The CAP code guidance on particular appeal to under 18s

 We expect society lottery operators to take care with the imagery and wording used in the content of scratchcards as well as in any associated marketing material. The ASA/CAP has published advice titled  [Gambling and lotteries guidance - protecting under-18s (opens in a new tab)](https://www.asa.org.uk/resource/protecting-children-and-young-people-gambling-guidance-2022.html)  and rulings that identify gambling ads that appeal particularly to under 18s. Content is considered to have ‘particular appeal to children or young persons’ if it is likely to appeal more to under 18s than to over 18s. The use of colourful and exaggerated cartoon-style graphics are likely to be considered to have particular appeal to under-18s, as are cartoon animals. Characters from, or similar to those from, children’s TV, films, nursery rhymes and fairy tales are similarly at risk of being particularly appealing to children.

 The names of games such as “Piggy Payout”, “Fluffy Favourites”, “Pirate Princess” and “Jack and the Beanstalk”, depending on the context, could also be seen to have particular appeal because they contain elements familiar to children and young persons which may contribute to their appeal to that group.

 The ASA has published a number of rulings that identify gambling adverts that appeal particularly to under 18s and which were subsequently banned. Operators should also have regard to these when designing lottery products.


 Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format  [contact us](/forms/formatrequest)  with details of what you require. It would help us to know what technology you use and the required format.

 **PDF Files**  Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in  [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/)  .

 [Lottery products and particular appeal to children advice

 application/pdf PDF 212.7 kB](//assets.ctfassets.net/j16ev64qyf6l/6qz2kxBzRNqMCfgKYwJmFQ/fc45b88916042fc8ccfb4f376fa187e9/Advice-on-use-of-imagery-on-lottery-scratchcards.pdf) [Joint letter: ASA and Remote Gambling Association

 application/pdf PDF 241.6 kB](//assets.ctfassets.net/j16ev64qyf6l/1XEiD65ojh7dtMzNLKStnK/71464504f25f5054ee245af1362a6056/Ltr-from-ASA-CAP-CG-RGA-final.pdf)

---

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* [Lottery products and particular appeal to children](#)
* [The rules](#the-rules)
* [The CAP code guidance on particular appeal to under 18s](#the-cap-code-guidance-on-particular-appeal-to-under-18s)

 [Print this guide](#)


>  This is an HTML version of this advice. You can also view or download the  [original External Lottery Managers advice (PDF)](#1fMVw9kmwZB2NyaKW4VPzD)  published in September 2014, updated July 2020.
>
>


 The purpose of this note is to provide advice to External Lottery Managers (ELMs), society and local authority lotteries and others about the requirements of the  [Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents)  (the Act) relating to ELMs.

 The interpretation of the Act is ultimately a matter for the courts but it is hoped that this advice note will be helpful to ELMs, societies and local authorities in understanding the requirements and the Gambling Commission’s approach in respect of compliance with those requirements.

 This note also contains some advice supplementary to the requirements of the Act, relevant regulations and the  [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp/online)  . For further information see  [Promoting society and local authority lotteries](/licensees-and-businesses/guide/promoting-society-and-local-authority-lotteries)  and the conditions and codes attached to your licence.

 We may update this advice from time to time to reflect developments in the sector.

##  What is an ELM?

##  Licensing requirements

##  The purpose of society and local authority lotteries

##  The relationship between ELMs and society and local authority lotteries

##  The licence conditions and codes of practice relating to ELMs

##  Proceeds and profits - ELMs

##  Non-compliance

##  Footnotes

##  Files


 Lotteries within Great Britain are the preserve of good causes and as such the Act did not intend ELMs to be primarily a vehicle to create profit for commercial organisations; rather, the intention was to enable societies and local authorities to raise funds for their own non-commercial purposes.

 An ELM is defined in  [section 257 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/257)  as someone that makes arrangements for a lottery on behalf of a society or local authority but is not a member, officer or employee of the society or local authority. A society or local authority and an ELM must be separate entities and be able to demonstrate that they are independent of each other.

 To this end the Commission would not consider ELMs to be independent if, for example, a director or employee of an ELM was also a trustee, director, employee or member of the society whose lottery they are promoting.  The Commission might not also consider the ELM and society to be independent if, for example, a director or employee of an ELM was closely connected to someone (e.g. a family member or personal friend or associate) who was a trustee, director orindividual holding a strategic decision making role within the society whose lottery the ELM is promoting.

 The Act allows societies and local authorities to employ ELMs to manage all or part of their lotteries so that societies and local authorities may benefit from the experience or economies of scale that come with employing an ELM.

 Under  [section 252 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/252)  , a person promotes a lottery if they make or participate in making the arrangements for a lottery. It states further that a person promotes a lottery in particular if they:

* make arrangements for printing of tickets
* make arrangements for the printing, publication and distribution of promotional material  [1](#1)
* make arrangements to advertise a lottery
* invite an individual to participate in a lottery
* sell or supply tickets
* offer to sell or supply tickets
* use premises for the purpose of allocating prizes or for any other purpose connected with the administration of a lottery.

 Under  [section 258 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/258)  a person commits an offence if they carry out any of these activities on behalf of a society or local authority unless they:

* are an officer, employee or a member of a licensed or registered society or local authority
* are a licensed ELM directed by a society or local authority to run all or part of its lottery.

 A person also commits an offence if they facilitate a society or local authority lottery unless they act in accordance with an operating licence. Under  [section 259 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/259)  a person facilitates a lottery if they:

* print lottery tickets for a specified lottery
* print promotional material for a specified lottery
* advertise a specified lottery.

 Uncertainty can arise as to whether services provided to societies or local authorities amount to the promotion or facilitation of a lottery or to the provision of services which do not amount to promotion or facilitation. The Commission’s advice note  [Promoting society and local authority lotteries](/licensees-and-businesses/guide/promoting-society-and-local-authority-lotteries)  gives further guidance on the distinctions between the two, but anyone who is uncertain whether the services provided require the provider to hold an ELM licence should contact the Commission for further guidance.


 An ELM must hold a lottery manager operating licence issued by the Commission before they can promote a society or local authority lottery. The ELM (and the relevant society or local authority) will also need to hold a remote gambling licence if they intend to sell tickets by means of remote communication (eg internet, telephone etc).

 It is the responsibility of both the society (or local authority) and the ELM to ensure that the other party holds the relevant operating licence(s) before they enter into any arrangements regarding the promotion of lotteries.

 Unless an ELM qualifies as a small scale operator (SSO)  [2](#2)  ,  individuals holding key management positions at an ELM may be required to hold a Personal Management Licence (PML) - this may be the managing director, chief executive, finance director, compliance manager, marketing manager and IT manager.

 The Commission expects all licensed operators to put in place people and systems to enable them to be compliant with the Act and licence conditions. In general the function of regulatory compliance should be assumed by one individual who will have overall responsibility for ensuring compliance. For large scale operators the person holding responsibility for compliance should have no other function in order to ensure they can carry out their role without the potential for any conflict of interest. The Commission understands and accepts that this may not always be possible for small scale operators who have few employees able to hold key management positions.


The purpose of society and local authority lotteries

 The intention of the Act is to allow non-commercial societies to use a lottery as a means of raising funds from the public for the cause promoted by the society or for the local authority to raise funds for any purpose for which they have the power to incur expenditure. The provisions are relatively limited in scope. It is not the intention of the Act to allow society or local authority lotteries to be promoted for private or commercial gain although it is accepted that an ELM is a commercial business that usually exists to produce a commercial profit.

 The proportion of the proceeds of a lottery that are distributed for the purposes of the society or local authority are called the ‘profits’ (see section 7 - Proceeds and profits, and the Commission’s advice note  [Lottery proceeds, April 2013](/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020)  for further information. Each society or local authority lottery must return a minimum of 20% of the proceeds to the purposes of the society or local authority.

 Under  [section 260 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/260)  it is an offence to use any part of the ‘profits’ of a lottery for a purpose other than that stated by the society or in the promotional material.  [Section 261 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/261)  applies the same offence to small society lotteries.

 Under  [section 254 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254 )  , alongside the profits, the proceeds of a lottery will be split between the payment of prizes and paying reasonable expenses. The expenses can include a payment to an ELM in respect of the services provided in respect of promotion of the lottery. However, that payment must be proportionate and reflect the lawful status of the lottery as a means of raising funds to support a non-commercial society or local authority. The promoting society or local authority must ensure any fees paid to an ELM constitute an expense reasonably incurred organising the lottery.


The relationship between ELMs and society and local authority lotteries

 As highlighted in  [section 257 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/257)  the Act allows a society or local authority lottery to employ an ELM to manage all or part of its lottery on its behalf. The intention of these provisions is relatively limited in scope: they are designed to do nothing more than to allow a society to ‘outsource’ the running of a lottery to a third party.

