCCP) or other legislation places particular responsibilities or restrictions on an employer or the operator of premises, it is not appropriate to impose the same through conditions on a premises licence.” 4.14 At Paragraph 9.25 it states: The following mandatory conditions apply t o all premises licences:  the summary of the premises licence issued by the licensing authority must be displayed in a prominent place on the premises. In England and Wales this must include a summary of the terms and conditions of the premises licence.  the layout of the premises must be maintained in accordance with the plan that forms part of the premises licence.  neither National Lottery products nor tickets in a private or customer lottery may be sold on the premises in England and Wales. Sale of Nationa l Lottery and private lottery tickets are prohibited in Scotland. 4.15 At Paragraph 9.27 it states: “s.169 of the Act gives licensing authorities:  the ability to exclude from premises licences any default conditions that have been imposed under s.168  the power to impose conditions on premises licences that they issue.” 4.16 At Paragraph 9.28 it states: “Licensing authorities should make decisions on conditions on a case-by-case basis, and in the context of the principles of s.153. They must aim to permit the use of premises for gambling and so should not attach conditions that limit their use except where it is necessary in accordance with the licensing objectives, the Commission’s codes of practice and this guidance, or their own statement of policy. Conversely, licensing authorities should not turn down applications for premises licences where relevant objections can be dealt with through the use of conditions.” 4.17 At Paragraph 9.29 it states: “Licensing authority statements of policy will need to consider the local circumstances which might give rise to the need for conditions. Where there are specific risks associated with a particular locality, the licensing authority might decide to attach conditions to the premises licence to mitigate those risks. For example, local issues associated with a high crime rate may put a premises at risk of not b eing consistent with the licensing objectives, and specific conditions may be necessary to address the risk.” 4.18 At Paragraph 9.30 it states: “Where there are risks associated with a specific premises or class or premises, the licensing authority may consider it necessary to attach conditions to the licence to address those risks, taking account of the local circumstances.” 4.19 At Paragraph 9.31 it states: “Conditions imposed by the licensing authority must be proportionate to the circumstances which they are seeking to address. In particular, licensing authorities should ensure that the premises licence conditions are: Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public  relevant to the need to make the proposed building suitable as a gambling facility  directly related to the premises (including the locality and any identified local risks) and the type of licence applied for  fairly and reasonably related to the scale and type of premises  reasonable in all other respects.” 4.20 At Paragraph 9.32 it states: “The Act sets out certain matters that may not be the subject of conditions:  s.169(4) prohibits a licensing authority from imposing a condition on a premises licence which makes it impossible to comply with an operating licence condition  s.172(10) provides that conditions may not relate to gaming machi ne categories, numbers, or method of operation  s.170 provides that membership of a club or body cannot be required by attaching a condition to a premises licence (the Act specifically removed the membership requirement for casino and bingo clubs and this p rovision prevents it being reinstated)  s.171 prevents a licensing authority imposing conditions in relation to stakes, fees, winnings or prizes.” Bingo 4.21 At Paragraph 18.1 it states: Bingo is not given a statutory definition in the Act although two types of bingo are commonly understood:  cash bingo, where the stakes paid make up the cash prizes that are won  prize bingo, where various forms of prizes are won, not directly related to the stakes paid. 4.22 At Paragraph 18.2 it states: The game and rules of bingo have evolved to the point where, despite the absence of any formal industry standard, the way in which bingo is played is broadly similar throughout Great Britain. Bingo is equal chance gaming. The Commission has published its view of what b ingo is and how it differs from other forms of gambling. This can be found in our guidance How bingo is defined (this advice does not form part of the Guidance to licensing authorities).This advice was developed with the support of key stakeholders from the bingo industry. 4.23 At Paragraph 18.3 it states: Cash bingo is the main type of bingo played in commercial bingo premises. They also offer prize b ingo, largely as games played in the intervals between main stage games. This means that only premises with a bingo premises licence, or a large casino premises licence issued under the Act (where the operator holds a bingo as well as a casino operating licence), will be able to offer bingo in all its forms. 4.24 At Paragraph 18.4 it states: As well as commercial bingo premises, bingo can be found in other gambling premises. Prize bingo is traditionally a game played in arcades, especially seaside amusement arcades, or at travelling funfairs. For these operators, prize bingo is subject to the allowances for prize gaming in the Act. This means that, subject to limits on participation fees and prizes, adult gaming centres, licensed and unlicensed family entertainment centres, and travelling fairs, (or any premises with a prize gaming permit) are able to offer prize gaming, which includes prize bingo. In this form of gaming, the nature of the prize must not be determined by reference to the number of people playing the game, and the nature or the size of the prize must not be determined by reference to the amount paid for or raised by the gaming. See Part 27 of this guidance for a fuller discussion of prize gaming. Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public 4.25 At Paragraph 18.5 it states: Licensing authorities need to satisfy themselves that bingo can be played in any bingo premises for which they issue a premises licence. An operator may choose to vary their licence to exclude a previously licensed area of that premises, and then apply for a new premises licence, or multiple new premises licences, with the aim of creating separate premises in that area. Essentially providing multiple licensed premises within a single building or site. Before issuing additional bingo premises licences, licensing authorities need to consider whether bingo can be played at each of those new premises. 4.26 At Paragraph 18.6 it s tates: Under the Act, children and young persons (anyone up to the age of 18) cannot be employed in providing any facilities for gambling on bingo premises, and children (under 16) cannot be employed, in any capacity, at a time when facilities for playing bingo are being offered. However, young persons, aged 16 and 17, may be employed in bingo premises (while bingo is being played), provided the activities on which they are employed are not connected with the gaming or gaming machines. Licensing authorities are able to find information about the restrictions that apply in Licence conditions and codes of practice (LCCP). 