Strategy to Prevent Underage Play

Strategy to Prevent Underage Play

  • 1.0 Introduction

    Camelot UK Lotteries Limited ('Camelot') is committed to maximising returns to the Good Causes in a socially responsible way, and therefore its responsible gaming strategies are an important element of its business strategy. Camelot recognises that National Lottery products might pose a risk to certain vulnerable groups and as a responsible operator understands its responsibility for minimising the harm to society.

    This strategy deals with Camelot's approach to preventing underage play, and (as Camelot is a member of the WLA and EL1) is consistent with the WLA Principles and Framework for Responsible Gaming (see Appendix 1) and the EL Responsible Gaming Standard (see Appendix 2). This strategy is intended to complement applicable laws and regulations within the UK and demonstrates how Camelot is striving for best practice relating to responsible gaming.

    The aims of Camelot's strategy are:

    • to actively discourage people under 16 from buying;
    • to actively deter retailers from selling tickets to people under 16;
    • to raise awareness, especially among adults, of the dangers of buying National Lottery products for children;
    • to understand the impact of National Lottery products on gambling problems in people under the age of 16, their families and relationships;
    • to understand the effect on society of underage gambling;
    • to prevent underage play;
    • to support treatment where problems cannot be prevented;
    • to promote the need for responsible gaming programmes across the lottery sector.

    It is clear that the treatment of people with gambling related problems is the domain of clinicians and other healthcare specialists. Camelot actively engages with a range of interested groups in order to understand the problem gambler's perspective. However, Camelot's primary aim is to establish responsible gaming programmes e.g. the prevention of underage and the prevention of excessive play to minimise the risk for society in general and particularly for vulnerable groups.

    Camelot takes the responsibilities of its regulator the Gambling Commission very seriously and therefore strives for a joined-up approach. In doing so, Camelot acknowledges that its responsible gaming strategy must be based on a common understanding of the issues posed by problem gambling.

    In defining its responsible gaming strategies Camelot listens and responds to the concerns of its stakeholders such as public interest groups, retailers, players etc.

    Camelot's underage play strategy is one of several strategies that form its responsible gaming strategy; in particular this strategy should be read in partnership with the Strategy to Prevent Excessive Play.

    Both strategies should be read in conjunction with both the Camelot Code and the Corporate Responsibility Code (The CR Code). The CR Code provides guidance to all of Camelot's employees, contractors and others providing services on behalf of Camelot in how to effectively uphold the company's commitment to operating The National Lottery with integrity and in a responsible manner. The purpose of the Camelot Code is to affirm the company's strong dedication to the highest standards of business conduct. The CR code complements the Camelot Code by expanding further on the way the company manages and reports on responsible play, its commitments to its staff, retailers, suppliers, local communities and other stakeholders and environmental protection.

    1 WLA stands for the World Lottery Association and EL stands for the European Lottery Association.

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  • 2.0 Definitions

    When thinking about responsible gaming Camelot has identified four key vulnerable groups

    1. those on low incomes;
    2. those who do not understand the risks of playing;
    3. those who are already addicted to gaming products;
    4. those under the age of 16.

    The underage play strategy addresses the fourth of these vulnerable groups.

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  • 3.0 Context

    In 2009, The National Lottery accounted for approximately 6% of the UK gambling market. This compares with 63% spent at bookmakers and 12% on gaming machines. More broadly, on average approximately 70% of the UK adult population regularly plays National Lottery games with the average spend per player at £3.152. The UK National Lottery is the sixth largest in the world in terms of sales but it ranks 64th in terms of per capita spend according to La Fleur's World Lottery Almanac (2010).

    An independent research report commissioned by the National Lottery Commission and conducted by Ipsos MORI and the International Gaming Research Unit (Nottingham Trent University) was published in July, 2009 titled 'British Survey of Children, the National Lottery and Gambling 2008-09'. It can be downloaded from The main findings from that report were:

    "The research consisted of a quantitative survey of nearly 9000 children aged between 12-15 in England and Wales about their experiences of, and attitude towards, gambling on a range of games. The key findings were3:

    • Only 2% had played Lotto in the past seven days - down from 5% in 2005-06 - and 4% had bought scratchcards (down from 6% in 2005-06);
    • The proportion of children trying to buy tickets is also on a downward trend: 2% of children attempted to buy National Lottery tickets in the past seven days, compared with 5% in 2005-06;
    • 4% tried to buy scratchcards, down from 8% in 2005-06;
    • When asked what would deter them from buying National Lottery tickets, 34% of the children say being asked to prove they were over 16 would be off-putting;
    • Children are most likely to buy their National Lottery tickets and scratchcards at cornershops and newsagents, while supermarkets and other retailers are used much less frequently.

    Camelot welcomed the insights gained from this study and has indicated to the NLC that it will develop some of the key issues through its responsible gaming strategy. In particular, a review of Operation Child (see section 7.0) has been undertaken and a more risk-based approach to the programme is now taken.

    2 Per player spend has been calculated by dividing the total sales figure for 2009/10 with the 47 million people in the UK who are 16 or older (Census data) divided by 52 weeks.

