Integrity and the BHA
The BHA’s Director of Integrity, Legal and Risk Adam Brickell recently announced a full review of the BHA’s Integrity provision. The Review will consider the BHA’s integrity policies and processes, and the department’s structure.
The Review is now under way, but in the meantime the following blog provides an explanation as to how the Integrity unit currently operates, including their use of intelligence, day to day processes, their relationship with the Raceday teams and some detail about how investigations work.
What is intelligence?
You have probably experienced the pleasure – some might say the frustration! – of putting together a big jigsaw puzzle, with hundreds or even thousands of pieces and only a picture on the lid of the box to guide you.
Now imagine having those pieces spread out in front of you, but with no lid to work with. That’s how it feels sometimes, dealing with the hundreds of items of intelligence and information that the BHA integrity unit handles every month.
Gathering intelligence and piecing it all together is at the heart of what we do, bringing into focus a picture of what is going on. Go back to our jigsaw puzzle analogy. If you have no lid to help you, you start by looking at the colours and patterns that match up, find the bits that fit each other and slowly, you start to work out what is going in, maybe in one or two corners of the overall picture. That might give you an idea of what the final result is going to be like, so you can start to dig around in the middle and piece those bits together.
That’s what working with racing intelligence is like. Piecing together information, developing it part by part until the overall picture is emerging and then finally, putting the last pieces of the puzzle into place and producing it as evidence.
And the thing is, you never know which piece of information – which part of the puzzle – is going to set you on your way. Trivial in isolation, it could be crucial as a stepping stone in the overall process.
The gathering of intelligence is an on-going, never-ending process. The integrity team runs a full intelligence database, along the lines of those used by law-enforcement agencies, while the betting and racing analysts spend their days profiling horses and connections about whom there are, or might be, integrity concerns.
All members of the team regularly monitor social media and networking sites for further information. When intelligence is received that corroborates or enforces the views of the analysts monitoring the racing, it becomes a priority for further development. Often, it is the intelligence that drives the process.
Throughout the day, from early in the morning when most betting firms go up with their prices, the BHA betting analysts monitor the markets for any signs of unusual activity. This takes place across all the modern betting platforms, and our analysts can also call upon our own bespoke monitoring software to drill down and understand the emerging picture.
Notwithstanding the fact that betting organisations have a duty under their licence conditions to report suspicious betting to us as the sport’s governing body, and to the Gambling Commission, we will consider sharing information with the Gambling Commission ahead of any suspected coup, or in the case of particularly unusual betting patterns. This will often take the form of simply alerting them to the facts as we understand them in order that they can act as they see appropriate. The BHA is often pressed to make statements in such circumstances, but confidentiality normally needs to be exercised – especially when there is a good chance that a full investigation might follow.
As well as the betting markets, our analysts also study the races themselves, using speed maps and a database provided by an industry-leading software company to establish the likely shape of races, both from a performance perspective and a betting angle. Which horses should be short in the betting? Which ones are potential drifters, based on information in the public domain – and crucially, which ones are not? What are the ‘right’ prices for each of the contenders? These are all questions that the team looks to address before the action gets underway.
Joining things up with the Raceday teams
Before racing, the team will update the professional stipendiary stewards at each racetrack with betting information, and highlight to them any potentially unusual activity or horses to be wary of or vigilant about, based on the emerging intelligence and profiling work. Post-race, we can advise the stewards on any issues about runners and/or rides that concern them, and on occasions, we can request action before a race, when betting patterns are especially unusual. On rare occasions, a pre-race stewards’ enquiry is held, which can disrupt a potentially corrupt event by letting those involved know that we are aware of what is going on. If we have particular concerns about the betting on a race and the way it could potentially unfold, for example, we can call connections to the stewards’ room in the minutes before the race and ask them all for their riding instructions.
As well as the stewards, we also work closely with other raceday officials. Our on-course team of Equine Welfare & Integrity Officers (EWIOs) are regularly briefed by the integrity unit to consider issues around horses’ arrival on the racecourse. This can be a valuable source of information relating to time of arrival, how the horse arrives and its general condition and wellbeing.
We also work on a daily basis with our veterinary team, most obviously in the area of pre- and post-race testing, and testing in training, but also in cases where information received suggests there might be welfare or veterinary issues around a particular horse or yard. If we suspect a trainer might be issuing spurious self-certifications for non-runners, we have the power to send one of our own vets to the yard to satisfy ourselves that all is above board, and we often do.
We also liaise closely with the team of BHA handicappers. Each is assigned his or her own group of horses to monitor, assess and rate for handicapping purposes, and as such they know the horses in their own group inside-out. If they see a ride they don’t like or suspect may need further investigation, they know they can contact us about it. If we see something that might have handicapping implications, it is good that they know about it, although they have total autonomy over the final ratings decisions that they make.
As a result of all the monitoring, profiling and intelligence gathering we do, of course we often get to the point where a full investigation is required, and that involves our team of investigating officers dotted around the country. They will interview individuals involved, and we will request the disclosure of full telephone records and betting account histories. If they are licensed or registered individuals, they are bound by the rules of racing and those rules require them to comply. Failure to do so can result in disqualification, and can also account for the delays that can lead to investigations taking far longer than ideal. This is more the case, however, when we are dealing with people who are not registered and therefore not bound by the rules to comply. In these circumstances, our ability to investigate is severely hindered, though we do have the power to ‘exclude’ such individuals from the sport, which means they are not permitted to set foot on licensed premises nor have dealings with licensed persons in relation to horseracing.
However, once those telephone and betting records are in-house, our intelligence analysts piece together a timeline of communication and betting activity that can often provide those final few pieces of the puzzle, and bring to light the full picture of what has gone on. This doesn’t happen overnight, and often involves a painstaking linking together of associations, relationships, sequences of events and who was where, when and either with whom or in contact with whom at relevant times. More often than not, we discover the truth is more complex than we originally imagined – or to return to our original analogy, this jigsaw puzzle has more pieces than it appeared at the outset!
Once completed, however, the analysts’ evidence is normally extremely compelling, and when corruptors are challenged over the details and why communication took place when it did, it can unravel their defence.
Keeping racing on the right side of the line
Make no mistake, gathering intelligence is a non-stop process, and it helps us to be proactive rather than sitting back and waiting for something to happen that needs to be investigated. You never know which part of the puzzle is going to be the one that finally sets everything in motion.
Every piece of information we receive is logged, assessed, graded and linked where necessary to other pieces of intelligence. Not everyone with valuable information is bound by the rules to assist us, but everyone is invited to submit in strictest confidence anything they think will help keep the sport on the right side of the line.
The safest and most secure way to submit information is through Racestraight (https://www.britishhorseracing.com/racestraight/). Log in here (or call on 0800 085 2580) and you can anonymously give details of any wrongdoing you may have seen or heard, on or off the track. This information is passed to our integrity team and processed in the way any other information would be handled.
The Integrity Review may result in wholesale changes to the way that the department operates, or just minor enhancements – that will be decided off the back of a thorough analysis of the way we operate, with independent oversight from the “Challenge” panel, and we look forward to seeing what we can do better. However, we are also confident that the operation we have been running over the years has been one which is recognised as world-leading in the domain of sports integrity, so we hope we are starting from a pretty decent base.