4.27 At Paragraph 18.7 it states: Children and young people are allowed into bingo premises; however, they are not permitted to participate in the bingo and if category B or C machines are made available for use these must be separated from areas where children and young people are allowed. Social Responsibility (SR) code 3.2.5 (3) states that ‘licensees must ensure that their policies and procedures take account of the structure and layout of their gambling premises’ in order to prevent underage gambling. 4.28 At Paragraph 18.8 it states: S.172(7), as amended, provides that the holder of a bingo premises licence may make available for use a number of category B gaming machines not exceeding 20 percent of the total number of gaming machines on the premises. For example, a premises with a total of 25 gaming machines available for use can make five or fewer category B3 gaming machines available on that p remises. Premises that were licensed before 13 July 2011 are entitled to make available eight category B gaming machines, or 20 percent of the total number of gaming machines, whichever is the greater. There are no restrictions on the number of category C or D machines that can be made available. Regulations state that category B machines at bingo premises are restricted to sub-category B3 (SI 2007/2158: Categories of Ga ming Machine Regulations 20070) (opens in new tab) (but not B3A) and B4 machines. Licensing authorities should ensure that gambling machines are made available for use in a manner consistent with our guidance within Part 16. For the purpose of calculating the category B machine entitlement in gambling premises, gaming machines should only be counted if they can be played simultaneously by different players without physical hindrance. This includes tablets. 4.29 At Paragraph 18.9 it states: The gaming machines must remain within the licensed area covered by the premises licence. In the unusual circumstance that an existing bingo premises covered by one premises licence applies to vary the licence and acquire additional bingo premises licences (so that the area that was the subject of a single licence will become divided between a number of separate licensed premises) it is not permissible for all of the gaming machines to which each of the licences brings an entitlement to be grouped together within one of the licensed premises. 4.30 At Paragraph 18.10 it states: Equipment operated by a bingo operating licence for the purpose of playing bingo, for example what are currently known as mechanised cash bingo, electronic bingo terminal (EBTs) and video bingo ter minals (VBTs), will be exempt from controls on gaming machines provided they comply with any conditions set by the Commission and, in the case of EBTs, do not hold gaming machine content. Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public 4.31 At Paragraph 18.11 it states: An EBT that offers gaming machin e content in addition to bingo content is considered to be a gaming machine and would count towards the total number of gaming machines or towards the offering of bingo. Any EBTs that do not offer gaming machine content would not count towards the number of gaming machines. 4.32 At Paragraph 18.12 it states: Social Responsibility Code Provision 3.5.6 requires that all non-remote casino (and bingo and betting licences except those at a track) and holders of gaming machine general operating licences for adult gaming centres must offer self - exclusion schemes to customers requesting such a facility. There is also an Ordinary Code provision at 3.5.7. The full details can be found within the LCCP. 4.33 Mandatory conditions At Paragraph 18.19 it states: A notice stating that no person under the age of 18 years is permitted to play bingo on the premises shall be displayed in a prominent place at every entrance to the premises. At Paragraph 18.20 it states: No customer shall be able to enter bingo premises directly from a casino, an adult gaming centre or betting premises (other than a track). At Paragraph 18.21 it states: Over 18 areas, within bingo halls that admit under -18s, must be separated by a barrier with prominently displayed noti ces stating that under-18s are not allowed in that area and with adequate supervision in place to ensure that children and young people are not able to access these areas or the category B or C machines. Supervision may be done either by placing the terminals within the line of sight of an official of the operator or via monitored CCTV. At Paragraph 18.22 it states: Any admission charges, the charges for playing bingo games and the rules of bingo must be displayed in a prominent position on the premises. Rules can be displayed on a sign, by making available leaflets or other written material containing the rules, or running an audio-visual guide to the rules prior to any bingo game being commenced. At Paragraph 18.23 it states: Any ATM made available for use on the premises shall be located in a place that requires any customer who wishes to use it to cease gambling i n order to do so. 4.34 Default conditions At Paragraph 18.24 it states: Bingo facilities in bingo premises may not be offered between the hours of midnight and 9am. However, there are no restrictions on access to gaming machines in bingo premises. Controlling where gaming machines may be played - bingo 4.35 At Paragraph 18.25 it states: The following policy objectives summarise the key elements that underpin the approach to controlling where gaming machines may be played:  with very few low-risk exceptions, non -remote gambling should be confined to dedicated gambling premises  the distinctions between different types of licensed gambling premises are maintained  gambling activities are supervised appropriately Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public  within casino, bingo and betting premises, gaming machines are only made available in combination with the named non -remote activity of the operating licence. 4.36 At Paragraph 18.26 it states: The Act and associated regulations set out a comprehensive regulatory framework for controlling gaming machines. By linking different machine entitlements to different types of premises, the framework seeks to ensure the number and power (in terms of stakes, prizes and speed of play) of machines is proportionate to the premises. For such a framework to have any meaningful effect it must be possible for regulatory authorities and consumers to distinguish between different gambling premises. 4.37 At Paragraph 18.27 it states: The LCCP requires (Social Responsibility Code Provision 9) that gaming machines are only made available in combination with the named non - remote activity of the operating licence. So, unless a bingo premises operator offers substantive facilities for non-remote bingo it should not make gaming machines available for use on the premises in question. To contain the unavoidable risk to the licensing objectives associa ted with gaming machines, premises which offer machines must be appropriately supervised. 4.38 At Paragraph 18.28 it states: The current regulatory framework prescribes that category B gaming machines may only be made available in licensed gambling premises and not in locations which may prompt more ambient gambling such as pubs. Maintaining distinctions between different gambling venues allows individuals to make a deliberate choice whether to enter that particular gambling environment. In carrying out their functions under the Act licensing authorities should satisfy themselves that a premises applying for or licensed for bingo is operating or will operate in a manner which a customer would reasonably be expected to recognise as a premises licensed for th e purposes of providing facilities for bingo. 