    3 Directly taken from press release by the National Lottery Commission which can be found at

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  • 4.0 Corporate Responsibility: Governance

    Chart showing the Corporate Responsibility Board structure

    The Corporate Responsibility Board (CRB) consults and is advised by the independent Advisory Panel for Corporate Responsibility (APCR)4. The CRB is informed by several consultative groups including the Public Interest Group Forum, the Staff Forum and the Retailer Forum. The Player Protection Panel reports into the CRB. This is a cross-functional working group from within the business that oversees our player protection strategy and is chaired by a functional director. The Environmental Steering Group now functions as part of the CRB and oversees our environmental strategy.

    The chair of the Player Protection Panel owns the Strategy to Prevent Underage Play. In 2010/11 the Player Protection Panel will agree a set of specific priorities to refresh Camelot's approach to preventing excessive and underage play and to ensure that responsible gaming remains core to growth.

    The Stakeholder Engagement Panel agrees and coordinates the high-level stakeholder engagement strategy. Its members are senior representatives from around the business who have direct contact with Camelot's key stakeholders.

    The corporate risk management policy provides detailed guidance on the identification, assessment and control plans of risks across the business. Risks are identified at departmental risk workshops and are cross matched against the historical database to ensure complete coverage. A new risk assessment framework has been developed to ensure uniformity. Camelot also has a number of written policies covering its social, environmental and ethical impacts.

    A corporate responsibility report is produced annually which enables transparency and accountability in Camelot's approach to player protection. This is independently assured by an external body to provide additional credibility.

    4The Advisory Panel for Corporate Responsibility (APCR) is made up of independent specialists from outside the company with professional expertise in areas of stakeholder concern. Its job is to challenge our approach and advise us how to improve our practice, working closely with the CRB but also reporting outputs to the main Board. It is chaired by a Non-Executive Deputy Chairman of Camelot, who represents the views of shareholders on the APCR and reports back to the Board on matters discussed by the Panel. Other members have a particular stakeholder perspective and expertise in their stakeholder area.

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  • 5.0 Research

    Camelot supports research and studies from independent sources in order to contribute to society's understanding of problem gambling. This includes the funding of such research and those studies and cooperation with prevalence studies funded by the state. Camelot began in 2007 to plan a structured research strategy in respect of responsible gaming. It will design this with input from key stakeholders with the objective of ensuring that key new insights in the area of responsible gaming are understood and acted upon by Camelot and shared with its regulator.

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  • 6.0 Employee Training and Awareness

    Camelot endeavours to ensure that appropriate levels of awareness of responsible gaming are maintained throughout the organisation so that responsible gaming is made an integral part of daily operations. It provides employees with information on its responsible gaming programmes through internal communications channels throughout the year.

    Based on job demands and their level of customer interaction, relevant employees in key functions such as customer services (including temporary staff and contract staff) are given additional training on responsible gaming, in particular on treatment referral for potential problem gamblers.

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  • 7.0 Retailer programme

    Camelot provides information materials to National Lottery retailers to raise their awareness of responsible gaming and to educate them on issues relating to underage play. For example, Camelot runs campaigns in its bi-monthly retailer magazine 'Jackpot' and provides retailers with posters and stickers for their premises, refusal registers, sales force briefings etc.

    Before new National Lottery retailers become active they are provided with training on responsible gaming. This training covers a retailer's responsibilities in respect of underage sales as well as providing advice on how to refuse a sale effectively and without causing offence.

    Camelot conducts a comprehensive test purchasing scheme (Operation Child) using young people specifically selected because they look under 16, but are in fact over 16, to test if retailers have the relevant safeguards in place to prevent underage play. If on three separate occasions a retailer sells a lottery ticket to a test purchaser and does not implement the safeguards, the retailer's terminal will be removed and his/her agreement to sell lottery tickets ended.

    For the purpose of Operation Child, the licence commits Camelot to not less than 9,000 test visits per financial year. The evolution of Operation Child is an integral responsibility of the Player Protection Panel and any initiatives are subject to the establishment of clear objectives and mechanisms for measuring success.

    Retailers who sell to someone under 16 during the course of a Trading Standards operation, would normally have their terminal removed5.

    5In exceptional circumstances, a terminal will not be removed on the basis that Trading Standards guidance has not been followed during the test purchase by a TS Authority, bringing the "test purchase" into conflict with reasonable opinion. Trading Standards have in such cases on legal advice decided to take no action and the matter referred to Camelot. Any cases reported to Camelot are investigated and a sanction is applied, usually termination or suspension, however the legal position is considered.

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  • 8.0 Game design

    The Game Design Protocol, designed in partnership with universities and gambling-related charities, is a risk matrix that enables Camelot to assess any potential problems with proposed new games and to ascertain whether games are of above average appeal to any vulnerable group. If a particular game appears to pose risks to a vulnerable group, Camelot either revises the product and/or its marketing, or simply does not launch the game at all. Checking the actual experience of specific games against the predictions of the Protocol has shown the predictions to be accurate.