 The fact that a society or local authority may employ a licensed ELM to manage all or part of its lottery does not absolve the society or local authority from its responsibility for ensuring that the lottery is conducted in such a way as to ensure that it is lawful and fully compliant with the Act, related regulations and all licence conditions and codes of practice.

 Under  [section 252(4) of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/252#:~:text=252Promoting%20a%20lottery&text=(4)Where%20arrangements%20for%20a,or%20authority%20promote%20the%20lottery.)  , where an ELM is employed to make the arrangements for all or part of the lottery including paying prizes and the expenses, the society or the local authority is equally responsible, with the ELM, for the lawful distribution of the proceeds.

 This includes the mandatory requirement to return a minimum of 20% of the proceeds of any lottery promoted to the purposes for which the promoting society is conducted or the local authority has the power to incur expenditure (for further information, refer to the Commission’s advice note  [Lottery proceeds, April 2013](/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020)  .

 If an ELM (or a service provider) is involved in the distribution of the proceeds, the Commission expects that they agree with the society or local authority in advance about how they will be distributed. This should include discussing and agreeing the prize structure, and ensuring that any expenses are reasonably incurred. If involved in the distribution of the profits of a lottery (ie the proportion returned for the purposes of the society or local authority), this must be done in accordance with terms agreed with the society or local authority and in accordance with the society’s or local authority’s purpose. The society or local authority must always retain overall control of the distribution of profits.


The licence conditions and codes of practice relating to ELMs

 All ELMs licensed by the Commission to run lotteries on behalf of societies and local authorities are required to comply with specific conditions and codes of practice relevant to them. The specific licence conditions are set out at the time a licence is issued and are printed on the licence.

 Some of the licence conditions and codes of practice applicable to ELMs are referred in the following paragraphs. Specific details are contained in the  [Licence conditions and codes of practice](/licensees-and-businesses/lccp/online)  .

###  Protection of customer funds and lottery proceeds

 There are a number of requirements on ELMs in relation to protecting customer funds as well as the proceeds of lotteries by putting ‘ring-fencing’ in place. In relation to customer funds the LCCP requires that:

* ‘Licensees who hold customer funds must ensure that these are held in a separate client bank account or accounts’  [Condition 4.1.1 of the Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/condition/4-1-1-segregation-of-funds)
* ‘Licensees who hold customer funds must set out clearly in the terms and conditions under which they provide facilities for gambling information about whether customer funds are protected in the event of insolvency, the level of such protection and the by which this is achieved.

 Such information must be according to such rating system and in such form the Commission may from time to time specify. It must be provided in writing to each customer, in a manner which requires the customer to acknowledge receipt of the information and does not permit the customer to utilise the funds for gambling until they have done so, both on the first occasion on which the customer deposits funds and on the occasion of any subsequent deposit which is the first since a change in the licensee’s terms in relation to protection of such funds.  [Condition 4.2.1 of the Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/condition/4-2-1-disclosure-to-customers)  .

 The LCCP also sets out a definition of customer funds.

 For lottery proceeds, the following applies: ‘Licensees must have arrangements in place to ensure separation between lottery proceeds they hold on behalf of non-commercial societies or local authorities and their own trading income and that such lottery proceeds are legally protected by means of separate bank accounts having trustee status or equivalent legal protection for each society or local authority in the event of the licensee’s insolvency, in which event the proceeds will be paid to the society or local authority.’  [Condition 11.2.1 of the Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/condition/11-2-1-lotteries-managers)  .

 The second part of the previous paragraph is specific to ELMs who hold the proceeds of a lottery on behalf of a society or local authority prior to or following a lottery draw. It is vital for an ELM to understand that the proceeds of any lottery are proceeds belonging to the society or local authority and that they are holding those funds in trust on behalf of those entities. The Commission places particular importance on the ELM having sufficient arrangements in place to protect those funds (the proceeds) for the society or local authority to ensure that they are not used for any purpose other than that which the Act permits and that they are protected in the event of the ELM’s insolvency or any claim on the ELM’s financial reserves.

 [Section 254 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254)  defines ‘proceeds’ as ‘the aggregate of amounts paid in respect of the purchase of lottery tickets’. The Commission’s view is that if monies are committed/appropriated to the purchase of a ticket in a specific lottery draw, then the monies are likely to be ‘proceeds’. If monies are held in an account before being ‘allocated to a gamble’ (a lottery) then the monies are likely to be customer funds. For example, monies paid in advance by those wishing to partake in lotteries are customer funds until they are committed/appropriated to the purchase of a lottery ticket in a particular draw and thereafter lottery proceeds within the definition in section 254(1). Lottery proceeds also have the potential to revert to being customer funds in the event the draw does not take place, or in the event the subscription is cancelled and where the stake is refunded to the participant.

###  Social responsibility

 Lotteries are a form of gambling and as such ELMs are required to ensure that children and other vulnerable people are not harmed or exploited by the lotteries they manage. Societies and local authorities have the same requirements placed on them.

 The minimum age for participation in a society or local authority lottery is 16 years. A person commits an offence if they invite or allow a child (someone under the age of 16) to enter such a lottery. ELMs, licensed societies and local authorities must have written policies and procedures in place to help prevent and deal with cases of under-age play. They must be able to evidence how these procedures and policies are applied to mitigate any risk to the licensing objectives  [3](#3)  .

 Licence holders must take all reasonable steps to ensure that information about how to gamble responsibly and how to access information and help in respect of problem gambling is readily available, and all marketing material for the lottery must display the begambleaware logo (including a link to the begambleaware website in the case of electronic material).

 All licence holders are required to make a contribution to research, education and treatment in relation to problem gambling. ELMs, licensed societies and local authorities should ensure this provision is met either directly or through membership of a trade body that makes a donation to a recognised organisation on behalf of its members. A licensed society must meet this provision and it can be rightly included as an expense of the lottery or can be taken from other non-lottery financial reserves.

 ELM’s are also required to make a contribution but it cannot form part of the expenses of a lottery although in the Commission’s view it is permissible for the funds to come from the part of the expenses paid to the ELM by the society for providing their services. While the Commission does not specify the recipient or the amount of the contribution, many licensees choose to make a donation to the Responsible Gambling Trust, based on a percentage of their gross gambling yield.

>  Further information about social responsibility requirements is available in the Commission’s  [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp/online)  . You can also download sector-specific extracts from the LCCP.
>
>

###  Regulatory returns

 [Licence condition 15.3](/licensees-and-businesses/lccp/condition/15-3-1-general-and-regulatory-returns)  requires that all ELMs submit an annual regulatory return to the Commission. The return must be submitted within 42 days of the end of the annual business period. This must contain all of the necessary information requested by the Commission and is best submitted securely online.

 Where the ELM makes the arrangements for any part of the lottery they must record the proportion of the proceeds of the lottery generated by the ELM’s activity and include this in their regulatory return, together with details on the annual managed proceeds split by product type. In some circumstances, the ELM may need to request this information from the society.

 For example, if the ELM is only ‘making arrangements’ in respect of one aspect of the lottery campaign such as direct mail, the ELM is only required to report the proceeds generated by that aspect of the lottery.

###  Lottery Submissions

 The licence conditions attached to all lottery operating licences include a requirement that in respect of each lottery promoted a submission must be sent to the Commission within three months of the date of the lottery, showing the total proceeds and how they have been distributed. It is the responsibility of the society and the ELM to ensure that any lottery submission made in respect of the distribution of the proceeds of a lottery is a true and accurate reflection of how those proceeds have been distributed.

 Where the ELM is instructed by a society to make lottery submissions on its behalf the ELM must ensure that the society approves every submission before it is made.

###  Information to lottery players: proceeds and prizes

 Social responsibility codes attached to all lottery operating licences include a requirement to take account of the Commission’s guidance on providing information to lottery players about how proceeds are used and the likelihood of winning a prize and how those prizes are allocated. This information must be available prior to participating in a lottery.

 Further information about these requirements can be found in the Commission's guidance  [Information to lottery players: proceeds and prizes](/licensees-and-businesses/guide/information-to-lottery-players-proceeds-and-prizes)  .


 [Section 254 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254)  clarifies what is meant by ‘proceeds’ and ‘profits’ of a lottery. It defines proceeds as ‘the aggregate of amounts paid in respect of the purchase of lottery tickets’. This means that proceeds are the total amount paid for tickets before any deductions.

 Profits are defined as the amount of proceeds less any deductions for prizes, rollovers and reasonable expenses incurred in connection with running the lottery.

