03 Jul 2003 Pre-2014 Releases

Joint BHB/JC Security Review Group Report

You will find below the following:

(i) EXECUTIVE SUMMARY of the report

There are 25 diagrams in this report of different shapes and sizes. It has been difficult to get these on to the website and so some are not included.


The Security Review Group has fulfilled its task under the six Terms of Reference which, in
essence, are:

(i) to identify the nature of the threats to the integrity of horseracing in Great Britain and assess
the breadth and depth of such threats; and
(ii) to consider how best the Security Department of the Jockey Club should be structured and
organised to deal with the threats to racing’s integrity.
Integrity is crucial to the future success of a sport which supports a multi-billion pound racing
and betting industry. The integrity of horseracing in Great Britain has taken some severe knocks
over the past 5 years, with high profile arrests of five well known jockeys and a trainer in 1998
and 1999, although all were cleared of any criminal wrong-doing.

In 2000 a trial of five persons accused of conspiring to defraud by doping two racehorses
collapsed at Southwark Crown Court and all five defendants were cleared of the criminal charges
on the direction of the Judge. Three of the defendants were subsequently banned by the Jockey
Club from setting foot on all racecourses in Great Britain.

In 2002 a series of criminal trials involving an international drug smuggling gang came to a
conclusion and, in one of the trials, allegations surfaced about the corrupt activities of criminals
in horseracing.

Also in 2002, two high profile television programmes cast serious aspersions on the integrity of
horseracing in Great Britain.

In November 2002 the Jockey Club and BHB jointly commissioned a Review of the integrity of
British horseracing and how best the Security Department of the Jockey Club should be
structured and organised to deal with it.

The Group, which commenced its work in January 2003, comprised senior representatives from
the Jockey Club, the BHB, the Horserace Betting Levy Board, the Department for Culture,
Media and Sport and a retired senior Police Detective. The Group was independently chaired by
a retired Chief Constable.

The Review has been completed in five months and has been an inclusive process with wide
consultation involving a broad cross section of principal stakeholders in horseracing, others
having an interest in the sport, including the betting industry, the racegoing and betting public
and the media.

The threats to horseracing’s integrity have been identified under five broad categories:

• Breaches of the Orders and Rules of Racing by persons licensed or registered by the
Jockey Club, or by others;
• Corrupt practice by any person in respect of gambling on horses, including both the betting
on horses to win and the “laying” of horses to lose;
• Criminal activity including terrorism and animal rights extremism, the doping of horses,
money laundering and other corrupt practices concerned with horseracing; • Illegal activity which affects the welfare of racehorses; and
• Breaches of employment laws in respect of staff engaged in the sport of horseracing.
Consideration has been given to the current breadth and depth of those threats, as well as the
likely sources involved.

The Group has considered the threat to integrity from two standpoints; fact and public
perception. It has also considered allegations made in one of the television programmes that
racing was “institutionally corrupt” and a more subtle version of that allegation that, knowing or
suspecting that corrupt practices were taking place in the sport, there has been a corporate failure
to act on those issues by the regulators of the sport and other sections of the racing and betting

The Group finds on the evidence available that both those allegations are unsubstantiated.
However, there is no room for complacency because significant threats to racing remain. Those
threats, together with changes in how people can now bet on horses to win or lose, will need to
be carefully monitored by the appropriate authorities and action taken when corruption is
suspected. The Review has examined in detail the strategic aims and objectives of the Security
Department and made recommendations which include a re-focussing of the Department’s
priorities. It has examined the strengths and weaknesses of the Department and considered what
opportunities are available to address the threats to racing’s integrity and what obstacles lie in its

The Review has made recommendations to improve the effectiveness, culture, openness and
administration of the Security Department including additional staff resources for the central
intelligence cell at Jockey Club Headquarters at Portman Square and a significant improvement
in its use of information technology. It has also recommended a rationalisation of the roles of
the Racing Intelligence Officers and Investigating Officers as well as the crucial bolstering of
expert knowledge within the Department of all aspects of gambling.