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  • 9.0 Remote gaming channels

    Camelot's interactive channels were designed to provide appropriate protection to vulnerable players from the heightened risk of excessive and underage play associated with remote gaming channels. When the interactive channels were launched, Camelot put in place a strict registration and authentication process which prevents underage people from registering. This includes an interactive Age Check (iAC) accreditation for its system that recognises all National Lottery games played interactively are only accessible after registration and are not accessible to under 16s.

    During 2006/07 these controls were subject to an international benchmarking review. As a result, trial games on interactive are only accessible after registration and therefore not accessible for U16s.

    Camelot undergoes an independent annual review of the National Lottery interactive platforms by GamCare.

    Camelot recognises that game design tools for interactive gaming should be used to evaluate the potential impact of games on player behaviour. Tools include the modified version of the evolved GDP which can be applied to Instant Win Games (IWG) periodically, GAM-GaRD and the systematic monitoring of play data.

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  • 10.0 Advertising & Under 16s

    As a general premise, advertising should not in any manner bring the National Lottery into disrepute.

    Until 31st May 2011 Camelot was required under the Third Licence to adopt and maintain a code of practice covering advertising, sales promotion and public relations in respect of The National Lottery. Camelot satisfied this licence requirement through its Advertising & Sales Promotion Code of Practice.

    On 1st September 2010 new CAP/BCAP Codes came into effect which meant that for the first time, The National Lottery was caught by the provisions of the CAP/BCAP Codes. As a consequence, many of the provisions included in The National Lottery Advertising & Sales Promotion Code of Practice were duplicated in the CAP/BCAP Codes. Camelot agreed with the National Lottery Commission that The National Lottery Code would be withdrawn and the remaining provisions that were not caught by the CAP/BCAP Code would be incorporated into either this strategy (see below), the Strategy for Preventing Excessive Play or The Third Licence.

    • No suggestion should be made in any advertising that anyone under the age of 16 can participate in the National Lottery.
    • All emails and marketing communications promoting National Lottery games must set out the under age restriction. The only exception to this is where proof of age has already been verified. Agreed exceptions:
      • Permanent point of sale items;
      • Accessories and items of clothing;
      • Any advertising which does not feature or promote a National Lottery game;
      • Where technical restrictions preclude an accurate representation e.g. on Interactive Media;
      • Any communication to players whose proof of age has already been verified e.g. letters to subscribers, e-mails and text messages to registered players;
      • Where inclusion would require the statement to be too large to be feasible e.g. airships, air balloons and flagpoles.

    Any other exceptions will require the prior approval of the Commission.

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  • 11.0 Treatment Referral & Player Education

    Camelot strongly believes that a properly validated proof-of-age card should be available to all young people, preferably at no cost to the young person. It accepts that there are several different options within such schemes, and Camelot has supported and endorsed all schemes that provide a properly validated proof-of-age card; for example, Camelot was involved with the inception of the "CitizenCard" proof of age scheme and is a member of the CitizenCard board.

    Camelot engages with prevalent UK problem gambling organisations including treatment centres and health professionals through the Public Interest Group Forum, the Gambling Research Education and Treatment Foundation (GREaT), and attendance and participation at conferences and seminars dealing with gambling addiction.

    This enables Camelot to understand problem gamblers' perspectives on the impact of lottery products on their situation. Furthermore Camelot provides relevant information relating to treatment services to players and retailers in printed form as well as on the National Lottery website. The adequacy and effectiveness of these arrangements are reviewed by the Player Protection Panel at least annually.

    The provision of educational information for players and the wider public is an area that Camelot reviews on an ongoing basis. Examples of information provided to players are:

    • the Players Guide has a section on responsible play;
    • GamCare's helpline number is featured in the Players Guide and on the back of scratchcards, playslips and National Lottery tickets;
    • all Players Guides, National Lottery tickets, playslips and scratchcards feature the age restriction message;
    • the National Lottery website features responsible gaming information including links to the GamCare website;
    • Camelot designed, funded and distributes a 'Serious Fun' leaflet that contains advice to people who either have a gambling problem themselves or know someone close to them who has. It has been distributed to 11,000 doctor's surgeries, libraries and Citizen Advice Bureaux' across the UK;
    • all Point-of-Sale materials (e.g. posters etc.) contain the age restriction message.

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  • 12.0 Stakeholder Engagement

    Camelot wants to understand if its strategy is meeting the expectations of its stakeholders and to look for ways in which it can improve its approach. Therefore Camelot regularly engages with its stakeholders and includes these activities in its reporting channels. This is in the form of formal consultation with public interest groups representing vulnerable people so as to assess its underage play strategy, and includes consultation with retailers and players through the relevant stakeholder forums and surveys. These consultations and surveys provide opportunities for stakeholders to voice relevant concerns or questions and Camelot integrates the results from these processes into its strategic decision-making activities (e.g. Player Protection Panel and Corporate Responsibility Board meetings). Camelot provides responses to stakeholders through a mixture of updates at appropriate forums, commenting via its Corporate Responsibility Report and direct correspondence with its stakeholders.