 [Section 99(2) of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/99 )  of the Act specifies the way in which the proceeds of a lottery must be distributed, as follows: ‘The first requirement is that at least 20% of the proceeds of any lottery promoted in reliance on the licence are applied:
 **a)**  in the case of a licence issued to a non-commercial society, to a purpose for which the promoting society is conducted
 **b)**  in the case of a licence issued to a local authority, for a purpose for which the authority has power to incur expenditure’.

 In addition to profits the proceeds can only be used to:

* provide prizes
* pay expenses ‘reasonably incurred’ organising the lottery.

 Further information regarding lottery proceeds can be found in the Commission’s advice note  [Lottery proceeds, April 2013](/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020)  .


 The Commission requires all lottery operators to comply with the licensing objectives of the Act and treats any breach of the licence conditions very seriously. In circumstances where either a breach of the Act or the licence conditions occurs the Commission will consider what criminal or regulatory action it needs to take. That could include a review of the ELM’s operating licence, which could result in a formal warning, additional licence conditions, a financial penalty or suspension or revocation of the operating licence. Further details can be found in the Commission’s  [Licensing, compliance and enforcement policy statement](/policy/licensing-compliance-and-enforcement-under-the-gambling-act-2005)  .

 In circumstances whereby the ELM has been deemed to have committed a breach of the Act or the licence conditions the Commission may also consider taking action against the society or societies they promote lotteries for. This would be the case where the society was deemed to have failed to ensure that the lottery was conducted in such a way as to ensure that it was lawful and fully compliant with the Act, related regulations and all licence conditions and codes of practice.


 1  Promotional material is defined as a document that advertises, invites participation, contains information about how to participate, or lists winners, in a particular lottery.

 2  A gambling operator qualifies as an SSO unless there are four or more persons who have responsibility for any of the key functions.

 3  Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime; ensuring gambling is conducted in a fair and open way; protecting children and other vulnerable persons from being harmed or exploited by gambling  [(Section 1 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/1)  .


 Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format  [contact us](/forms/formatrequest)  with details of what you require. It would help us to know what technology you use and the required format.

 **PDF Files**  Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in  [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/)  .

 [External lottery managers advice

 application/pdf PDF 367.5 kB](//assets.ctfassets.net/j16ev64qyf6l/1fMVw9kmwZB2NyaKW4VPzD/73135deafd36822ed825e144139bc842/External-lottery-managers-advice.pdf)

---

 Last updated: 7 June 2021

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* [External Lottery Managers](#)
* [What is an ELM?](#what-is-an-elm)
* [Licensing requirements](#licensing-requirements)
* [The purpose of society and local authority lotteries](#the-purpose-of-society-and-local-authority-lotteries)
* [The relationship between ELMs and society and local authority lotteries](#the-relationship-between-elms-and-society-and-local-authority-lotteries)
* [The licence conditions and codes of practice relating to ELMs](#the-licence-conditions-and-codes-of-practice-relating-to-elms)
* [Proceeds and profits - ELMs](#proceeds-and-profits-elms)
* [Non-compliance](#non-compliance)

 [Print this guide](#)


4.3.1 - Publication of percentage of lottery proceeds returned to the purposes of the society or local authority

 Applies to:

 All lottery operating licences issued to non-commercial societies and local authorities

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator’s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Each year, licensees must publish details on the percentage of the total proceeds of lotteries promoted in the previous calendar year in reliance on this licence applied to purposes for which the society is conducted, or purposes for which the local authority has power to incur expenditure. This should be through either their annual report, lottery page of their society website or any other means appropriate to the size and scale of the organisation.


>  Lotteries in Great Britain can only be promoted by charities, other good causes and local authorities. They cannot be promoted for private or commercial gain.
>
>

 Each society or local authority lottery must return a minimum of 20% of the proceeds to the purposes of the society or local authority (the good cause). They must also provide consumers with information about the proportion of lottery proceeds (ticket sales) returned to good causes or for local authority expenditure, in a calendar year.

 Read our guidance for  [Promoting society and local authority lotteries](/licensees-and-businesses/guide/promoting-society-and-local-authority-lotteries)  .


Our advice on  [promoting multiple society lotteries](/licensees-and-businesses/guide/promoting-multiple-society-lotteries)  provides advice about some of the factors we are likely to take into account when making decisions about whether the requirements of the Gambling Act 2005 are satisfied in a particular lottery scheme. It contains advice supplementary to the requirements of the Act, relevant regulations and the Licence conditions and codes of practice. It also provides more information on what constitutes a branded lottery scheme, and what operators are required to do when promoting lotteries through such schemes.


 Society lotteries and external lottery managers (ELMs) that wish to promote individual society lotteries under one umbrella brand must ensure those lotteries are not combined to form one single lottery, which could be a breach of the requirements of the Gambling Act 2005 and relevant regulations.

 They must also ensure that consumers are provided with sufficient information for them to make an informed choice as to whether they wish to support that good cause or not. It must be clear to consumers that although there is a common brand, they are participating in individual society lotteries; and which lottery they are participating in. There should therefore be information about the promoting society available in any marketing or advertising material.

 [Offering lottery, gaming and betting products under common branding](/licensees-and-businesses/guide/offering-lottery-gaming-and-betting-products-under-common-branding-june-2012)  provides advice to lottery promoters and others about the principles we use in licensing and regulating those who wish to combine the promotion of lotteries with provision of facilities for other types of gambling.


Promoting your lottery in countries outside of Great Britain

 The Gambling Act 2005 neither permits nor prohibits a lottery lawfully promoted in Great Britain from being promoted in another country. Great Britain is England, Scotland and Wales.

>  Northern Ireland, the Channel Islands and the Isle of Man have their own gambling laws.
>
>

 If you promote a lottery in Great Britain and would like to promote it in another country, including sending tickets, application forms or any other information about the lottery (by a website or by email, post, telephone or other means) you should contact the relevant authorities in that country first to see what is allowed and if there are any special requirements.

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 Applies to:

 All remote casino, bingo and betting licences other than ancillary licences and remote betting intermediary (trading room only) licences

 1 All gambling software  [1](#221-1)  used by the licensee must have been manufactured by the holder of a gambling software operating licence. All such gambling software must also be supplied to the licensee by a holder of a gambling software operating licence. Such software must only be installed or adapted by the holder of such a licence.

##  References


1  As defined in section 41(2)&(3) of the Act


Risk of privacy screens around gaming machines

 A screen or pod around a gaming machine, designed to increase the privacy of the player, could be stopping your staff from effectively monitoring gaming machine play.

>  It is your responsibility to ensure your staff are able to effectively monitor gaming machine play for a number of reasons that are part of your licence conditions.
>
>

 The  [Licence conditions and code of practice (LCCP)](/licensees-and-businesses/lccp/online)  state:

 ‘Facilities for gambling must only be offered in a manner which provides for appropriate supervision of those facilities by staff at all times’.

 Age verification, customer interaction and self-exclusion policies all require you to take into account the structure and layout of your gambling premises.

 You must be able to evidence to us and your local licensing authority how you have considered the risk to the licensing objectives and implemented effective controls, prior to the introduction of any new machine arrangements.

 Where you are unable to demonstrate effective controls we, or the LA, can use regulatory powers to instruct the removal of any impediments to staff carrying out their responsibilities and investigate any regulatory breaches.

 Commercial motivations should never take precedence over the requirement to provide gaming machines in a safe and responsible manner.


 Where you encounter atypical gaming machine arrangements, you should consider the means by which gaming machines are supervised (eg line of sight to counter, effective CCTV, mirrors or floor staff) and consider whether that is appropriate for that premises.

 Whether amendments to a premises amount to a ‘material change’ warranting an application to vary the premises licence under  [section 187 of the Gambling Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/187 )  is a matter for local determination and it is expected a common sense approach should be adopted. There is more information in  [section 7.51 of the Guidance to licensing authorities](/guidance/guidance-to-licensing-authorities/part-7-application-for-premises-variation-s-187-material-change)  .

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 Last updated: 14 June 2021

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 Applies to:

 All operating licences except gaming machine technical, gambling software and host licences

1. Licensees, as part of their internal controls and financial accounting systems, must implement appropriate policies and procedures concerning the usage of cash and cash equivalents (eg bankers drafts, cheques and debit cards and digital currencies) by customers, designed to minimise the risk of crimes such as money laundering, to avoid the giving of illicit credit to customers and to provide assurance that gambling activities are being conducted in a manner which promotes the licensing objectives.
2. Licensees must ensure that such policies and procedures are implemented effectively, kept under review, and revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time.


 Applies to:

 All gaming machine general operating licences for adult gaming centres and family entertainment centres

1. Licensees must neither:
	1. provide credit themselves in connection with gambling; nor
	2. participate in, arrange, permit or knowingly facilitate the giving of credit in connection with gambling.