4.39 At Paragraph 18.29 it states: Licensing authorities are not being asked to impose a ‘one size fits all’ view of how a bingo premises should look and function. Rather they are ensuring that a premises licensed for the purposes of providing facilities for bingo is operating as such and is not merely a vehicle to offer higher stake and prize gaming machines. 4.40 At Paragraph 18.30 it states: In exercising its functions under the Act, a licensing authority should take account of the relevant code of practice on ‘controlling where gaming machines may be played’. It is specifically obliged to do so when exercising functions under section 153 of the Act. In circumstances where a licensing authority considers an existing premises is not compliant with these general requirements, they should contact the Commission at the earliest opportunity. 4.41 At Paragraph 18.31 it states: Both the Commission and licensing authorities have the power to attach specific conditions to operating or premises licences in circumstances where additional assurance is required. The Commission favours the approach of general conditions for all supplemented by operator -specific conditions in cases where novel or contentious operating models are used which include the provision of gaming machines. This is to deliver the policy objectives above and ensure the risk to the licensing objectives is minimised. 4.42 At Paragraph 18.32 it states: In the Commission’s view the above approach would ideally be adopted at licensing stage. Licensing authorities should ensure that they request all the Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public information required from an applicant for a new premises or for a variation to an existing premises in order to satisfy themselves as to the matters set out at s153 of the Act. This includes the codes of practice and this guidance. The approach of adding case specific conditions can equally be deployed in respect of an existing unit where concerns arise or when changes are made to the operating model. HILLINGDON’S GAMBLING POLICY 5.1 The information in this section of the report relates to the relevant sections within the London Borough of Hillingdon’s Statement Gambling Policy which members should consider. General Principles 5.2 At Paragraph 5.6 it states: “Under the Act, the Licensing Authority has no discretion to grant Premises Licences in circumstances where that would mean departing from the Gambling Commission Guidance and Codes of Practice and this Licensing Authority’s own Statement of Licensing Principles. Therefore, our primary focus shall be to aim to permit the use of premises for gambling in so far as we think it is: i) In accordance with any relevant Code of Practice issued by the Gambling Commission. ii) In accordance with any relevant Guidance issued by the Gambling Commission. iii) Consistent with the Licensing Objectives. iv) In accordance with this Statement of Licensing Principles.” 5.3 At Paragraph 5. 7 it states: “The Council appreciates that gambling can be an emotive subject but acknowledges and endorses the Gambling Commission Guidance that “moral objections to gambling are not a valid reason to reject applications for premises licences “ (except as regards any “no casino resolution”) and also that unmet demand is not a criterion for a Licensing Authority.” Location At Paragraph 5. 19 it states: “The Gambling Commission Guidance stipulates that demand issues cannot be considered in relation to the location of premises but that considerations made in terms of the licensing objectives can.” 5.4 At Paragraph 5.20 it states: “In accordance with the Gambling Commission’s Guidance for Local Authorities, this Licensing Authority will pay particular attention to the protection of children and vulnerable persons from being harmed or exploited by gambling, as well as issues of crime and disorder.” 5.5 At Paragraph 5.21 it states: “The authority has not adopted any specific policy in relation to areas where gambling premises should not be located. Should any such policy be decided upon, this policy statement will be updated accordingly. It should be noted t hat any such future policy will not preclude any application being made with the onus upon the applicant showing how any potential concerns can be overcome.” 5.6 At Paragraph 5.22 it states: “Each case will be decided on its merits and will depend, to a large extent, on the type of gambling that it is proposed will be offered on the premises.” Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public 5.7 At Paragraph 5. 23 it states: “If an applicant can demonstrate appropriate measures to overcome concerns, that will be taken into account by the Council.” Conditions At Paragraph 5.24 it states: “Any conditions attached to licences will be proportionate and will be: (i) Relevant to the need to make the proposed building suitable as a gambling facility (ii) Directly related to the premises and the type of licence applied for (iii) Fairly and reasonably related to the scale and type of premises and (iv) Reasonable in all other respects” At Paragraph 5.28 it states: “Decisions upon individual conditions will be made on a case- by-case basis, although there will be a number of control measures this licensing authority will consider utilising should there be a perceived need, such as the use of door supervisors, supervision of adult gaming machines, appropriate signage for adult -only areas etc. There are specific comments made in this regard under each of the licence types below.” At Paragraph 5.29 it states: “This policy acknowledges that there are conditions that the licensing authority cannot attach to premises licences: (i) Any condition on the premises licence which makes it impossible to comply with an operating licence condition. (ii) Conditions relating to gaming machine categories, numbers, or method of operation. (iii) Conditions which provide that membership of a club or body be required (the Gambling Act 2005 specifically removes the membership requirement for casino and bingo clubs and this provision prevents it being reinstated). (iv) Conditions in relation to stakes, fees, winning or prizes.” Bingo Premises 5.8 At Paragraph 5.35 it states: Bingo is a class of equal chance gaming and is permitted in alcohol licensed premises and in clubs provided it remains below a certain threshold, otherwise it will be subject to a bingo operating licence which will have to be obtained from the Gambling Commission. 5.9 At Paragraph 5. 36 it states: The holder of a Bingo Operating Licence will be able to provide any type of bingo game including cash and prize bingo. Where bingo is permitted in alcohol licensed and non -gambling premises, this must not become a predominant commercial activity; otherwise a bingo operating licence will be required. 5.10 At Paragraph 5.37 it states: Commercial bingo halls will require a bingo premises licence from the Council. Amusement arcades providing prize bingo will require a prize gaming permit from the Council. 