    An internal Stakeholder Engagement Panel reviews and develops Camelot's working relationships with all those with an interest in The National Lottery. This panel is made up of those across the business who manage specific stakeholder relationships.

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  • 13.0 Reporting, Measurement, Sharing & Certification

    Through its programmes, Camelot develops a broad range of experience, knowledge, skills and tools in the area of responsible gaming including underage play. Camelot is committed to actively sharing these through a mixture of formal and informal interactions, for example public reporting, attendance at seminars and conferences, in specialist working groups, and through professional collaboration.

    Camelot reports publicly on an annual basis to stakeholders through the Corporate Responsibility Report on the impact and breadth of its responsible gaming programmes. In 2009/10 for the third year running this report was independently verified by Deloitte LLP, using Accountability's AA1000 (2008) Assurance Standard. It assesses Camelot's broad-based corporate responsibility performance including its underage play activities. The report details progress against commitments and key performance indicators and is available at In particular, in respect of underage play the following indicator is tracked:

    • retailers who refused to sell to an Operation Child test purchaser on first visit (percentage);

    Camelot will review its key performance indicators on excessive and underage play at least annually with a view to ensuring that performance is being measured in the relevant areas based on new insights in the area of responsible gaming (supported through Camelot's research strategy, see 5.0). However, Camelot recognises that the effectiveness of performance indicators depends on being able to monitor key trends and therefore the annual assessment will bear this in mind.

    In respect of its responsible gaming strategy, Camelot will also undergo independent assessment of its programmes by the WLA and EL in respect of their Responsible Gaming Principles & Framework and Standard respectively. The results of these assessments will be included in the Corporate Responsibility Report.

    Camelot achieved the highest level of accreditation on the WLA Framework in 2009 as well as achieving certification of alignment with the European Lotteries Responsible Gaming Standards.

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  • Appendix 1 - WLA Responsible Gaming Principles & WLA Responsible Gaming Framework

    • Responsible Gaming Principles


      WLA Members are united in their commitment to foster the continuity of public order and the fight against illegal gambling as defined by governments in the each respective member jurisdiction. This commitment provides the background for the WLA Responsible Gaming Principles.

      These Principles, using the WLA bylaws as a reference, have been developed as a result of the unanimous decision of the WLA Membership in Granada to develop a comprehensive set of standards related to social responsibility. Gaming responsibility is a pivotal element in each individual WLA Member's ongoing commitment to this social responsibility and part of a proactive approach to the social impact of lotteries and other forms of gaming, including Sports Betting.

      While the WLA Members, as gaming operators, play a central role in responsible gaming, there are a number of other stakeholders who play equally critical roles in this field, namely governments, regulators, treatment providers, researchers, community groups, individual players and their social networks. To effectively deal with issues of responsible gaming, a group effort is essential, and the principles in this document address the lottery industry's relationship to these stakeholders.

      In pledging their support for these principles, WLA Members commit their vigilance in making responsible gaming an integral part of their daily operations, including activities involving employees, patrons, retailers and other stakeholders. This pledge of support includes the encouragement of research initiatives and striving to achieve an appropriate balance between revenue, entertainment and customer expectations.

      The Principles in this document should not be construed as interference, or attempt to interfere with each respective governmental policy and the activities within their jurisdiction, but rather are meant to complement relevant policies and activities within each jurisdiction.

      Therefore, WLA Members hereby commit themselves, within the social, economic political, ethical and cultural context and legal framework of the respective jurisdictions in which the lotteries operate, to the following Responsible Gaming Principles:

      1. WLA Members will take reasonable and balanced measures to meet their objectives while protecting the interests of their customers and vulnerable groups; at the same time upholding their respective commitments to defend public order within their own jurisdiction.
      2. WLA Members will ensure their practices and procedures reflect a combination of government regulations, operator self-regulation and individual responsibility.
      3. WLA Members will develop their practices concerning responsible gaming-related issues on the fullest possible understanding of relevant information and analysis of documented research.
      4. WLA Members will work with stakeholders - including governments, non-governmental organizations, regulators, researchers, public health professionals, and the general public - to share information, develop research and promote responsible gaming as broadly as possible, and encourage a better understanding of the social impact of gaming.
      5. WLA Members will promote only legal and responsible gaming in all aspects of their activities, including the development, sale and marketing of their products and activities; and will make reasonable efforts to ensure their agents do the same.
      6. WLA Members will provide the public with information in an accurate and balanced manner to enable individuals to make informed choices about gaming activities within the lotteries' jurisdiction. This commitment requires the following:
        • a. That the marketing of lottery activities and products be subject to reasonable operator self-regulation, and promote responsible gaming practices and informed choices; and,
        • b. that individuals shall be provided with accurate information about gaming and the risks associated with it, for example, organizing education program.
      7. WLA Members will make a reasonable effort to monitor, test, and revise as appropriate, those activities and practices related to responsible gaming. Their findings will be publicly reported.

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    • WLA Responsible Gaming Framework

      The WLA Responsible Gaming Framework is designed to encourage and benchmark the actions that members are taking to demonstrate their commitment to the Responsible Gaming Principles (RGP). The specific nature of RG programs and the level to which the Framework is implemented is left to the discretion of the individual member organizations.