The staff of the Security Department are competent and committed people who perform their
difficult task well. However, they lack the necessary resources to do their job effectively and
recommendations are made on these issues as well as on refocusing their aims, objectives and

The Review has examined the interface between the Security Department, other Departments
within the Jockey Club and the wider racing and betting industries. It has recommended that the
Security Department should adopt a more open and consultative approach with the broader
racing community. The previous culture of secrecy and treating large sections of those involved
in racing as corrupt, or potentially corrupt, are judged to have been counter productive to both
the image of the Department and its need to embrace the wider racing community in addressing
integrity issues.

The Group considers that the primary role of the Security Department should be to police the
Rules of Racing. Crime connected with horseracing is a matter for the Police, with expert
assistance provided by the Security Department as necessary. In that respect no additional
powers are sought from the Government over and above those likely to be introduced for the
planned Gambling Commission. The Group does, however, strongly support the Jockey Club’s
continuing efforts to become a “Registered Body” which is exempt under the Rehabilitation of
Offenders Act to be allowed access to higher level checks with the Criminal Records Bureau. A
small number of amendments to the Rules of Racing are recommended to increase the
effectiveness of the Security Department in regulating the sport.

The Review Group has made 36 recommendations which it assesses will enhance the efficiency
and effectiveness of the Security Department to address the current and emerging threats to
racing’s integrity. A summary of those recommendations is contained at pages 4 – 8.

Recommendation 1

A new Mission Statement, to include the principal strategic aims and objectives of the Security

Recommendation 2

The Jockey Club Security Department’s primary responsibility should be to police ‘The Orders
and Rules of Racing’; criminal offences are matters for the Police.

Recommendation 3

A more robust information strategy to be adopted by the Jockey Club to demonstrate how it
regulates racing and what it is doing to address issues which affect the integrity of racing.

Recommendation 4

A robust prevention and deterrence strategy to be created and implemented by the Security

Recommendation 5

Stable guards should remain Jockey Club staff.

Recommendation 6

The Security Department to continue to liaise closely with the operators of betting exchanges
with a view to combating current threats and to identify any emerging risks.

Recommendation 7

All those licensed or registered by the Jockey Club who hold an account with a bookmaker or
betting exchange should register that fact with the Jockey Club and such registration should
become a condition of the grant of a licence or registration.

Recommendation 8

Consideration to be given to a proposal to address the shortage of stables on some racecourses,
with an interim solution to create a designated secure compound to which horseboxes with
runners not allocated a stable are directed.

Recommendation 9

The Director of Security should remain a member of the Jockey Club Regulatory Board.
Recommendation 10

An additional post of “Head of Intelligence” to be created to co-ordinate the whole intelligence
function within the Department and to assist in liaison with other agencies.

Recommendation 11

A post of “Chief Investigator” to be created from within the existing posts.

Recommendation 12

The appointment of the new Director of Security should involve an open advertisement,
followed by a transparent selection process matching the accountabilities and job description of
the role against the qualities and abilities of the best candidate for the post.

Recommendation 13

A full user requirement for a computerised database for the Security Department at Jockey Club
Headquarters to be prepared.

Recommendation 14

Within the proper bounds of confidentiality, improvements to be made in the feedback
arrangements for those who have provided information to the Security Department.

Recommendation 15

The Security Department to review and rationalise its targeting policy to be consistent with its
Departmental aims and objectives.

Recommendation 16

Digital cameras to be issued to appropriate security staff and the effectiveness of existing covert
cameras to be reviewed.

Recommendation 17

Investigators should be de-briefed following a case, to identify and share good practice and
develop intelligence.

Recommendation 18

Personal notebooks to be issued with unique reference numbers and a record of issue.

Recommendation 19

Where Police decline to pursue a criminal investigation, consideration to be given to taking
action under the Rules of Racing.
Recommendation 20

The roles of the Racing Intelligence Officer and the Investigating Officer to be combined.

Recommendation 21

A new post of Betting Investigator to be created.

Recommendation 22

Stable guards to be properly briefed including consideration given to providing photographs and
identification details of excluded persons.

Recommendation 23

A designated point of contact to be established between stable guards on duty and other Security
Department staff.

Recommendation 24

All Security Department Operational Orders to be stored and accessed electronically.