5.11 At Paragraph 5.38 it states: In each of the above cases it is important that where children are allowed to enter premises licensed for bingo, in whatever form, they are not allowed to participate in any bingo game, other than on category D machines. When considering applications of this type the Council will therefore take into acc ount, among other things, Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public the location of the games or machines, access to those areas, general supervision of the premises and the display of appropriate notices. 5.12 At Paragraph 5.39 it states: The Licensing Authority recognises that there is no ban on children or young people having access to Bingo premises, that it is illegal for Under 18s to play or use Category B and C machines and that they cannot be employed in providing facilities for gambling or bingo premises. In any event, children under 16 cannot be employed in any capacity at a time when facilities for playing bingo are being offered. 16 and 17 year olds may be employed while bingo is taking place provided the activities on which they are employed are not connected with the gaming or gaming machines. Where children aged 16 and 17 are employed in bingo premises, the Licensing Authority would expect to see sufficient controls restricting access to Category B and C machines. 5.13 At Paragraph 5. 40 it states: A limited number of gaming machin es may also be made available at Bingo licensed premises . A list of categories of gaming machines is on page 43 category C or above machines are available in premises to which children are admitted, the licensing authority will seek to ensure that: (i) All such machines are located in an area of the premises separated from the remainder of the premises by a physical barrier which is effective to prevent access other than through a designated entrance. (ii) Only adults are admitted to the area where these machines are located. (iii) Access to the area where the machines are located is supervised. (iv) The area where the machines are located is arranged so that it can be observed by staff of the operator or the licence holder and (v) At the entrance to, and inside any such area there are prominently displayed notices indicating that access to the area is prohibited to persons under the age of 18. 5.14 At Paragraph 5. 41 it states: The Council will expect applicants to offer their own measures to meet licensing objectives however appropriate measures / licensing conditions may cover issues such as:  Proof of age schemes.  CCTV – this should be of sufficient quality that it will use evidence.  the provision of entrances/machine areas  physical separation areas  location of entry  notices/signage  specific opening hours  self-exclusion schemes - these are schemes whereby individuals who acknowledge they have a gambling problem ask to be barred from certain premises  provision of information leaflets/helpline numbers for organisations such as GamCare This list is not mandatory, nor exhaustive, and is merely indicative of example measures that the Council can consider implementing. 5.15 At Paragraph 5.43 it states: With regard to segregation of Category B and C machines from Category D machines, there is a requirement that there must be clear segregation between these types of machine so that children do not have access to Category B or C Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public machines and the Licensing Au thority will take into account any guidance issued by the Gambling Commission in the light of any regulations made by the Secretary of State. Gaming Machines 5.16 At Paragraph 6.5 it states: “A gaming machine can cover all types of gambling activity, which can take place on a machine, including betting on virtual events. A machine is not a gaming machine if the winning of a prize is determined purely by the player’s skill. However, any element of chance imparted by the action of the machine would cause it to be a gaming machine.” 5.17 At Paragraph 6.7 it states: “There are four classes of gaming machines: Categories A, B. C and D, with category B further divided into sub -categories B1, B2, B3, B3A and B4. Appendix 5 sets out the current maximum stakes and prizes that apply to each category. 5.18 At Paragraph 6.8 it states: “The Gambling Act also prescribes the maximum number and category of gaming machines that are permitted in each type of gambling premises.” The table, below, shows the maximum number and category of gaming machines that are permitted at a bingo premises: BINGO PREMISES MAXIMUM OF 20% OF THE TOTAL NUMBER OF GAMING MACHINES WHICH ARE AVAILABLE FOR USE ON THE PREMISES FOR CATEGORIES B3 AND B4. NO LIMIT ON CATEGORY C AND CATEGORY D MACHINES LEGAL CONSIDERATIONS THE GAMBLING ACT 2005 6.1 When considering an application for a grant of a new Bingo Premises Licence, the Sub - Committee shall carry out its functions with a view to taking steps it considers appropriate for promoting the licensing objectives. Section1 of the Gambling Act 2005 creates three licensing objectives: 1. Preventing gambling from being a source of crime and disorder, being associated with crime or disorder or being used to support crime; 2. Ensuring that gambling is conducted in a fair and open way, and 3. Protecting children and other vulnerable persons from being harmed or exploited by gambling Statutory aim to permit gambling 6.2 The guidance issued by the Commission states at Paragraph 1.19: "The Act places a legal duty on both the Commission and licensing authorities to aim to permit gambling, insofar as it is considered to be reasonably consistent with the licensing objectives. Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public The effect of this duty is that both the Commission and licensing authorities must approach their functions in a way that seeks to regulate gambling by using their powers, for example, powers to attach conditions to licences, to moderate its impact on the licensing objectives rather than by starting out to prevent it altogether." 6.3 An application for a new premises licence may be made pursuant to s.159 of the Act. 6.4 All applications will be decided on a case-by-case basis. 6.5 Where relevant representations are made and not withdrawn, the Licensing Authority must hold a hearing to determine the application, unless all are agreed that such a hearing is unnecessary s.162 (2). 6.6 Section 153(1) of the Act provides that licensing authorities should aim to permit the use of premises for gambling in so far as they think it: (i) in accordance with any relevant code of practice under section 24; (ii) in accordance with any relevant guidance issued by the Gambling Commission under section 25; (iii) reasonably consistent with the licensing objectives; and (iv) in accordance with the authority’s statement of licensing policy. 6.7 Section 153(2) of the Act goes on to state that in “determining whether to grant a premises licence a licensing authority may not have regard to the expected demand for the facilities which it is proposed to provide. 6.8 Relevant representations are those that relate to the effect of the granting of the application on the promotion of the licensing objectives made by an interested party or responsible authority that have not been withdrawn and are not, in the opinion of the relevant licencing authority, frivolous or vexatious s.162(3) Gambling Act 2005. 