 Applies to:

 All non-remote general betting licences (except where betting is offered under a 2005 Act casino premises licence), pool betting licences and all remote licences (including ancillary remote betting licences), except gaming machine technical, gambling software, host, ancillary remote casino, ancillary remote bingo and remote betting intermediary (trading rooms only) licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator’s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees who choose to offer credit to members of the public who are not themselves gambling operators must also:
	1. have procedures for checking and scoring applications for credit from such customers, for setting, and for the increase of, credit limits
	2. explain these procedures to customers
	3. set a maximum credit limit for each customer and not permit customers to exceed that limit without further application
	4. apply a 24-hour delay between receiving a request for an increase in a credit limit and granting it in those cases where the limit exceeds that which the operator previously set
	5. not require a minimum spend within a set time period
	6. take all reasonable steps to ensure that offers of credit are not sent to vulnerable persons, including those who have self-excluded from gambling
	7. ensure that information about an offer of credit includes a risk warning of what may happen in the event of default.


 Lotteries are a form of gambling and as such societies and local authorities are required to ensure that children and other vulnerable people are not exploited by their lottery.

 The minimum age for participation in a society or local authority lottery is 16 years of age. A person commits an offence if they invite or allow a child to enter such a lottery. Licensed societies and local authorities running lotteries must have written policies and procedures in place to help prevent and deal with cases of under-age play.

 Licence holders must take all reasonable steps to ensure that information about how to gamble responsibly and how to access information and help in respect of problem gambling is readily available.

 Further information about social responsibility requirements is contained in the Commission’s  [Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/online)  .

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 Applies to:

 All licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator’s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees must have and put into effect policies and procedures intended to promote socially responsible gambling including the specific policies and procedures required by the provisions of section 3 of this code.
2. Licensees must make an annual financial contribution to one or more organisation(s) which are approved by the Gambling Commission, and which between them deliver or support research into the prevention and treatment of gambling-related harms, harm prevention approaches and treatment for those harmed by gambling.


LCCP RET list: Procedure and guidance for removal of organisations

 The purpose of this guidance note is to reiterate the requirements and expectations for organisations on the LCCP RET list for research, prevention and treatment, and clarify the circumstances, criteria and process for removing organisations from the list.

##  Background - LCCP RET list procedure and guidance for the removal of organisations

##  Requirements for operators

##  Requirements for organisations on the LCCP RET list

##  By accepting RET contributions from licensed operators, organisations on the LCCP RET list commit to:

##  Approach - LCCP RET list procedure and guidance for the removal of organisations

##  Removal from the LCCP RET list

##  Process

##  Appeals

---

 Last updated: 30 July 2021

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Background - LCCP RET list procedure and guidance for the removal of organisations

 On 1 January 2020 a new LCCP requirement came into force requiring operators to direct their annual financial contribution for gambling research, prevention and treatment (referred to as RET for shorthand) as required by  [LCCP SR code 3.1.1](/licensees-and-businesses/lccp/condition/3-1-1-combating-problem-gambling)  to one or more organisations on a  [list maintained by the Commission](/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions)  .

 This change was a result of the Commission’s review of the RET arrangements in February 2018 which concluded that the current voluntary system was falling short of its objectives. The Commission was concerned that RET contributions were disparate and uncoordinated and that some recipients of RET contributions had no clear link to the research, prevention or treatment of gambling harms. To address this the Commission committed to improving the transparency of the amounts and destinations of RET funding, with a specific commitment in relation to LCCP and following a public consultation the amended SR code came into force.


 The purpose of the LCCP RET list is to demonstrate to operators how to be compliant with the LCCP requirement to make annual financial contributions to research, prevention and treatment.

 Operators must:

* make an annual financial contribution to each of research, prevention and treatment
* ensure that these donations go to one or more organisation on the LCCP RET list
* ensure that they have no connection to the recipient organisation
* report information accurately in their annual or quarterly regulatory return to the Commission about the destination(s) of their payment and the amounts that have been contributed. This includes ensuring that there is no duplication of data across multiple licences.


By accepting RET contributions from licensed operators, organisations on the LCCP RET list commit to:

* using contributions solely for the purpose of reducing gambling harms
* working within the structures of the Strategy to engage with people with lived experience
* providing information as requested to support the coordination and delivery of actions under the Strategy.

 Collaborating under the National Strategy to Reduce Gambling Harms to:

* prioritise actions
* coordinate activity
* minimise duplication or conflict of activity.

 Upholding the principles of the Strategy by taking:

* an evidence-based approach
* evaluating impact
* supporting transparency.

###  Organisations on the LCCP RET list are also expected to:

* work with the Gambling Commission in an open and cooperative way and inform the Commission of anything that could have a significant impact on the nature or structure of their organisation
* not interpret being on the LCCP RET list as approval or endorsement by the Gambling Commission nor refer to the Commission approving or endorsing their organisation in any promotional or publicity materials
* not have industry representatives on their boards or in other roles that have decision-making powers
* provide data on the amount of LCCP RET contributions received, which operator(s) they relate to, and when the contribution(s) were made
* provide information about changes to the information outlined above to the Gambling Commission as soon as reasonably possible.


Approach - LCCP RET list procedure and guidance for the removal of organisations

 The Gambling Commission commits to working with organisations on the LCCP RET list in an open, supportive and transparent manner. Any investigations into possible removal from the LCCP RET list will be conducted fairly and openly and organisations whose status on the LCCP RET list is under consideration will be given the opportunity to review and comment on their potential removal before a final decision is made.

 We expect organisations on the LCCP RET list to also be open and transparent with the Commission and to alert us as soon as possible to any potential issues which may affect their status on the LCCP RET list, including any formal investigations.


 Organisations on the LCCP RET list must inform the Commission of anything that could have a significant impact on the nature or structure of their organisation. Any misrepresentation or failure to reveal information may be deemed sufficient cause for the organisation to be refused or removed from the list of organisations to which gambling businesses may make financial contributions in order to meet the LCCP RET requirement.

 Examples of criteria which would undermine the aims and objectives of the LCCP RET list and would result in review and likely removal from the list include (but are not limited) to the following:

* going into administration or equivalent, or criminal charges being laid, the nature or circumstances of which give the Commission cause for concern (such as theft or fraud)
* an investigation by a professional, statutory, regulatory or government body into their activities and/or removal of their independent oversight (e.g. Charity Commission or CIC status)
* changes in key personnel or circumstances which means the organisation is no longer commissioning or delivering research, prevention or treatment to reduce gambling harms
* failure to provide information when requested (e.g. data on RET contributions)
* evidence of a persistent refusal to engage collaboratively with other stakeholders and partners
* complaints by other organisations, service users or others where there is evidence to suggest serious concerns
* mergers or takeovers, LCCP RET list status cannot be transferred to another organisation and a new request must be submitted.


 Where there is evidence of a serious concern which may compromise the aim of the LCCP RET list, call into question an organisation’s suitability to be on the RET list, or an issue that could have a significant impact on the nature or structure of an organisation on the list, the Gambling Commission will undertake an internal review as follows:

* the Gambling Commission will convene a review panel comprising members of the Social Responsibility Funds Group
* Gambling Commission officials will compile a summary of the issue(s) identified, along with any relevant documents, setting out the evidence and concerns
* the organisation under review will be given sight of these papers and will be given the opportunity to provide any written representations and any relevant supporting information that they would like the panel to consider
* the review panel will consider the papers and any representations or additional documents provided by the organisation and reach a decision accordingly. A decision letter will be sent to the applicant as soon as practicable after the decision has been made.

>  An organisation that is removed from the LCCP RET list will not to be prevented from applying to rejoin the RET list again, but the Commission may take account of any previous decision that has been made when assessing the application.
>
>


 If an organisation wishes to appeal a decision made by the review panel for removal from the list, the following appeals process will apply:

* notification of the wish to appeal must be sent to  [SRFunds@gamblingcommission.gov.uk](mailto:SRFunds@gamblingcommission.gov.uk)  within 28 days of the date the decision letter was issued
* the Gambling Commission will convene an appeal panel comprising at least one Executive Director (or higher) who will have had no involvement with the decision under appeal
* Gambling Commission officials will compile a pack of papers, comprising the original papers that were considered by the review panel, any representations and additional documents that were submitted by the organisation, and the decision under appeal, as well as any further documents that may be relevant to the case
* the organisation making the appeal will be given sight of these papers and will be given the opportunity to provide any further representations or additional documents they would like the appeal panel to consider as to why the original decision was wrong
* the Appeal panel will consider the papers and any representations or additional documents provide by the organisation and reach a decision accordingly. A decision letter will be sent to the organisation as soon as practicable after the decision has been made.