Recommendation 25

The Chief Investigator to have responsibility for a fewer number of racecourses to compensate
for his additional supervisory role.

Recommendation 26

In addition to the current staff of the Central Intelligence Cell, the following new posts to be

. Head of Intelligence (a new post with the role possibly re-designated from within existing
staff – see Recommendation 10)
. Office manager/allocator
. Administrator/researcher
. Inputter/typist
. Betting analyst (current postholder retiring)
An additional post of Betting Investigator is also recommended.
Recommendation 27

Training for all posts within the Security Department should be reviewed; there is a pressing
need for formal induction courses and training in some specialist areas, like betting.
Recommendation 28

The Director of Security to review the arrangements for both executive and operational liaison
with other Departments of the Jockey Club and BHB and, in particular with:

• The Stewards and Stewards Secretaries and the Director of Regulation;
• The Licensing Department;
• The Disciplinary Department (including the Disciplinary Stewards and the Race Reader);
• Handicappers
• The Public Relations Department.
Whilst the principal focus of this recommendation refers to those personnel within the Jockey
Club, improved liaison with the BHB, particularly the Handicappers, would also be beneficial.

Recommendation 29

Formal executive liaison arrangements to be made between the Director of Security/Head of
Intelligence and the Chairman and General Manager of the NJPC.

Recommendation 30

The Director of Security to review liaison arrangements with the principal stakeholders in
horseracing and, in particular with:

• The National Trainers Federation;
• The Jockeys Association (GB);
• The Racehorse Owners Association;
• The Racecourse Association Ltd.
Recommendation 31

The Director of Security to review and enhance the liaison arrangements between the Security
Department and the bookmakers and betting exchanges.

Recommendation 32

In addition to reviewing the Department’s general liaison arrangements with the bookmakers and
betting exchanges, the Security Department actively to develop the initiatives for the exchange
of information that are currently taking place between it and the betting industry.

Recommendation 33

The Director of Security to develop closer executive liaison arrangements with HM Customs and
Excise, the Association of Chief Police Officers (ACPO) and the National Criminal Intelligence
Service (NCIS) to agree protocols for mutual operational co-operation.
Recommendation 34

Relevant information should be sought by the Security Department from the bookmakers and
betting exchanges to the fullest extent practicable under voluntary arrangements, pending
planned legislation establishing a Gambling Commission.

Recommendation 35

The Jockey Club Regulatory Board to review the position of the trainer when the jockey is found
in breach of the Rules in relation to non-tiers; that should include consideration of a “strict
liability” offence, and more severe penalties, including suspension in serious cases.

Recommendation 36

The Regulatory Board to consider amending Rules 241 and 236.