6.9 The Sub-Committee can only consider matters within the application that have been raised through representations from interested parties and responsibl e authorities. Interested parties will include persons who: (i) Live sufficiently close to premises carrying out gambling activities; (ii) Have business interests that might be affected; and (iii) Represent persons listed above. 6.10 The Act, via regulations also imp oses mandatory and default conditions that promote the licensing objectives. There are no default conditions in relation to ACG’s. 6.11 In respect of the imposition of Conditions by the Licensing Authority, Section 169 (4) states that a “licensing authority may not attach a condition to a premises licence which prevents compliance with a condition of the operating licence which authorises the holder to carry out the activity in respect of which the premises licence is granted”. 6.12 The decision determined by the Sub -Committee will be accompanied with clear, cogent reasons for that decision, having had due regard to being reasonably consistent with the Licensing Objectives; the Human Rights Act 1998; any relevant code of practice unde r Section 24 of the Gambling Act 2005; any relevant guidance issued by the Commission under Section 25 of the Gambling Act 2005; and this Statement of Policy. The decision Licensing Sub-Committee Hearing – 27 October 2025 Part I – Public and the reasons for that decision will be sent to the Applicant and those who have m ade relevant representations as soon as practicable. 6.13 The Council in its capacity as Licensing Authority has a duty to have regard to its public sector equality duty under s.149 of the Equality Act 2010. In summary s.149 provides that a Public Authority must, in the exercise of its functions, have due regard to the need to: (i) Eliminate discrimination harassment, victimisation and any other conduct that is prohibited by or under this Act; (ii) Advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; and (iii) Foster good relations between persons who share relevant protected characteristics and persons who do not. 6.14 Section 149(7) of the Equality Act 2010 defines nine relevant protecte d characteristics examples are: race, sex, age, disability, gender reassignment and religious beliefs. 6.15 Officers have provided the Sub -Committee with recommendations related to this application. Subject to the above-mentioned factors having been properly considered, the Sub-Committee may depart from the recommendations if there are good reasons for doing so. The Sub -Committee is advised that such departures could give rise to an appeal or judicial review 6.16 Interested parties, Responsible Authorities and the Applicant have the right to appeal the decision of the Licensing Sub -Committee to the Magistrates’ Court within a period of 21 days beginning with the day on which the applicant was notified by the Licensing Authority of the decision to be appealed against. BACKGROUND DOCUMENTS: The Gambling Act 2005 Licence Conditions and Codes of Practice by the Gambling Commission Guidance for Local Authorities issued by the Gambling Commission The London Borough of Hillingdon’s Statement of Gambling Policy

Page 1 of 18 Merkur Slots, Part Ground Floor, 62 Station Road, Hayes, UB3 4DF Local Area Risk Assessment Trading Name: Merkur Slots Premise: Part Ground Floor, 62 Station Road, Hayes, UB3 4DF Local Authority: London Borough of Hillingdon Premise Licence No: New application Operator Licence No: 000-003266-N-103444-031 (Merkur Slots UK Limited) Company Details: Merkur Slots UK, Second Floor Matrix House, North Fourth Street, Milton Keynes, MK9 1NJ Name and Title of Assessor: Ewelina Lesner – Internal Compliance Auditor and Amanda Kiernan – Head of Compliance Date of Assessment: 05/06/2025 Review Date: On opening in conjunction with local staff Page 2 of 18 Local Area Profile Risk Factors Local Risk Profile: The premise, a former Barclays Bank is situated at 62 Station Road. The postcode is within the Hayes Town ward/electoral division, which is in the constituency of Hayes and Harlington. Is located just 3-minutes’ walk away from Hayes Town centre. Train station is within 0.1 mile away and Heathrow Airport 2.5 miles away. Nearby occupiers include KFC and other restaurants, coffee shops, pharmacies, banks, amongst several other retailers. The Old Crown Pub is located opposite the premises. The YMCA is a short distance from the premise. Hayes Town ward has a very large concentration of residents that are aged 20 -30, this age group are classed as potentially vulnerable to being effected by gambling harm. Establishments of note: KFC restaurant, 60 Station Rd, Hayes UB3 4DF; Hayes & Harlington Station, Station Approach, Hayes UB3 4BX Adjoining premises: 62 Station Road, UB3 4DF is located next to KFC restaurant. No premise on the other site as bridge is running across the canal. Crime statistics: (Data: Mar 2024 - Feb 2025) Annual total crime rate in local area is 249 per thousand population. This can be rated as 7 out of 10 or high crime level compared to other local areas in England and Wales. Annual total crime rate in Hillingdon is 89 per thousand population, which can be rated as 4 out of 10 or low crime level compared to other local authority districts in England and Wales. Below are annual crime rates by crime type. Figures represent the number of crimes of a certain type per thousand population and indicate the relative ratings of the local area for a specific crime type compared to other local areas. Violence and sexual offences 58.8 (6/10), Anti-social behaviour 57.5 (7/10), Public order 25.4 (7/10), Theft from the person 21.4 (5/10), Other theft 15.4 (6/10), Shoplifting 12 (4/10), Drugs 10.7 (6/10), Robbery 10 (8/10), Vehicle crime 10 (6/10), Burglary 9.36 (7/10), Criminal damage and arson 8.69 (5/10), Bicycle theft 6.68 (7/10), Other crime 2.01 (4/10), Possession of weapons 1.34 (4/10). (Crystalroof.co.uk) Population: Across the UK, the gender split is roughly equal at 49% male, 51% female. This address in Hayes and Harlington constituency is broadly in line with those figures, with 52% male. 72% of residents that are single. (streetcheck.co.uk) Culture: The main ethnic group is White British, representing 20% of the population. On average, 37% of the population in London belong to the White British ethnic group. Other ethnic groups are: Black African 17%, Other Asian 16%, Indian 9%, Other White 8%, White Irish 6%, Pakistani 6%, Other 6%, Black Caribbean 4%, Other Black 2.6%, Mixed 1.7%, Arab 1.7%, Roma 0.9%. The main religions are Christian and Muslim, each representing 35% of the population. On average, 41% of the population in London belong to the Christian religion and 15% belong to Muslim. Other religions are: No Religion 11%, Hindu 9%, Religion Not Stated 7%, Buddhist 0.9%, Jewish 0.9%, Other Religion 0.9%. (Crystalroof.co.uk) Unemployment: Full-Time Employee 10.5%, Part-Time Employee 5.7%, Self Employed 0.9%, Unemployed 19%, Full-Time Student 21.9%, Retired 4.7%, Looking After Home or Family 3.8%, Other 33.5%. (streetcheck.co.uk) Deprivation: Index of Multiple Deprivation - 7/10. This is used to characterise the deprivation levels of the neighbourhoods. It takes into account the following domains: Income Deprivation Domain - 7/10, Employment Deprivation Domain - 5/10, Education, Skills and Training Deprivation Domain - 6/10, Health Deprivation and Disability Domain - 3/10, Crime Domain - 9/10, Barriers to Housing and Services Domain - 10/10, Living Environment Deprivation Domain - 8/10, Income