* [LCCP RET list: Procedure and guidance for removal of organisations](#)
* [Background - LCCP RET list procedure and guidance for the removal of organisations](#background-lccp-ret-list-procedure-and-guidance-for-the-removal-of)
* [Requirements for operators](#requirements-for-operators)
* [Requirements for organisations on the LCCP RET list](#requirements-for-organisations-on-the-lccp-ret-list)
* [Approach - LCCP RET list procedure and guidance for the removal of organisations](#approach-lccp-ret-list-procedure-and-guidance-for-the-removal-of)
* [Removal from the LCCP RET list](#removal-from-the-lccp-ret-list)
* [Process](#process)
* [Appeals](#appeals)

 [Print this guide](#)


3.5.2 - Self-exclusion – non-remote ordinary code

 Applies to:

 All non-remote licences and remote betting intermediary (trading rooms only) licences, but not gaming machine technical and gambling software licences

 **Ordinary code**  These do not have the status of operator licence conditions but set out good practice. Operators may adopt alternative approaches to those set out in ordinary code provisions if they have actively taken account of the ordinary code provision and can demonstrate that an alternative approach is reasonable in the operator's particular circumstances; or that to take an alternative approach would be acting in a similarly effective manner. Ordinary codes of practice are admissible in evidence in criminal or civil proceedings and must be taken into account in any case in which the court or tribunal think them relevant, and by the Commission in the exercise of its functions; any departure from ordinary code provisions by an operator may be taken into account by the Commission on a licence review, but cannot lead to imposition of a financial penalty.

1. Self-exclusion procedures should require individuals to take positive action in order to self- exclude. This can be a signature on a self-exclusion form.
2. Individuals should be able to self-exclude without having to enter gambling premises.
3. Before an individual self-excludes, licensees should provide or make available sufficient information about what the consequences of self-exclusion are.
4. Licensees should take all reasonable steps to extend the self-exclusion to premises of the same type owned by the operator in the customer’s local area. In setting the bounds of that area licensees may take into account the customer’s address (if known to them), anything else known to them about the distance the customer ordinarily travels to gamble and any specific request the customer may make.
5. Licensees should encourage the customer to consider extending their self-exclusion to other licensees’ gambling premises in the customer’s local area.
6. Customers should be given the opportunity to discuss self-exclusion in private, where possible.
7. Licensees should take steps to ensure that:

- the minimum self-exclusion period offered is of a duration of not less than 6 nor more than 12 months
- any self-exclusion may, on request, be extended for one or more further periods of at least 6 months each
- a customer who has decided to enter a self-exclusion agreement is given the opportunity to do so immediately without any cooling-off period. However, if the customer wishes to consider the self-exclusion further (for example to discuss with problem gambling groups), the customer may return at a later date to enter into self- exclusion
- at the end of the period chosen by the customer, the self-exclusion remains in place for a further 6 months, unless the customer takes positive action in order to gamble again
- where a customer chooses not to renew the self-exclusion, and makes a positive request to begin gambling again during the 6 month period following the end of their initial self-exclusion, the customer is given one day to cool off before being allowed access to gambling facilities. The contact must be made via telephone or in person
- notwithstanding the expiry of the period of self-exclusion chosen by a customer, no marketing material should be sent to them unless and until they have asked for or agreed to accept such material.

- The licensee should retain the records relating to a self-exclusion agreement at least for the length of the self-exclusion agreement plus a further 6 months.
- Please note that the Commission does not require the licensee to carry out any particular assessment or make any judgement as to whether the previously self-excluded individual should again be permitted access to gambling. The requirement to take positive action in person or over the phone is purely to a) check that the customer has considered the decision to access gambling again and allow them to consider the implications; and b) implement the one day cooling-off period and explain why this has been put in place.
- Licensees should have, and put into effect, policies and procedures which recognise, seek to guard against and otherwise address, the fact that some individuals who have self-excluded might attempt to breach their exclusion without entering a gambling premises, for example, by getting another to gamble on their behalf.
- Licensees should have effective systems in place to inform all venue staff of self-excluded individuals who have recently attempted to breach a self-exclusion in that venue, and the licensees neighbouring venues.
- In providing training to staff on their responsibilities for self-exclusion, licensees should have, as a minimum, policies for induction training and refresher training.


Destinations of regulatory settlements to be applied for socially responsible purposes

 The Commission reviews proposals for destinations of regulatory settlements.

 The following projects have been approved as destinations of regulatory settlements since March 2019. Some of these projects have been approved as destinations but have not yet received funds. This information will be updated at least on an annual basis.