1.1 Background to the Security Review
1.1.1 The integrity of British Horseracing is crucial to the future success of a sport which
supports a multi-billion pound racing and betting industry.
1.1.2 Over the past five years the integrity of British horseracing has taken some severe
knocks. The arrests in 1998 and 1999 of five well-known jockeys and a prominent
trainer for alleged corruption offences, although all were subsequently cleared of any
criminal wrongdoing, sent shockwaves through the racing world.
1.1.3 In 2000 at Southwark Crown Court, five men were accused of conspiracy to defraud by
doping two race horses. The case collapsed at the end of the prosecution evidence when
the Judge directed that all five defendants should be acquitted of the criminal charges as
there was no case to answer. Subsequently three of the defendants were banned
indefinitely by the Jockey Club from setting foot on any British racecourse.
1.1.4 A further five criminal trials involving a global drug trafficking gang followed and,
during one of those trials at Woolwich Crown Court in 2000, serious allegations were
made about criminal involvement in horseracing, including claims of doping, money
laundering and other corrupt practices.
1.1.5 When reporting restrictions on these trials were lifted in June 2002, further damaging
allegations surfaced about the activities of a man, now wanted on an international arrest
warrant for serious criminal offences, in respect of corrupt practices within horseracing
linked with persons licensed by the Jockey Club.
1.1.6 Evidence given at the Woolwich trial by a well-known ex-jump jockey and passages in
his autobiography raised further serious concerns about alleged corrupt practices within
British Horseracing involving suspected criminals and persons licensed by the Jockey
Club. The jockey was subsequently banned by the Jockey Club for eight years. On
Appeal that was reduced to five years and a further Appeal to the High Court is in
1.1.7 In 2002 two high profile television programmes, the Kenyon Confronts “They Stop
Horses Don’t They?” and Panorama’s “The Corruption of Racing” made further serious
allegations about various corrupt practices within British Horseracing. The programmes
created much concern for those responsible for regulating horseracing in this country, for
Racing’s stakeholders, for racegoers and for the general public. Specifically, allegations
made within the Panorama programme that “racing is institutionally corrupt in some
respects” cast serious aspersions on the integrity and fairness of racing and the resolve of
those responsible for regulating racing to deal with the various issues involved. The
programmes served as a ‘wake-up call’ to all those involved in horseracing to address the
concerns and, where necessary, put its house in order. 1.2 The Regulation of Horseracing
1.2.1 Horseracing in Great Britain is self-regulating, with responsibilities for control shared
between The Jockey Club (the Regulating Authority) and the British Horseracing Board
(BHB) (the Governing Authority). The Jockey Club’s principal regulatory objective is to
maintain the integrity of horseracing by ensuring, as far as possible, the honest outcome
of every race. It licenses jockeys, trainers and racecourses, as well as registering all
stable employees and owners of racehorses. In its licensing role, the Jockey Club is a
non-statutory body and exercises a function in the public interest. The Jockey Club is
responsible for making and enforcing the Rules of Racing, policing the sport through its
disciplinary function. The licensing and disciplinary functions are supported by the
Club’s Security Department.
1.2.2 The Jockey Club works closely with the British Horseracing Board to fulfil their joint
responsibilities for controlling horseracing in Great Britain. Importantly, whilst
recognising that horseracing and betting are inextricably linked neither the Jockey Club
nor the BHB regulates betting on horseracing.
1.2.3 The Jockey Club’s integrity functions are largely funded by the Horserace Betting Levy
Board. The total grant for integrity in 2002/2003 was £16.4 million, covering the Jockey
Club and BHB Field Force (eg, stewards secretaries and handicappers), the Security
Department, the Racetech services (camera patrol, photo finish and starting stalls) and
the Horseracing Forensic Laboratory. The Security Department’s allocation from the
£16.4 million was £1.715m.
1.3 The Integrity Review Committee
1.3.1 The Jockey Club recognised the concerns about the integrity of horseracing following the
revelations in the drug gang trials and in July 2002 reconvened its Integrity Review
Committee to consider what action needed to be taken to address the concerns. The
members, terms of reference and recommendations of the Integrity Review Committee
are contained in Appendix G.
1.4 The Security Review Group
1.4.1 Following the Kenyon Confronts and Panorama programmes The Jockey Club and BHB
jointly agreed that a review of racing’s integrity and the Jockey Club’s Security function
should take place. In January 2003 the Joint Group under the independent chairmanship
of a retired Chief Constable began its work.
1.4.2 The membership of the Group is shown at Appendix A and its Terms of Reference at
Appendix B. The methodology and wide consultation process adopted by the Group is
shown at Appendix C.
1.4.3 The Group has received full co-operation from a wide cross-section of the principal
stakeholders in the racing and betting industries as well as helpful contributions from the
race-going public. The Group is indebted to all those who have assisted it in its work
including those bodies outside horseracing which have been consulted for comparative
analysis and elements of good practice (see also Appendix C).
1.5 Other Reviews
1.5.1 The Review has been conducted in the full knowledge that other important reviews and
activity affecting British Horseracing are in progress or have been completed, principally:
• The Government’s review of Gambling Legislation and, in particular, the proposals
for a new Gambling Commission;
• The BHB’s Racing Review;
• The Jockey Club’s proposals for an independent Regulatory Authority for British
• The Control Risks Group Security Review Report dated January 2002.
1.5.2 Where appropriate to the Terms of Reference of the Group, issues raised in those reviews
have been taken into account.
1.6 The Threats to the Integrity of Horseracing
1.6.1 All those consulted during this Review either during personal interview, or by
correspondence, have commented on the importance of the integrity and fairness of
British Horseracing.
1.6.2 The principal tasks for the Group under its Terms of Reference have been to identify:
(i.) What is the nature of the threats to the integrity of horseracing in Great Britain and
what are the breadth and depth of the various threats arising either from breaches of
the Rules of Racing or criminal activities?