Deprivation Affecting Children Index (IDACI) - 7/10, Income Deprivation Affecting Older People Index (IDAOPI) - 8/10. (Crystalroof.co.uk) Local Police: Station Road, Hayes, UB3 4DF is within the Hayes Town policing neighbourhood, under the Metropolitan Police Service force area. Police Station address: 755 Uxbridge Road, UB4 8HU. During due diligence the police have advised this areas has a few issues with ASB, alcohol and drug abuse. Current policing priorities include: Violent crimes related to females; targeting street drinking, begging & ASB and the tower blocks being subject to drug dealing, noise, rough sleepers and ASB leaving residents feeling unsafe. Age Verification Test results: Age verification test purchasing, and mystery shopper visits are frequently carried out by third party companies - ServeLegal and Store Checker. All venues receive 2 or 3 random test visits per year. Independent Security Reviews MERKUR Slots UK appointed Leveche Associates Ltd to conduct independent covert visits on numerous AGC/Bingo venues that operate throughout the UK 24-hrs, 7 days a week including six venues in and around the London area. Key comments from the reports include: ‘Visits to these premises established that they are well run and that there are clearly defined systems in place to ensure th e premises operate in support of the gambling objectives and do not attract or take advantage of juveniles or other vulnerable persons. The visits also established that MERKUR Slots customer do not cause crime or anti -social behaviour.’ ‘MERKUR Slots UK and their premises operate in support of the principles of Secured by Design, the company recommended by the Chief Officers of UK Police Forces for Crime Prevention standards’. ‘The presence of MERKUR Slots does not lead to or result in people, who have been on a night out, staying in the area any lon ger than they had planned to’. Page 13 of 18 Training & Social Responsibility Merkur Slots takes responsible gambling and social responsibility seriously, ensuring all staff are fully trained to carry out their roles in a responsible manner. Merkur Slots has attained Responsible Gambling Accreditation from the G4 Global Gambling Guidance Group. Merkur Slots works with YGAM (Young Gamers and Gamblers Education Trust) and Betknowmore to deliver City and Guilds accredited training on vulnerable and gambling harm to all levels of management. Merkur Casino has a dedicated Learning and Development Team and a Safer Gambling team that deliver face to face compliance and social responsibility training. Safer Gambling team review and evaluate the effectiveness of training. Gambling Accredited training completed by members of management that hold Personal Management Licences (PML). All staff complete on boarding and 6 monthly refresher training: The Essentials of Compliance and annually: Safeguarding Children and Vulnerable People Age Verification and Customer Interaction. Staff are aware of the importance of social responsibility, trained to advise customers of gambling responsibly and identifying potential problem gamblers. Compliance and Social Responsibility Folder and Player Protection Framework containing policies and procedures is available to all staff via MyMerkur intranet. Venue Mangers review compliance logs weekly, Area Managers Monthly, Safer Gambling team monthly and Compliance Auditors annually. Page 14 of 18 Merkur Slots Hayes Premise Layout Premise level: Merkur Slots Hayes will be a ground floor premise. Premise frontage: Merkur Slots Hayes will be a property of a style which obscures the interior with digital Marketing Screens displaying safer gambling messages, no under 18’s, opening times. Marketing and promotions will comply with LCCP, and standards set by the Committee of Advertising Practice (CAP) and Broadcast Committee of Advertising Practice (BCAP). Counter Position: Merkur Slots Hayes floor layout will be of the design to avoid blind spots and enable supervision of entrances and machines from the central service area and staff will regularly patrol the gaming floor to supervise and interact with customers and identify underage or vulnerable persons. The central service area serves as the main support area for staff to manage the venue without having to leave the floor: - TiTo machines with a central redemption change machine GeWeTe, the GeWeTe is fitted with a duress code facility and built in time delay. Staff do not carry cash floats and only management can open the gaming machines and change machines. - Beverage and snacks are provided from the service area. - SMART Tablet located on the service desk provides the facility to record age verification checks, customer interactions, incidents, self-exclusions, reinstatements, track and trace and general venue management checklists. - The CCTV monitor on the central desk allows staff to view the exterior at all times. Floor layout: Merkur Slots Hayes floor layout will be designed to avoid blind spots to enable the active management and observation of customers entering and leaving the premises, from the central service area the entrances, machines and toilet can be observed, and staff will regularly patrol the gaming floor and interact with customers allowing identification of underage and vulnerab le persons. 'Stay in Control' Posters and Leaflets will be located in prominent locations within the premise. Machine Positions: Merkur Slots Hayes will operate under a Bingo Licence, with proprietary bingo equipment, and a range of category B3 (max stake £2/prize £500), C (max stake £1/prize £100) and D (max stake 10p/prize £5) machines (company average stake is 30/40p). Bingo will be available by means of Tablets offering a range of Bingo products and Live calling. Bingo Tablets are linked to Merkur bingo venues and other operators across the country and allow customers to play Bingo including the National Game which is played twice per day in the venue when customer numbers are as low as one. Hidden Areas: Merkur Slots Hayes will be fitted with a HD CCTV system with coverage of all public areas including all entry and exits points, CCTV will be clearly advertised to customers with screens visible by employees when working in the service area. Page 15 of 18 Additional Comments Merkur Slots has attained the prestigious Global Gaming Guidance Group (G4) accreditation for Responsible Gambling. This is only awarded after a rigorous audit of the company’s safer gambling measures. Furthermore, ongoing accreditation requires reassessment every 18 months. None of our operational venues have been subject to review proceedings. This document provides an assessment of risk at premise level relating to the provision of these facilities for gambling. Merkur Slots is a national operator and employs several standard policies, procedures and control measures across all premises. These issues are clearly articulated in the "Compliance Manual" to be found in the premise and in our Player Protection Framework. The company also carries out premise’s security risk assessments (available on request) and health and safety risk assessments which inter alia relate to the objective of keeping crime out of gambling. Where relevant, Merkur Slots has also considered any substantive local risks identified in a wide range of policy statements related to gambling and local area profiles specifically related to gambling. However, the company does not operate discriminatory policies