      Level 1 - Assessment (see below) is a minimum requirement of WLA membership; performance against the other voluntary levels will be publicly reported by member organizations, but is not a requirement.

      The RG Framework consists of:

      • 7 principles
      • 4 program elements
      • 4 levels
      • Action items for each level
      • Support tools provided to members
      • WLA administration

      The Program Elements are broad categories of commitments and actions that are derived from the main components of actual WLA member programs. Program elements are:

      1. Commitment
      2. Responsible Gaming Activity
        • i. Research on responsible gaming issues
        • ii. Employee training
        • iii. Retailer program
        • iv. Game design
        • v. Remote gaming channels
        • vi. Advertising & marketing communications
        • vii. Player education (encompasses treatment referral)
      3. Learning
        • i. Stakeholder engagement
        • ii. Member cooperation and participation
        • iii. Self-assessment
      4. Reporting

        Each Program Element and sub-components will have simple, clear definitions. See Glossary in Appendix A.

        Member Collaboration is permitted - and encouraged - in the development and implementation of Responsible Gaming programs. For smaller lotteries, in particular, this provides for more efficient and effective use of resources, making the RGF more accessible. The four levels were developed to reflect varying levels of RG program development within the WLA membership and to encourage continuous improvement.

        The four levels are:

        • Level 1 - Assessing
        • Level 2 - Planning
        • Level 3 - Implementing
        • Level 4 - Continuous improvement

        To achieve level 2, 3 or 4, the member must demonstrate that they have completed over 75% of an award-level. Member organisations will not be able to claim having reached Level 2, 3 or 4 unless they have been reviewed by the independent Assessment Panel which has confirmed this level.

        Additionally, when the independent Assessment Panel determines that a member has completed between 75% and 99% in respect of either Level 3 or Level 4, the member will be requested to provide the independent Assessment Panel with a written action plan detailing how and when they expect to reach 100% or written explanations when the member believes that it has no direct control over reaching 100% due to specific local or jurisdictional circumstances. The independent Assessment Panel may seek further clarifications in respect of any plans or explanations given by the member.

        The Action Items are specific, measurable actions undertaken by member organizations through which levels are evaluated. While necessarily general to accommodate differences within the membership, they point to specific initiatives and metrics where appropriate. The nature of reported data and level of specificity will be determined by the WLA. Self-assessment takes place on current RG commitments, policies, programs and communications against RG Framework

        In order to facilitate the application of this framework by member organizations, the WLA will create and disseminate RG Framework Support Tools, consisting of guidelines/case study, shared information, and third-party support.

        These will be based on good practices by WLA members and other organizations. Specifically, the following will be developed:

        • Research Guidelines/ case studies
          • based on good practices from within the industry
        • Employee Training Module
          • based on good practices from within the industry
        • Retail Program Guidelines/ case studies
          • based on good practices from within the industry
        • Game Design Guidelines/ case studies
          • based on good practices from within the industry
        • Player Education Guideline / case studies
          • based on good practices from within the industry
        • Stakeholder Engagement Tool
          • based on good practices from within and outside the industry
        • Reporting Tool
          • based on good practices from within and outside the industry

        The WLA will develop and provide a standard Self-Assessment Tool, to be used by all member lotteries. This user-friendly Self-Assessment Tool will clearly outline all information that must be submitted to the WLA. Members have 12 months from the adoption of the Framework, or upon joining, to complete the self-assessment.

        The Annual Benchmarking Report provides a platform for the WLA to publicly report its commitment to the Responsible Gaming Principles, to describe the program and related actions through case studies, to report the aggregate performance of its membership, and to list members according to their levels.

        The WLA will also provide basic RG Framework Administration. In addition to providing the support tools and annual benchmarking report, the WLA will do the following:

        • Facilitate peer-to-peer support and learning, through a common program
        • Provide members with a centralized web-based database on international good practices
        • Develop a broad communications plan for members and external stakeholders (e.g. present the RGF at industry and non-industry conferences)
        • Award levels to members based on review by an independent panel
        • Develop an evaluation plan, to ensure that the RGF is efficiently and effectively meeting the needs of the membership and broader stakeholder community
        • Revise the RGF, as required, based on evaluation results

        The Independent Assessment Panel will be composed of WLA member representatives and non-industry people with experience in Responsible Gaming / Problem Gambling issues. It will be chaired by an objective party who is not directly involved in the industry nor the issues. The panel will assess the information provided by lottery operators, assess the quality of the assurance provided, designate levels and give feedback to lottery operators on their performance.

        With this in hand, the WLA is in a position to "award" the level to the member company.

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    • Level 1 - Assessing

      Level 1 Description: All WLA members automatically qualify for the first level of the Responsible Gaming Framework. Level 1 is the only required level in this Framework. Members will formally enter this level after submitting a letter from their CEO stating publicly that they have, as an individual organization, embraced the framework.

      Members will be actively encouraged by WLA through the provision of support tools and training to further progress into the other levels. Level 1 is, however, the only stage which is required.