(ii.) How best can the Security Department deal with threats to racing’s integrity?

1.6.3 A major difficulty facing the Group has been to identify and quantify the precise nature
of the threats to racing’s integrity, how to evidence them and whether the threats existed
in reality or in perception.
1.6.4 Although both the Kenyon Confronts and Panorama programmes raised important issues
about racing’s integrity and made allegations of corrupt practices, the principal criticism
of the programmes voiced by many people consulted was that, whilst compelling
viewing, the programmes presented their cases using selected interviews, information
provided by various sources and imputations of corruption with little firm evidence to
substantiate the serious allegations. As such, the potential damage done to the integrity
of horseracing , it was claimed, was more about a perception that racing was corrupt
rather than the reality.
1.6.5 This report seeks to clarify whether, in fact, the integrity and fairness of racing are
threatened and, if so, what should be done to address the issues.
1.6.6 Section 2 of this report deals, in detail, with “the threat”. Horseracing is principally a
sport enjoyed daily by millions of people. But it also supports an industry comprising
many different components including a multi-billion pound betting market. The
inextricable relationship between horseracing and betting is a crucial factor in considering
integrity issues. The sport would not survive in its current form without betting and the
level of betting is significantly dependent upon the public perception of the integrity of
racing and on the fair and honest outcome of each race.

1.6.7 Bookmakers have long had contacts within the racing world. Right or wrong, it can
create the impression that bookmakers are ‘in the know’ and enjoying insider information
which may undermine the confidence of punters in the sport. Mr Justice Gray dealt with
this issue in his judgement in the High Court in September 2002 in the case of The
Jockey Club and Roger Buffham, the BBC and The Chief Constable of the Greater
Manchester Police when he ruled that there was justified public interest in the proposed
Panorama programme covering:
(i.) The relationship between bookmakers, trainers, racing stables, jockeys and known
(ii.) Action taken by the Jockey Club in relation to corruption and the integrity of

(iii.) The integrity and fairness of racing and bookmaking in the UK; and
(iv.) The effectiveness of the Jockey Club’s role as a regulator of the sport and industry

of horseracing

1.6.8 The Judge, however, also recognised the difficulties associated with regulating and
monitoring the relationship between bookmakers and contacts in the racing world when
he said: “I have well in mind the inhibitions to which the Jockey Club feels itself to be
subject in cases where the evidence goes no further than to establish, for example, an
undesirable association between a jockey and bookmaker….”
1.6.9 The recent emergence of Betting Exchanges on which punters can “lay a horse to lose”
rather than “bet to win” adds a new dimension to the threat to racing’s integrity,
particularly when ‘inside or privileged information’ is available on a horse’s under
performance in a race. These issues are also fully discussed in Section 2.
1.6.10 Although the Jockey Club and its Security Department are principally concerned with
policing the integrity of racing, the strong view of many consulted in this Review, is that
each of the constituent elements of the sport and industry of horseracing has to share in
that responsibility.
1.6.11 Racing has been described to the Group as a large family, if sometimes a squabbling one.
However, the strength of a family is also a potential weakness, with vested interests
occasionally prejudicing common action or agreements for the greater good of the sport.
1.6.12 Understandably, perhaps, the threats to racing’s integrity are seen differently by the
various sections of the racing industry. One person’s ‘corruption’ may be seen by
another merely as ‘gamesmanship’. In any sport, it is recognised that there is an
acceptable level of ‘playing the rules’ to gain best advantage. In horseracing, owners,
trainers and jockeys are always susceptible to accusations of ‘bending the rules’ or ‘not
playing it straight’ if a horse does not run to form or runs badly. There are genuine
reasons why that can happen; equally the current handicapping system, for example, and
a trainer’s instructions and/or a jockey’s manner in riding a horse can be manipulated by
trainers or jockeys and possibly owners to affect the performance of a horse in a
particular race. The proposals in BHB’s racing review deal with handicapping issues in