 Information about destinations of regulatory settlements to be applied for socially responsible purposes. |  Date  |  Organisation  |  Amount  |  Project  |
| --- | --- | --- | --- |
|  November 2022  |  Anonymind and Leon House  |  £992,298.94  |  A 24-month study to better understand gambling in the veterans community including the pathways to problem gambling and access to interventions to develop policy and practice solutions.  ||  November 2022  |  Addiction Recovery Agency (Ara)  |  £115,000  |  A 18-month project to understand the developmental precursors to disordered gambling, with a focus on the relationship between disordered gambling and trauma. This will assist in the development of more effective early intervention and treatment initiatives.  ||  November 2022  |  Glasgow University  |  £402,184  |  A 18-month project that will conduct new empirical research on gamblers patterns of expenditure across a range of areas, through secondary analysis of existing data, design and implementation of a bespoke random probability survey of gamblers and a Discrete Choice Experiment. To understand the preferences and choices of gamblers to generate robust new insights into likely consumer behaviour changes in response to a range of potential new protections from gambling harm.  ||  November 2022  |  GamCare  |  £236,086  |  A 12-month pilot to explore the feasibility of enabling organisations to 'warm transfer' their customers who are harmed by gambling directly into the National Gambling Helpline’s live-chat and instant messenger services (for example WhatsApp and Facebook Messenger).  ||  November 2022  |  Red Card Gambling Support  |  £130,000  |  A 2-year pilot to provide gambling awareness and education for semi-professional (non-league) football clubs, targeting 1,500 young players aged 16 to 25 years old and club staff in up to 30 clubs across London, southeast, and the Midlands.  ||  November 2022  |  JC Foundation Trust  |  £24,560  |  A 18-month project to support the Jewish community in Salford and ensure that more individuals and families in this community receive the help and support they need to reduce their gambling habits and therefore improve their financial situation, personal relationships, and mental health.  ||  November 2022  |  The Association of Directors of Public Health (ADPH) North East  |  £750,000  |  A 3-year pilot to address gambling harms in a region which has high rates of deprivation and high rates of harmful gambling compared to other areas in England. Working with key target groups including those already living in poor health, low life-satisfaction, pre-existing mental health conditions and history of substance misuse and implementing and evaluating co-produced interventions with practice partners and experts by experience, across primary, secondary, and tertiary prevention.  ||  August 2022  |  GREO  |  £1,612,300  |  The goal of the Gambling-Related Suicide Research Programme is to fund research in the United Kingdom (UK) that will improve understanding of the links between gambling and suicide to increase the effectiveness of regulatory measures, harm reduction, prevention, postvention, and ultimately reduce the number of gambling-related suicides in the UK. Among the £1,612,300 available, GREO Evidence Insights will disburse more than 80 percent as research grants and supports for knowledge mobilisation via a transparent, peer review adjudicated competition. Two grant opportunities were launched in March 2023.  ||  August 2022  |  Behavioural Insights Team (BIT)  |  £4,320,000  |  An extension of the BIT Gambling Policy & Research Unit to develop and test approaches to reducing gambling harms. The Unit will work with stakeholders and policymakers to discover, test and scale ways to reduce gambling harm.  ||  August 2021  |  University of Edinburgh and Evidence to Impact  |  £35,598.92  |  The project is a pilot study to test delivery of Preventing Gambling Related Harm in Adolescents (PRoGRAM-A), a school-based, peer-led gambling prevention intervention which trains secondary school students to become peer supporters to diffuse gambling prevention messages to their peers and social networks. The intervention is adapted from an existing and effective smoking prevention programme called A Stop Smoking in Schools Trial (ASSIST).  ||  December 2021  |  TalkBanStop Campaign in partnership with Gamcare, Gamban and GAMSTOP  |  £1,379,451  |  A one-year extension to the TalkBanStop partnership pilot to further promote, offer and evaluate the use of blocking software free of charge, alongside other tools for consumers which are already free of charge. This one-year extension is with a particular focus on evaluation to inform decisions around long-term sustainability.  The three organisations coming together to promote and evaluate the role of blocking software are: * GamCare’s National Gambling Helpline
* GAMSTOP self-exclusion
* Gamban blocking software, (which will be provided free of charge as part of the pilot).
 |
|  November 2021  |  GamCare  |  £1,107,082  |  A three-year project to develop a new money and debt service within GamCare which will complement existing services and provide simultaneous gambling, money and debt advice support to gamblers and affected others via telephone or online, and foster partnerships with money and debt organisations to increase cross-signposting and referrals.  |
|  November 2021  |  Sheffield Mind Ltd  |  £148,202.27  |  A two-year pilot to develop new ways of working with young people at risk of gambling-related harm in Sheffield with an emphasis on resilience and prevention to empower young people to act as peer educators.  |
|  August 2021  |  GREO  |  £226,064  |  The overarching goal of this 18-month project is to support specific communities who are at greater risk for gambling harms by extending understanding of effective information pathways.  |
|  August 2021  |  National Institute of Economic and Social Research (NIESR)  |  £140,050  |  This short six-month pilot aims to provide a new way of measuring the socio-economic effects of gambling through an evaluation of existing evidence on benefits and costs of gambling, a specialised survey and NIESR-specific modelling to measure the behavioural dimension of gambling and its socio-economic effects, and ongoing engagement with key stakeholders.  |
|  August 2021  |  Gambling with Lives  |  £498,000  |  This one-year project will create, test and embed a range of information, resources and training tools, and undertake professional engagement, with partners across Greater Manchester. This will facilitate identification of people experiencing gambling harms, help to ensure that essential information is provided and support people to identify support that is needed.  |
|  August 2021  |  Behavioural Insights Team (BIT)  |  £1,680,000  |  Funding for one-year to support the creation of a Gambling Policy & Research Unit that will: * work with key stakeholders to design and scale successful interventions across the gambling market such as with banks and the financial services sector to help them understand, identify and support their most at-risk customers
* build evidence for policy and regulatory advice and changes through a database of ‘what works’ that can be replicated and iterated globally
* explore instances where gambling is influenced and intersects with other sectors, to inform cutting-edge solutions.
 |
|  August 2021  |  City, University of London in partnership with LAB Group Services  |  £209,601  |  University of London, and LAB Group Services have collaborated on a one-year project to research methods for reducing gambling related harms in digital spaces. To understand the impact of COVID this project has been extended to include the full integration of mobile kinetics and interventions through a supplementary project of research to dovetail with its original laptop/desktop focused research.  |
|  August 2021  |  Local authorities represented by the Association of Directors of Public Health, Yorkshire & Humber  |  £800,000  |  This three-year project is to implement and embed a sustainable, multi-component and collaborative programme across Yorkshire and the Humber to tackle gambling related harms, including gambling related debt, with a focus on education and prevention and access to support and treatment. The aim of the project is to understand what works in preventative education through insights provided by research and evaluation and to increase referrals to treatment and support.  |
|  August 2021  |  Ara-Addiction Recovery Agency in partnership with: * Beacon Counselling Trust
* DrugFam
* GREO
 |  £994,540  |  This project is a collaboration between a number of organisations working to support affected others in a two-year project to expand the knowledge and evidence of any links between gambling and substance misuse in those affected by another’s gambling. The pilot also aims to develop support via hubs which will offer structured support plan to affected family members.  |
|  July 2021  |  GamCare  |  £344,440  |  A 2-year project to accelerate GamCare’s work in improving signposting for gambling customers, specifically through developing industry codes for the display of safer gambling information and evaluating the impact of these codes on customer behaviour.  |
|  July 2021  |  Epic Restart Foundation  |  £500,000  |  The EPIC Restart Foundation pilot project will aim to help those recovering from the effects of gambling addiction to build resilience, find new and meaningful opportunities, and positively restart their lives after gambling by giving ongoing help after treatment to help prevent any relapse via a three-stage education programme.  |
|  March 2021  |  Deal Me Out CIC  |  £161,103  |  This project aims to deliver a safer gambling awareness and education programme in Wales which will specifically target Welsh language users.  |
|  March 2021  |  Scottish Public Health Network (ScotPHN)  |  £394,000  |  Building on the work of ScotPHN to develop a whole systems approach to reducing gambling harms, this programme of activity supports development of public health surveillance approaches, evaluation of programme activity, local community capacity building and a summit on gambling harms to be held in Glasgow.  |
|  March 2021  |  StepChange Debt Charity in partnership with Personal Finance Research Centre (PFRC), University of Bristol and Northern Gambling Clinic  |  £63,604  |  This project aims to explore how to reduce the harm caused by gambling related over indebtedness among those who gamble and those with problem debts.  |
|  March 2021  |  Beacon Counselling Trust Criminal Justice Police Custody Suites Screening, Horizon Scanning and Capacity Building Project  |  £984,000  |  This projects aims to use the findings from an initial pilot to develop a sustainable implementation model embedded within NHS commissioning. Beacon intend to work with the following Police forces over approximately three years to develop a model that will be suitable for roll out nationally: * Lancashire
* Merseyside
* West Midlands
* Cumbria
* Manchester
* Cheshire
 |
|  February 2021  |  GamCare – Criminal Justice Project  |  £850,851  |  This project aims to deliver a bespoke two-year Gambling Harms and Criminal Justice (CJ) Development Project. The nature of the work will include: * CJ-focused training and awareness raising to staff/people in the CJ system (CJS)
* exploration of the needs and issues facing gamblers in the CJS - facilitating ‘thought leadership’ to discuss potential solutions and responses
* raising the profile of the gambling/crime issue, including targeted campaigns.
 |
|  February 2021  |  Academic Forum for Gambling Research, facilitated by GREO  |  £574,600  |  This project will support the development of the Academic Forum for the Study of Gambling which is a coordinated body to support rigorous, independent research to prevent, reduce, and address gambling harms in the UK, facilitated by GREO.  |
|  December 2020  |  GREO-Global Research Exchange  |  £2,088,370  |  The project aims to develop a knowledge translation platform to facilitate evidence-based action in support of the National Strategy to Reduce Gambling Harm in Great Britain. The next phase of the project builds upon the ‘research to inform action’ enabler of the National Strategy for the purpose of widening the research base and improving links between research and policy.  |
|  November 2020  |  YGAM in partnership with Redcard, TalkGen and Clear View Research  |  £627,391  |  The project’s aim is to create a purposeful and tailored approach for gambling-harm prevention, with and for BAME communities. The project centres on understanding socio-cultural and religious contexts on shame and stigma.  |
|  November 2020  |  Beacon Counselling Trust in partnership with ARA - Recovery 4 All and GREO  |  £560,653  |  To meet the needs of an underserved ethnocultural population with unique cultural considerations, this two-year project will build capacity in the South Asian community to reduce gambling harms by: * implementing a culturally appropriate train-the-trainer model to deliver gambling harm reduction education
* increasing knowledge of gambling harm and treatment options among the South Asian population
* improving referral pathways to treatment for those experiencing harms.
 |
|  November 2020  |  Birmingham City Council in partnership with University of Birmingham  |  £393,800  |  Project aims to pilot the ability to detect and prevent gambling related harm as a cause of tenancy loss by establishing and putting in support mechanisms to those at risk or already engaged in harmful gambling.  |
|  November 2020  |  GamFam  |  £276,348  |  A pilot project which provides a support programme to families impacted by gambling related harms.  |
|  November 2020  |  Gamcare – Woman’s Programme  |  £1,669,000  |  The programme comprises primarily of training and prevention activities, outreach and strategic stakeholder engagement for women who are experiencing gambling related harm.  |
|  October 2020  |  TalkBanStop Campaign in partnership withGamcare, Gamban and GAMSTOP  |  £2,633,379  |  TalkBanStop partnership campaign.  A 12-month pilot to promote, offer and evaluate the use of blocking software free of charge, alongside other tools for consumers which are already free of charge. The three organisations coming together to promote blocking software are: * GamCare’s National Gambling Helpline
* GAMSTOP self-exclusion
* Gamban blocking software, (which will be provided free of charge as part of the pilot).
 |
|  September 2020  |  Gambling with Lives  |  £102,600  |  Scoping of a Treatment Pathway project to be delivered in collaboration with Leeds and York NHS Partnership Trust, NHS England, City Council public health team, primary care team the project aims to develop clear care pathways for those experiencing gambling related harm.  The pathway will be designed with stakeholders including people with lived experience, specialist treatment providers, public health and the third sector. The pathway will be designed with stakeholders including people with lived experience, specialist treatment providers, public health and the third sector.  |
|  July 2020  |  City University of London in partnership with LAB Group  |  £366,893  |  Project seeks to spot potential problem gambling earlier in the lifecycle, by mapping kinetic, typing, scrolling and other 'implicit' digital behavioural interactions via gambling and apps.  It also aims to provide comparative linguistic analysis and nudge theory to facilitate safer gambling messaging and take-up tools and support.  |
|  July 2020  |  YGAM  |  £90,000  |  Stand-alone to respond to Covid-19.  Development of Digital Learning (digital assets for flipped or fully online content solution, learning platform and of microsite).  Development of current face-to-face learning resources.  Development of Evaluation Framework.  |
|  February – July 2020  |  GamCare  |  £500,000 (part funded)  |  A project to enhance the delivery of youth education and age-appropriate treatment options. Design and delivery of both guided self-help and session plans for both young people and professionals. These will be available in both analogue and digital formats and supported by the existing evidence base around what works with young people.  |
|  June 2020  |  PG Solutions (part of ARA Group)  |  £311,000  |  Project to test and evaluate safer gambling messaging and embed a safer gambling toolkit to support the messaging. The project aims to reduce the numbers of people harmed by problem gambling and improve the access to safer gambling information, advice, and help.  |
|  June 2020  |  Forward Trust  |  £30,900  |  Supporting offenders serving prison sentences across 19 sites, conducting a survey exercise to assess if issues with gambling have worsened during the coronavirus prison lockdown, and developing tailored self-help material and resources for prisoners coming up to release.  |
|  June 2020  |  GamCare  |  £195,672  |  Ensuring GamCare maintains appropriate IT infrastructure to remain resilient during Covid-19 period.  |
|  June 2020  |  GamCare  |  £36,000  |  Project to enable gambling blocking software to be provided to individuals accessing the National Gambling helpline or GamCare treatment network, on a temporary basis. This project was originally in receipt of £21,000 although it was noted that an extension to the project may be possible. In December 2021, this project was extended to provide deeper longitudinal evaluation and research about those who access self-exclusion, barriers to treatment, and use of other tools such as gambling blocking and financial blocking. The extension was for a further £15,000.  |
|  May 2020  |  Gambling Research Exchange (GREO)  |  £1,100,000 (part funded)  |  Evaluation based project which aims to accelerate the implementation and spread of effective, evidence-based initiatives for safer gambling.  |
|  April 2020  |  Beacon Counselling Trust  |  £30,000  |  Scoping project working with five police forces in the North West of England to support co-ordination of police forces’ problem gambling screening activity within custody suites, working alongside other criminal justice projects.  |
|  April 2020  |  Beacon Counselling Trust  |  £517,228  |  Project in collaboration with the Unite trade union, the Union Learning fund, and Addiction Recovery Agency (ARA), alongside employers, to roll out a Workplace Charter, to reduce harms in the workplace from gambling through education, support and referral to treatment.  |
|  April 2020  |  Birmingham and Solihull Mental Health Trust  |  £67,500  |  Introducing and evaluating a co-designed and co-produced pilot public health Recovery College course on gambling and addiction. The course is targeted at mental health service users, carers and families and mental health professionals.  |
|  April 2020  |  GambleAware  |  £8,800,000  |  Funds to help ensure treatment and support services can continue to operate effectively and withstand additional pressures on their services caused by the Covid-19 outbreak.  |
|  March 2020  |  Charities Aid Foundation  |  £40,000  |  Supporting effective coordination of the National Strategy to Reduce Gambling Harms – focus on funding, flows and partnerships for the third sector.  |
|  January 2020  |  Greater Manchester Combined Authority  |  £750,000  |  Pathfinder project for local authority public health approaches.  |
|  December 2019  |  Health and Social Care Alliance  |  £496,647  |  Operation of a forum for participants with lived experience of gambling harm to steer the implementation of the National Strategy within Scotland.  |
|  December 2019  |  Scottish Public Health Network  |  £142,483  |  Embedding a whole population approach to gambling in Scotland.  |
|  November 2019  |  Centre for Public Scrutiny  |  £103,200  |  Using local authority scrutiny processes to understand and tackle gambling related harms.  |
|  November 2019  |  The Samaritans  |  £523,998  |  Training and resources for gambling businesses to identify and support customers experiencing risks of suicide.  |
|  October 2019  |  Money and Mental Health Policy Institute  |  £228,500  |  A two-year programme of work to engage the financial services sector in efforts to reduce gambling harms.  |
|  September 2019  |  Healthy Stadia  |  £37,500  |  An effective model to be rolled out to reduce the incidence of unhealthy gambling behaviour in the football stadium environment.  |
|  September 2019  |  Hurley Group  |  £1,562,184  |  A pilot project to explore the design and delivery of an NHS based integrated community-based service for people experiencing harm from gambling.  |
|  September 2019  |  Gordon Moody  |  £220,000  |  Capital funds to increase treatment capacity.  |
|  August 2019  |  Gordon Moody  |  £200,000  |  To enable the effective analysis of the data that is captured by Gordon Moody treatment provision.  |
|  July 2019  |  Howard League for Penal Reform  |  £1,838,000  |  Large scale problem gambling and crime commission.  |
|  June 2019  |  Gambling Research Exchange  |  £1,900,000  |  Creating a programme of work including a new research, dissemination evidence hub committed to preventing and reducing gambling harms in Great Britain in support of the National Strategy.  |
|  May 2019  |  GamCare  |  £3,223  |  Provide and distribute stock of printed self-help workbooks.  |
|  |  |  £298,590  |  Design and deliver a website to support the administration of the GamCare Safer Gambling Standard, and ensuring the ‘scores’ for accredited operators are clearly visible to consumers.  |
|  |  |  £250,000  |  To build capacity for the effective analysis of the data that is captured by GamCare treatment provision and from the National Gambling helpline.  |
|  March 2019  |  GambleAware  |  £30,000  |  To accelerate progress to deliver GambleAware’s activity to support the  [National Strategy to Reduce Gambling Harms.](/about-us/reducing-gambling-harms)  |