      Program Element Member Actions
      • Senior management is committed to RGP and embracing the framework, as reflected in letter to WLA from CEO
      • Self-assessment is assigned to senior-level resource within the member organization
      Responsible Gaming Activity No self-assessment required entering this level, but organization need to complete self-assessment in order to move into any other level.
      Learning No self-assessment required entering this level, but organization need to complete self-assessment in order to move into any other level.
      Reporting No self-assessment required entering this level, but organization need to complete self-assessment in order to move into any other level.
    • Level 2 - Planning

      Level 2 Description: The organization has committed to the overall voluntary RG Framework process, to researching and integrating the key program elements of the Framework. They need to self-assess their performance, including the prioritization of actions based on gaps against the RG Principles, Framework and WLA Tools. Following a successful review by the independent panel, the member organization is allowed to use a logo that indicates Level 2 has been achieved. Members will have to re-qualify every two to three years if qualification for the next level has not been achieved within this timeframe.

      Program Element Member Actions
      • Conduct self-assessment signed off by CEO and submitted to WLA
      • Identify implementation resource(s) and high-level budget
      • Identify priority action items based on gap analysis
      • Communicate RGF commitment and key steps to relevant employees
      • Communicate progress to WLA
      Responsible Gaming Activity
      • Incorporate into above self-assessment information on members activity on responsible gaming (if any) and identify resources and priority action areas, as noted above, across the Responsible Gaming activities
        • Research
        • Employee training
        • Retailer programs
        • Game design
        • Remote gaming channels
        • Advertising & marketing communications
        • Player education
      • Include in above self-assessment information about the organization's approach to:
        • Engaging with stakeholders on responsible gaming issues
        • Information sharing with WLA members and participation in industry initiatives
        • Identify resources and priority areas for engaging with stakeholders on responsible gaming.
      • Conduct preliminary stakeholder identification and prioritization
      • Identify resources and priority action items related to sharing information with WLA members and participating in industry initiatives.
      • Identify resources and priority areas for public reporting.
      • Review good reporting practices, using WLA database.
    • Level 3 - Implementing

      Level 3 Description: The organization has established relevant resources and has developed a plan, timetable and approved budget to implement specific RG program elements, including the identification of priorities and required human and financial resources. It has solicited contributions from external stakeholders and has developed internal and external communications to support the all aspects of the plan. Following a successful review by the independent panel, the member organization is allowed to use a logo that indicates Level 3 has been achieved. Members will have to re-qualify every two to three years if qualification for the next level has not been achieved within this timeframe.

      Program Element Member Actions
      • Establish RGF team or assign individual
      • Establish implementation plan based on RGF, including all priority program elements, timelines and approved budgets
      • Communicate progress to WLA
      Responsible Gaming Activity
      • Establish internal resources and starting to establish programs, based on Tools, in responsible gaming activity areas
        • Research
        • Employee training
        • Retailer programs
        • Game design
        • Remote gaming channels
        • Advertising & marketing communications
        • Player education
      • Establish stakeholder engagement team or person and plan, based on Tool
      • Establish member-sharing and participation plan and undertaken some work in this area
      • Executed some stakeholder engagement
      • Establish and train reporting team or assigned individual; identify external support requirements
      • Create internal data-gathering mechanism
      • Gather data
      • Develop reporting plan based on Tool
      • Identify and evaluate third-party assurance resources
    • Level 4 - Continuous improvement

      Level 4 Description: The organization is implementing its plan to integrate the specific program element considerations into its operations, is integrating the considerations of external stakeholders, and has in place the people and/or processes necessary for continuous improvement. These programs are mature and well established. It is also using independent third-party assurance, and communicating against its plans both internally and externally. Following a successful review by the independent panel, the member organization is allowed to use a logo that indicates Level 4 has been achieved. Members will have to re-qualify every 2 to three years.

      Program Element Member Actions
      • Execute implementation plan of program elements in RGF
      • Communicate progress to WLA
      • Regularly monitor outcomes related to all program elements and revise programs as needed.
      Responsible Gaming Activity
      • Programs on responsible gaming are mature, well established
        • Research
        • Employee training
        • Retailer programs
        • Game design
        • Remote gaming channels
        • Advertising & marketing communications
        • Player education
      • Stakeholder engagement fully underway and well established
      • Full participation in WLA member-sharing and participation program
      • Draft public report according to Tool
      • Engage external stakeholders to validate reported information to ensure materiality and completeness of information
      • Hire third-party assurance consultants & conduct independent review
      • Publish and disseminate report

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    • Appendix - Program Element Glossary