against any identified groups based on social demographic or ethnic origin. Therefore, identification of issues relating to gambling related harm are based on individual customer behaviour even where particular groups are identified through research at being at greater risk of gambling related harm. Assessors Name: Amanda Kiernan Signature: Date: 05/06/2025 Page 17 of 18 Merkur Slots, Part Ground Floor, 62 Station Road, Hayes, UB3 4DF: Page 18 of 18 Merkur Slots – Shop frontage example: NOTICE OF APPLICATION FOR A PREMISES LICENCE This notice is issued in accordance with regulations made under section 160 of the Gambling Act 2005 Notice is hereby given that MERKUR Slots UK Limited of the following address: Second Floor Matrix House North Fourth Street Milton Keynes MK9 1NJ the number of whose operating licence is 003266-N-103444 has made an application for a Bingo Premises Licence. The application relates to the following premises MERKUR Slots Part Ground Floor 62 Station Road Hayes UB3 4DF The application for a premises licence has been made to the following licensing authority: The Licensing Service London Borough of Hillingdon Civic Centre Uxbridge UB8 1UW W: www.hillingdon.gov.uk Information about the application is available from the licensing authority, including the arrangements for viewing the details of the application. The following person connected with the applicant is able to give further information about the application: Aaron Newbold Poppleston Allen 37 Stoney Street The Lace Market Nottingham NG1 1LS E: a.newbold@popall.co.uk T: 0115 9487406 Any representations under section 161 of the Gambling Act 2005 must be made no later than the following date: 14 July 2025 Merkur Slots UK Limited Operational Standards THE LICENSING OBJECTIVES UNDER THE GAMBLING ACT 2005 • Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime • Ensuring that gambling is conducted in a fair and open way • Protecting children and other vulnerable persons from being harmed or exploited by gambling Objective 1 - Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime. • Merkur Slots UK Limited is aware that it must notify the Gambling Commission should we suspect that offences under the Gambling Act 2005 are being committed. • Merkur Slots UK Limited complies with the Commission's advice on the Proceeds of Crime Act 2002. • Merkur Slots UK Limited has completed its own Business Anti -money laundering risk assessment, local area risk assessments and implements anti-money laundering policies and procedures. • If we suspect anyone of using our premises for the furtherance of criminal activity (for instance drug dealing, using counterfeit money, selling suspected stolen property and criminal damage) we will contact the police immediately, report to our Head of Compliance and record the instance in the AML and Incidents modules of the electronic Smart Tablet system. • All Merkur Slots UK Limited premises operate digital CCTV and customer areas are supervised. • Merkur Slots UK operates a group-wide Security Alert system where incidents are shared instantly with all licenced premises. We have an internal Fraud Measures Team that respond to and investigate incidents. As a BACTA member, we receive nationwide Securit y Alerts, which are circulated via the Security Alert system to all licenced premises. • All Merkur Slots UK premises provide a static alarm system which is also supported by Staff Guard, a nationwide security company that offers 24hr support via a monitoring centre with fully trained operatives who advise on difficult situations and escalate appropriately. • Merkur Slots UK Limited has an extensive security, audit and money laundering team monitoring employees and customer activity. • All Merkur Slots UK employees complete six-monthly refresher training which covers this licencing objective; anti-money laundering policies and procedures; and guidance on the Proceeds of Crime Act 2002. • Merkur Slots UK operate a robust late night working policy, which is fully supported by a full time Night Manager. • Merkur Slots UK does not operate a single -manning policy between 10pm and close, however, should an emergency occur a 'locked door' and 'keep in touch' policy is implemented. Objective 2 - Ensuring that gambling is conducted in a fair and open way. • Our gaming rules are prominently displayed in each of our licensed premises. • Our employees have a full understanding of machine gaming rules. Merkur Slots UK Limited Operational Standards • We encourage customer-facing employees to use positive discretion to resolve customer issues at a local level, where possible. • Our Customer Complaints procedure is display prominently in every venue. Where customer disputes cannot be resolved satisfactorily, we refer all potential disputes to our appointed Alternate Dispute Resolution provider (IBAS). • All venue managers complete a comprehensive 13 week induction programme prior to taking on responsibility of their own venue and team. • All licensed premises employees receive induction and six -monthly refresher training during their employment to ensure that potential issues can be addressed at the earliest opportunity. Objective 3 - Protecting children and other vulnerable persons from being harmed or exploited by gambling • All our licensed premises are strictly adult only and we provide appropriate notification on entry, on all marketing material and throughout our premises. • We operate a Think 25 policy as standard and all employees are trained to request a photographic form of identity if they suspect that a customer is under age. All challenges are recorded on our Smart Tablet system under Age Verification Checks and ServeLegal are our third-party independent partner for compliance testing. Test results are reported to the Gambling Commission. • All licensed premise employees receive induction and six -monthly refresher training during their employment on social responsibility and safeguarding children and vulnerable people, with a particular focus on the prevention of harm. • We prominently display information throughout our licensed premises on responsible gambling and provide details of organisations that can provide support and guidance such as BeGambleAware. • Socially Responsible messaging is implemented on B3 and Category C digital machines. • All licensed premise employees are trained to identify potential at risk customers and conduct effective interactions. Customer interactions are recorded on the Interactions module on the electronic Smart Tablet and reviewed centrally by the Compliance team. • Merkur Slots U K have a Sa fer Gambling Team dedicated to supporting venues with meeting this licensing objective and their socially responsible requirements. • We implement a self-exclusion policy throughout our licensed premises and operate a Smart Tablet system for recording self -exclusions, reinstatements, and breaches. We are also members of the Bingo Association Multi-Operator Self-exclusion Scheme. • The layout of our premises is designed to facilitate customer supervision by employees. • We provide an annual donation in support of research, prevention, and treatment (RPT) of problem gambling. All three licensing objectives are embedded at all levels within the organisation via training both online and face to face, during Operational meetings, Business Bulletin communications, Compliance/Audit visits, Safer Gambling Workshops and Annual Conferences.