---

 Last updated: 30 March 2023

 Show updates to this content  Added the latest 10 projects approved for funding via regulatory settlements.


Social Responsibility Funds Group - Terms of Reference

 The Social Responsibility Funds Group has been established to ensure robust and transparent decision-making in relation to the allocation of Regulatory Settlement funds and applications to join the approved Licence Conditions and Codes of Practice (LCCP) Research, Education and Treatment (RET) list.

 [Next page
 Scope](/licensees-and-businesses/guide/page/social-responsibility-funds-group-terms-of-reference-scope)

---

 Last updated: 4 May 2022

 Show updates to this content  No changes to show.


>  This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
>  Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this  [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update)  . The  [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance)  is not in effect and is subject to further consultation. Operators are not required to take it into account.
>
>

 You need to know:

* the types of markers and behaviours that could indicate harm relevant to online gambling, and
* how to spot when those indicators should trigger an interaction.

 You need to put together what you know about the customer, with the relevant indicators of harm, to decide whether you need to interact. More knowledge about what to look for, with effective processes for monitoring customer behaviour, can mean quicker and better-informed decisions.

 Some indicators of harm, such as high staking behaviour, can look similar to VIP and high-value customer activity. Even if you think the customer can afford it, they may still be experiencing gambling harms. Your enhanced contact with your VIPs means you have many opportunities to get to know them well and make better informed decisions.

###  Identify

 We expect you to: * use a range of indicators relevant to your business. Do not rely on financial indicators alone. You should use realistic thresholds and trigger points, and remember that not every customer who is experiencing or at risk of harm will trigger every indicator
* monitor customer activity so that you are able to interact early and quickly. Invest in systems and staff to manage your customer interaction process effectively
* monitor customer accounts from the time that they are opened
* make sure your process keeps pace with any increase in demand – through growth, mergers or other internal changes.
* train your staff to know their roles and responsibilities, and ensure they are supported and able to act promptly when they spot or are alerted to indicators of harm. This includes your VIP teams.
* aim to minimise the risk of harm for customers, whatever time of day they play, as well as for new customers
* take safer gambling seriously for all customers, including VIPs, and not let commercial considerations override customer protection. This means your VIP customers get the same level of protection as your other customers
* make meaningful records of all interactions with customers. Make these records available to staff and use them to aid decision-making. This should also take place in circumstances where an interaction has been ruled out e.g. because the customer is displaying signs of agitation
* even if you think your sector is “lower risk”, all forms of gambling present risks and you should understand the prevalence of gambling harms for the type of gambling products you offer and implement appropriate processes.
* actively promote and encourage the use of gambling management tools to all customers, and in particular where you have carried out a customer interaction. Research (Behavioural Insights Team, 2018) has shown that reducing friction in applying a gambling management tool leads to increased numbers taking it up.

 [Previous page
 Customer interaction: formal guidance for remote gambling operators](/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-remote-gambling-operators)  [Next page
 Understanding the impact of gambling harm](/licensees-and-businesses/guide/page/understanding-the-impact-of-gambling-harm)

---

 Last updated: 15 September 2022

 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.