      Formal commitment by members to implement the Responsible Gaming Framework in their organization.
      Responsible Gaming Activity:
      Formal and systematic development and implementation of five responsible-gaming-program areas: research; employee training; retailer programs; game design; and player education. *Note: This can be done independently, or in partnership with other member and non-member organizations.
      Research on responsible gaming issues:
      Systematic process to support and/or conduct, integrate and disseminate responsible-gaming-related research.
      Employee training:
      Systematic approach to ensure and support the efficient and effective application of RG principles by all relevant employees.
      Retailer program:
      Systematic approach to ensure and support the efficient and effective application of RG principles by retailers and their front-line staff.
      Game design:
      Systematic approach to applying evidence-based responsible gaming considerations to the design and introduction of new lottery and gaming products.
      Remote gaming channels (where applicable):
      Systematic approach to ensure that interactive/remote gaming platforms have safeguards in place that protect the player.
      Advertising & marketing communications:
      Application of policies and programs to ensure continuous improvement of responsible marketing and communications practices and application of codes.
      Player education:
      Systematic approach to support, integrate and disseminate information related to good practices in responsible play ("informed player choice") and treatment referral.
      Commitment to continuous improvement.
      Stakeholder engagement:
      Systematic approach to identifying, understanding and integrating the interests of decision-makers, decision-influencers and other members of society into key RG-related business decisions.
      Member cooperation and participation:
      Encourages sharing of cross-functional RG information and practices between WLA members and active participation in industry activities.
      Based on Tools provided by the WLA, member organizations will assess their own organization against the Responsible Gaming Framework and submit their self-assessment to the WLA for review by the independent panel. Member organizations will self-assess against the Framework each time they want to move up to another level.
      Third-party assurance:
      Member organizations require full assurance by an objective, third party for Level 4 only. Level 3 only requires that third-party assurance resources be identified and evaluated. There is no reference to third-party assurance in Levels 1 and 2.
      Systematic procedures for gathering, verifying and communicating commitments, actions and progress to the public or WLA

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  • Appendix 2 - European Lottery's Responsible Gaming Standard

    European Lotteries

      European lotteries are committed to address illegal gambling and related criminal activities while at the same time minimising any potential harm on society and vulnerable groups7 in particular by means of a controlled expansion of gaming Education and prevention is seen at the forefront of European lottery's commitment to responsible gaming.

      These standards have been created by the EL Responsible Gaming Working Group and include feedback from EL members. The objectives of the standards are:

      1. To foster the continuity of public order, integrity and the fight against illegal gambling and financial irregularities as defined under European legislation
      2. To identify best practice in respect of Responsible Gaming in the lottery sector
      3. To enable EL members to make Responsible Gaming an integral part of their daily operations and in doing so, to minimise harm to society.
      4. To state clear rules for EL members relating to their operations so as to:
        • ensure that the interests of players and vulnerable groups are protected
        • ensure that relevant laws, regulations and responsibilities are met
        • develop appropriate practices taking account of relevant information and research
        • develop a better understanding of the social impact of gaming.
        • promote the implementation of Responsible Gaming practices in all aspects of members' activities, and the activities of their agents
        • provide the public with accurate and balanced information to enable informed choices to be made about their gaming activities
        • to continuously improve, and public report on their Responsible Gaming programmes
      5. To enable EL members to demonstrate to society that their Responsible Gaming programmes are of an appropriate standard and have been independently verified.

      The treatment of people with gambling-related problems is the domain of therapists and other health care specialists.

      Whilst EL members are committed, where treatment services exist (see (2) vii), to collaborate with and lend support to service providers, the primary aim of members is to establish Responsible Gaming programmes to minimize the risk for all parts of society, in particular for vulnerable groups. These will be based on the principles of prevention and education.

      The Responsible Gaming Standards are expected to be adopted by all EL members in 2007 and implemented fully by all EL Members by the end of 2008, or at a different date as ratified by the EL Executive Committee. All members shall ensure that they comply with applicable laws and local jurisdiction at all times. In order to accommodate a rapidly changing gaming environment and new knowledge and research in the area of responsible gaming these Responsible Gaming Standards shall be reviewed at a minimum every other year.

      The standards are the primary element of an EL policy framework for Responsible Gaming; the policy framework will include other documents that supplement the standards, for example specific codes of conduct (such as the Code for Sports Betting) and various guidelines, which relate to Responsible Gaming practices within the EL community. The standards are designed to be complimentary to the WLA Responsible Gaming Principles and Framework, in that the EL standards specify outputs (i.e. it explains specific actions which EL Members shall take) that can be measured. It is expected that through the implementation of the EL Responsible Gaming Standards all EL members will, as a minimum, automatically meet Level 3 ('Implementing') of the WLA framework no later than the end of 2008. However, the EL Standards are intended, where necessary, to go beyond mere compliance with the WLA framework, as required in Europe.

      This document does not substitute any applicable laws and regulations within each Member's jurisdiction, but sets standards on Responsible Gaming which EL Member State Lotteries commit to follow accordingly.

      7The term 'vulnerable' groups can relate to different aspects of society, but in these standards means those that are below the age of legal play in any jurisdiction, those on low incomes, those that already have a gambling addiction, those who are sales agents, employees or contractors and/or those that are not aware of the risks associated with problem play.

    • 2. STANDARDS

      • i. Research

        Members shall, working with appropriate stakeholders, promote (e.g. initiate / engage in / communicate the results of) research and/or studies, including from independent sources in order to contribute to society's understanding of problem gambling. These results shall also been used for the formulation of future responsible gaming measures.