1.6.13 Some see this activity as all part of the game, part of the mystique and charm of
horseracing and tend to view it as gamesmanship rather than corrupt practice particularly
if the motive, for example, is to secure some handicapping advantage for a future running
of the horse. However, that grey area becomes more focused when the reason for
affecting a horse’s performance is motivated by achieving some monetary gain,
especially when betting on or “laying” a horse is involved and privileged information is
available only to a few. That is viewed as corrupt practice and a clear threat to racing’s
1.6.14 The Group has explored the grey area between ‘gamesmanship’ and ‘corrupt practice’. It
has sought to identify those issues which impact on the integrity of horseracing and
recommended action to address the problems (Sections 2 and 4).
1.6.15 It is not the purpose of this Review to drop a “strait-jacket” over the sport and industry of
horseracing. Rather, our efforts have concentrated on identifying the threats to the
integrity of horseracing and recommending a proportional response to address the issues.
1.6.16 The allegation made in the Panorama programme that “racing is institutionally corrupt in
some respects” has been closely examined by the Group. Hard evidence to support that
damaging assertion is lacking. However, during the course of this Review a more subtle
version of that sweeping allegation has been made. It has been said that there has been a
corporate failure by the Jockey Club, the BHB and the other elements of the sport of
horseracing and the betting industry in that, knowing or reasonably suspecting that
activity by various people or sections of the industry was a threat to racing’s integrity,
little or nothing was done to address it. Those issues will also be covered in Sections 2-4.
1.7 The Security Department
1.7.1 The Review has closely examined the work of the Security Department of the Jockey
Club. Strengths and weaknesses in its structure and operational objectives have been
identified and are commented upon in Sections 2-5 and 7. Much of the backlash from the
television programmes fell unfairly on the Security Department. They were perceived as
the ‘whipping boys’ of the racing industry and the ‘achilles heel’ of the Jockey Club.
1.7.2 The Group judges that its recommendations on the structure, objectives and resourcing of
the Security Department will significantly enhance its ability to address the integrity
issues affecting horse-racing today and in the future.
1.8 The Importance of Integrity in Horseracing
1.8.1 Without action to address the integrity and fairness issues which this report identifies, the
sport of horseracing will be the poorer and the industry which surrounds the sport will
suffer. Certainly, integrity remains a top priority for those connected with the
governance, regulation and financing of horseracing.
1.8.2 In his foreword to the Jockey Club’s Annual Report for 2001-02, which marked the 250th
anniversary of the Jockey Club’s involvement in British racing, Christopher Spence, the
Senior Steward, wrote: “…Focusing on regulation, the past twelve months have again
highlighted the importance of ensuring the highest standards of integrity of our racing.”
He then rightly added: “The key issue cannot be the responsibility of the regulator alone,
all participants in the racing industry are able to play a part through their own conduct
in maintaining public confidence which is so vital for the prosperity of the sport.”

1.8.3 In the same report, Christopher Foster, Executive Director of the Jockey Club and Keeper
of the Match Book, wrote: “…These integrity issues are subject to constant evaluation,
upgrading and improvement made possible by the provision of funds from the Levy
Board, which itself, regards the financing of measures to safeguard the integrity of the
sport as its top priority…”.
1.8.4 The Chairman of BHB, Peter Savill, commenting on the recently published Racing
Review said: “I firmly believe that the structure that we have recommended is the
blueprint for the future health of British Racing in the 21st century. By putting in place a
true meritocracy the consumers’ faith in the integrity of our sport can be re-established.”
1.8.5 Following the Panorama programme, Tom Kelly, Chief Executive of the Association of
British Bookmakers (formerly Chief Executive of Betting Office Licensees Association),
said: “…Although horseracing and betting on it will sometimes attract the attention of
unscrupulous individuals, the sport overall has a high level of integrity which the betting
industry is committed to defend….”
1.8.6 The Government’s position is also unequivocal. In a statement in June 2002, the Rt Hon
Richard Caborn MP, Minister for Sport, said: “The Government takes very seriously the
importance of