Understanding the impact of gambling harm

>  This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
>  Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this  [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update)  . The  [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance)  is not in effect and is subject to further consultation. Operators are not required to take it into account.
>
>

 In 2018, the Gambling Commission  [published research (Wardle et al 2018)](/news/article/new-report-takes-significant-step-forward-in-measuring-the-impact-of)  on understanding the full range of gambling harms and the impact this can have on society. This research defined gambling harms as ‘the adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society’. This can include loss of employment, debt and crime – gambling harms can also have detrimental impacts on physical and mental health and relationships, and at its worst, gambling can contribute to loss of life through suicide.

 Gambling harms cannot be solely measured in terms of finance and resources. This is why we expect you to use a range of indicators in order to identify customers who may be experiencing harms.

 [Previous page
 Identifying the right customers](/licensees-and-businesses/guide/page/identifying-the-right-customers)  [Next page
 Using the right indicators for your business](/licensees-and-businesses/guide/page/using-the-right-indicators-for-your-business)

---

 Last updated: 15 September 2022

 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.


Using the right indicators for your business

>  This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
>  Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this  [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update)  . The  [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance)  is not in effect and is subject to further consultation. Operators are not required to take it into account.
>
>

 Change compared with previous gambling activity is a general trigger for customer interaction. Building up your knowledge of your customers is key to helping you spot changes in their behaviour.

 You should use a range of indicators based on research, experience and shared practice. The PWC remote gambling research (2017) identified some account and play indicators, but they are not a definitive list.

 Your list should include the following.

###  Time and spend indicators

 Amount and frequency of time and deposits, time of day (according to research (PWC 2017), a higher percentage of overnight gamblers were found to be problem gamblers, than during other times of day), increasing length of sessions or escalation in deposit levels, large losses.

###  Account indicators

 Cancelled withdrawals, failed deposits, multiple or more expensive payment methods, pre-loaded cards and e-wallets which could indicate gambling with money the customer does not have.

###  Use of gambling management tools

 Changing deposit limits, trying to ‘switch off’ the reverse withdrawal option to prevent re-staking prior to withdrawal, previous self-exclusions, frequent or repeated use of the time out facility or previous customer interactions.

###  Customer-led contact

 Information or hints from customers, frequent complaints about not winning, requests for bonuses following losses, or talking about the negative impacts of their gambling.

###  Play indicators

 chasing losses, erratic betting patterns, gambling on higher risk products or unusual markets or outcomes on which the customer is unlikely to have been able to make an informed choice. People who bet in-play may place a higher number of bets in a shorter time period than people who bet in other ways, as  [in-play betting](/licensees-and-businesses/guide/in-play-or-in-running-betting)  offers more opportunities to bet.

 Some studies have shown that placing a high number of in-play bets can be an indication that a customer is at an increased risk of harm from gambling.

###  A ‘big win’ or a windfall

 Research (Parke and Parke 2017) shows high staking following a win could hide or even lead to harmful behaviour. Suddenly having more money than usual can lead to increasing staking, which can lead to harms not associated with wealth or resources.

 [Previous page
 Understanding the impact of gambling harm](/licensees-and-businesses/guide/page/understanding-the-impact-of-gambling-harm)  [Next page
 Affordability and customer’s personal circumstances](/licensees-and-businesses/guide/page/affordability-and-customers-personal-circumstances)

---

 Last updated: 15 September 2022

 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.


Affordability and customer’s personal circumstances

>  This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
>  Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this  [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update)  . The  [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance)  is not in effect and is subject to further consultation. Operators are not required to take it into account.
>
>

 Historically, gambling operators have not systematically considered customer affordability when developing their customer interaction policies. Many have used deposit or loss thresholds as a main or sole prompt for a customer interaction, but these have often been set at levels that were inappropriately high, in comparison to the average amount of money that the majority of people have available to spend on leisure activities. This has led to a number of examples of customers spending more than they could afford, and this not being identified sufficiently early, as seen in much of the Commission’s compliance and enforcement casework since 2017.

 Operators should aim to identify those experiencing or at risk of harm and intervene to try to reduce harm at the earliest opportunity. Reliance on deposit or loss thresholds that are set too high will result in failing to detect some customers who may be experiencing significant harms associated with their gambling. It is therefore imperative that threshold levels are set appropriately.

 Open source data exists which can help operators assess affordability for their GB customer base and improve their risk assessment for customer interactions. Thresholds should be realistic, based on average available income for your customers. This should include the  [Office of National Statistics publications (opens in a new tab)](https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances)  on levels of household income.

 In considering these thresholds, you should be aware of the difference between ‘disposable income’ and ‘discretionary income’ which refers to the amount left after living costs are taken into account, but it does still include many other unavoidable costs. Most people would consider it harmful if they were spending a significant amount of their discretionary income on gambling.

 [Previous page
 Using the right indicators for your business](/licensees-and-businesses/guide/page/using-the-right-indicators-for-your-business)  [Next page
 Vulnerability](/licensees-and-businesses/guide/page/vulnerability)

---

 Last updated: 15 September 2022

 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.


>  This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
>  Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this  [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update)  . The  [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance)  is not in effect and is subject to further consultation. Operators are not required to take it into account.
>
>

 Life events or changes to an individual customer’s circumstances may mean that a person becomes more or less vulnerable to experiencing gambling harms. Those circumstances could include bereavement, loss of income or other factors, as follows.

 It will not always be obvious or clear to an operator when such events have occurred, but knowing your customers, and ensuring staff ask questions when there are potential signs of vulnerability, will help to determine whether those individual circumstances present an increased risk.

 As part of ‘know your customer’ and developing customer interaction policies and procedures, operators should consider the factors that might make an individual more vulnerable to experiencing gambling related harm.

 Factors include:

* **personal and demographic**  - if the individual is experiencing poor physical or mental health, physical or cognitive impairment, suffering side effects from a brain injury or medication or has an addiction
* **situational**  - if the individual is experiencing financial difficulties, is homeless, is suffering from domestic or financial abuse, has caring responsibilities, experiences a life change or sudden change in circumstances
* **behavioural**  - if an individual has a higher than standard level of trust or high appetite for risk
* **market-related**  - if an individual is engaged in an activity which is highly complex; that they have a lack of knowledge and/or experience of the market
* **access**  - if an individual has difficulty accessing information because of poor literacy or numeracy skills, knowledge, dyslexia.

 We have seen examples through our casework of customers who should have received some interaction but did not, including customers who were particularly vulnerable, and more susceptible to experiencing gambling harms.

 [Previous page
 Affordability and customer’s personal circumstances](/licensees-and-businesses/guide/page/affordability-and-customers-personal-circumstances)  [Next page
 Spotting harmful gambling](/licensees-and-businesses/guide/page/spotting-harmful-gambling)

---

 Last updated: 15 September 2022

 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.


>  This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
>  Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this  [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update)  . The  [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance)  is not in effect and is subject to further consultation. Operators are not required to take it into account.
>
>

 How you monitor activity depends on your business. Larger operators with more active customers will need comprehensive systems, which could include a mix of automated and manual processes, and should draw on all available sources of data to give a comprehensive picture of the customer’s gambling.

 Options for spotting harmful gambling include:

* in-play real time monitoring to identify harmful behaviour as it occurs.
* daily reports on activity.
* chatroom monitoring and moderation.

 The right information can mean better and quicker decisions. You should aim to integrate your systems so that staff have a more complete picture of the customer’s activity, and this includes records of previous customer interactions.

 Unmonitored overnight gambling carries an increased risk. Remote gambling research (PWC 2017) found that the highest risk customers were much more likely to gamble overnight than non-problem gamblers. Some operators have full 24-hour dedicated safer gambling monitoring and support, so that customers have the same level of protection overnight as during the day. Another option could be more training and extra responsibilities for customer service staff or chat hosts to provide that support.

 Because VIP customers can also experience gambling harms, it is good practice to carry out a safer gambling check when upgrading a customer to VIP status, and to keep this under review. You should also use these opportunities to carry out checks for Anti-Money Laundering (AML). This could also help you to support customers who have had major wins.


 It is important that all staff receive training so that they are aware of the signs that could indicate that a customer may be experiencing harms associated with gambling.

 This is not an exhaustive list, but you should ensure that:

* staff are trained to identify the signs of harm and are able to refer back to documents that include the types of behaviour that may trigger customer interaction at an appropriate moment. Staff should know how to escalate a situation if they are unsure or require support.
* staff understand how indicators of harm could be displayed differently in VIP or ‘high value’ customers, and know how to spot the signs.
* as a minimum, staff receive training at induction as well as refresher training.