Task summary Case reference 2095-4186-5123-7608 T ask reference 2668-2721-3755-8306 Case manager Riviane Araujo T ask owner Lois King Case type Corporate Complaint Date requested 2025-07-17T08:43:15.390Z T ask target 2025-07-31T08:43:03.706Z T ask description Service request - investigate and send response (service) Dear T eam, Could you please arrange for this case to be investigated and responded to? Many thanks Regards Riviane Araujo Name: Christine O'Hara-Carnduff Email: Phone: Address: 32 32 Clayton Road 32 Clayton Road UB3 1AZ Back Case details Complaint  24/07/2025, 14:13 Case Management - Staff portal https://staff.hillingdon.gov.uk/complaint-tasks?taskid=871780832 1/5 Appendix 2 Which Hillingdon Council service does your complaint relate to? Corporate Complaint How would you like to make the complaint Myself Your details First name Christine Last name O'Hara-Carnduff Email address Confirm email address T elephone / mobile number Your address 32 32 Clayton Road 32 Clayton Road Hayes UB3 1AZ Complaint Complaint title Gambling licence for former Barclays Bank Hayes UB3 Details of complaints It has recently been brought to my attention that there is an application by purchasers who have bought the old 24/07/2025, 14:13 Case Management - Staff portal https://staff.hillingdon.gov.uk/complaint-tasks?taskid=871780832 2/5 Barclays Bank Station road Hayes. Originally we were told it was going to be flats but now we see there is an application for two floors of gambling. One slot machines and another a bingo hall. My concern is firstly we as residents on Clayton Road already struggle with parking issues. Despite having permits in place people simply take no notice of this and still park up. Traffic enforcement officers are hardly ever visible in our area. There simply will not be any parking for anyone coming to this gambling building. There is a small under ground car park but nothing else so I think our street will get more abuse and nothing done about it. Secondly why do we need another gambling premises in the high street? We already have 2 slot machines venues along side so many betting shops. Why are we in a time when there is very little money, Hayes is not an affluent area, but yet we are encouraging gambling? Thirdly I do want the type of clientele that gambling and betting shops encourage to be on the corner of my street. I have young children to be concerned about. These are my issues and concerns for the area. What can we do to resolve this from your perspective I totally object t o the up holding of a gambling licence for these premises and given my concerns above that Hillingdon council will see fit to not grant it. Have you c ontacted the Council and/or a Service area about this matter previously No If you have any supporting documents you can upload them here 24/07/2025, 14:13 Case Management - Staff portal https://staff.hillingdon.gov.uk/complaint-tasks?taskid=871780832 3/5

From: Riviane Araujo To: Lois King Subject: Re: Corporate Complaint - Licensing Services reference: 2095-4186-5123-7608Task assignment: Corporate Complaint - Licensing Services reference: 2095-4186-5123-7608 Date: 17 July 2025 13:01:27 Attachments: image001.png Outlook-alht534s.png Hello Lois, The complaint was submitted online on Sunday, 13 July. 13/07/2025 09:24 Christine O'Hara- Carnduff Case - New Case initiated: Corporate complaint Public The Complaints team has five working days to claim and progress cases, so this one was claimed and assigned today, 17 July. I hope it helps. Kind regards, Riviane Araujo Complaints and Enquiries Officer Hillingdon Council - Corporate Services Civic Centre, High Street, Uxbridge, UB8 1UW, Tel: 6513 (internal) Tel: 01895 556513 (external) - Appendix 2B

© Crown copyright and database rights 2023 Ordnance Survey AC0000810857 © Crown copyright and database rights 2025 Ordnance Survey 100019283 / 0 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.09 0.10 km Map Notes . Merkur Slots 4 5 6 2 1 7 3 Appendix 3

3.2.5 - Bingo and FEC SR code Social responsibility code Applies to: All non-remote bingo and family entertainment centre licences. 1. Licensees must have and put into effect policies and procedures designed to prevent underage gambling, and monitor the ef fectiveness of these. 2. This must include procedures for: a. checking the age of apparently underage customers b. refusing entry to any adult-only areas to anyone unable to produce an acceptable form of identification c. taking action when there are unlawful attempts to enter the adult-only areas. 3. Licensees must ensure that their policies and procedures take account of the structure and layout of their gambling premises. 4. Licensees must not permit children or young people to gamble in the adults-only areas of premises to which they have access. If there is a ‘no under-18s’ premises policy , licensees must pay particular attention to the procedures they use at the entrance to the premises to check customers’ ages. 5. Licensees must take all reasonable steps to ensure that all staff understand their responsibilities for preventing underage gambling. This must include appropriate training which must cover: a. all relevant prohibitions against inviting children or young persons to gamble on age- restricted products or to enter age-restricted areas; b. the legal requirements on returning stakes and not paying prizes to underage customers; and c. procedures for challenging any adult who may be complicit in allowing a child or young person to gamble. 6. Licensees must only accept identification which: a. contains a photograph from which the individual can be identified b. states the individual’s date of birth c. is valid d. is legible and has no visible signs of tampering or reproduction. 7. All licensees must conduct test purchasing or take part in collective test purchasing programmes, as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such a form or manner as the Commission may from time to time specify. Read additional guidance on the information requirements contained within this section. LCCP https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/print 45/99 Appendix 4 3.2.6 - Bingo and FEC ordinary code Ordinary code Applies to: All non-remote bingo and family entertainment centre licences. 1. The Commission considers acceptable forms of identification to include: any identification carrying the PASS logo (for example Citizencard or Validate); a military identification card; a driving licence (including a provisional licence) with photocard; or a passport. 2. Licensees should require a person who appears to relevant staff to be under the age of 25 to be asked to produce proof of age, either at the point of entry to the gambling area or as soon as it comes to the attention of staff that they wish to access gambling facilities. 3. Licensees should have procedures for dealing with cases where an adult knowingly or recklessly allows a child or young person to gamble. These procedures might include refusing to allow the adult to continue to gamble, removing them from the premises, and reporting the incident to the police or local authorities, or taking action where forged identification is produced. 4. Procedures should be put into effect for dealing with cases where a child or young person repeatedly attempts to gamble on their premises, including oral warnings, reporting the offence to the Gambling Commission1 and the police, and making available information on problem gambling to the child or young person concerned. 5. Where it is likely that customers’ young or otherwise vulnerable children will be left unattended on or adjacent to their premises, licensees should consider reminding customers of their parental responsibilities and assess whether there is a need to develop procedures for minimising the risk to such children. 6. In providing training to staff on their responsibilities for preventing underage gambling, licensees should have, as a minimum, policies for induction training and refresher training. Read additional guidance on the information requirements contained within this section. 1 These matters are to be reported to us online via our ‘eServices’ digital service on our website. LCCP https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/print 46/99

CAT EGORIES OF GAMING MACHINES CATEGORY MAXIMUM STAKE MAXIMUM PRIZE A Unlimited Unlimited B1 £5 £10,000* B2 £100 (in multiples of £10) £2 effective April 2019 £500 B3 £2 £500 B3A £2 £500 B4 £2 £400 C £1 £100 D** - - D non-money prize (other than crane grab machine) 30p £8 D non-money prize (crane grab machine) £1 £50 D money prize (other than a coin pusher or penny falls machine) 10p £5 D combined money and non- money prize (other than coin pusher or penny falls machines) 10p £8 (of which no more than £5 may be a money prize) D combined money and non- money prize (coin pusher or penny falls machine) 20p £20 (of which no more than £10 may be a money prize * C ategory B1 where the prize value available through its use is wholly or partly determined by reference to use made of one or more other subcategory B1 machines, no more than £20,000 * *Category D machines with a 10p stake are entitled to offer prizes of up to £5 in cash, or up to £5 in cash and £3 in non-monetary prizes. Category D machines with a 30p stake can offer £8 in non-monetary prizes only. Appendix 5