        This may include the funding of research and/or studies as well as arranging or participating in seminars, conferences and the support of the EL's work on responsible gaming initiatives.

        The responsibility for prevalence studies usually rests with the state. However, members shall co-operate with these studies where required.

      • ii. Employee training

        Members shall provide all employees with information on their Responsible Gaming programmes through appropriate communication channels at a minimum on an annual basis.

        Members shall ensure that an appropriate level of awareness relating to Responsible Gaming is maintained throughout the organisation, so that Responsible Gaming is made an integral part of daily operations.

        Relevant employees (including temporary staff and contract staff) shall, based on job demands and customer interaction, receive training on Responsible Gaming, including (where applicable) training on treatment referral for potential problem gamblers (see (2) vii). Preference should be given to specialist training providers for the provision of this training.

        Where a legal age of play exists in any jurisdiction, all employees that sell lottery products shall receive training that enables them to request validation of a person's age through appropriate means (i.e. ID or secondary forms of identification).

      • iii. Sales agents' programmes

        All sales agents shall be provided with information materials (e.g. brochures, leaflets, posters etc.) in order to raise their awareness of Responsible Gaming and to educate them on issues relating to problem play.

        Before new sales agents are allowed to sell members products they shall be provided with training on Responsible Gaming. Tailored training may be provided to retailers depending on the range of products they sell on behalf of members. Preference should be given to specialist training providers for the provision of this training.

        Members shall ensure that sales agents are informed (in writing) that they are prohibited from offering credit facilities to players, excluding (in some jurisdictions) the acceptance of credit cards.

        Members shall, where applicable, regularly assess the feasibility of providing training to sales agents in respect of treatment referral and the subject of problem gambling.

        Where members offer self-exclusion facilities, such as a player card, sales agents shall be informed (in writing) how the schemes operate and can be activated/removed by or for players.

        Members shall review the adequacy and effectiveness of sales agents Responsible Gaming programmes at least annually.

      • iv. Game design

        Before launching every new type of product/service, members shall conduct a social impact assessment using a structured assessment tool to examine relevant risk factors. Members shall implement effective strategies to minimize the negative impact of these risk factors. The risk factors shall be documented and any harm-minimization strategies clearly recorded so that the assessment can be reviewed as necessary.

        Thus, members need to be aware of the risk factors related to problem gambling at product level (e.g. event-frequency, win probability, near-miss), at situational level (e.g. location and number of gaming venues) and at organizational level (e.g. marketing and advertisements).

        Members shall only operate new types of products/services that are assessed (during the social impact assessment) to be 'high-risk' if doing so will enable an existing risk in the marketplace (i.e. if a product or service operated by someone other than the lottery member) to be reduced or regulated more effectively by the lottery member.

        Members shall consider whether any social impact assessment, but particularly those that indicate a 'high risk' product/service, should be supported by verification from an independent third party, and document the decision/outcome as part of the social impact assessment. Self-exclusion options should be built in wherever operationally possible.

      • v. Remote gaming channels

        Members shall, were applicable, assess the feasibility of arranging a periodic independent review of these platforms, in respect of their adequacy from a Responsible Gaming perspective, if this leads to a recognised accreditation from the independent third party (such as GamCare, G4 etc.). The outcome of any review should be documented and any action should be included in an action plan with specific owners and target dates. The outcome of such reviews shall be made available to the EL during the EL certification process (see xi.).

        Where applicable and depending on the products offered, members shall ensure that their remote gaming platforms (internet, TV, mobile devices) include e.g.:

        • Proof of address
        • Age verification systems
        • Customer-led and/or system default limits on play, spend and/or losses
        • Self-exclusion options for players
        • Reality check on the game screen (e.g. session clock, warnings relating to limits, cool offs/breaks between periods of play)
        • Data protection controls
        • Value of wagers shall be displayed
        • Self-assessment opportunities to help people to evaluate whether they are playing responsibly.
        • Links on every webpage to information about responsible gambling, the member's policies on responsible gaming, and sources of advice and support (e.g. helpline numbers, referral to treatment providers8). Members shall ensure that contact centre staff are able to refer to these sources of advice and support.

        Where applicable, members shall also assess, at least annually, the extent that the above arrangements can be implemented in respect of ITVM and/or VLT products/services, for example through the use of player card or other registration schemes. Members shall document the content and results from the review, where applicable.

      • vi. Advertising and marketing

        Members shall not direct advertising at vulnerable groups (in respect of age, social status, or gambling habits).

        Members shall adopt an 'advertising and marketing code which ensures that advertising and sales promotion activities do not encourage underage or problem play and do not provide the player with misleading information such as a false impression of the odds of winning.

        8 See (2) vii

        Members shall also comply with relevant voluntary and/or mandatory codes relating to the provision of their services. Members' own code shall specify which mandatory and/or voluntary codes are applicable to their span of operations.

        The code shall ensure that advertising and marketing campaigns:

        • do not offer unreasonable incentives for loyalty that are linked to winning more based on gambling more
        • only ever accurately portray winning as a matter of pure chance
        • only ever accurately represent the chances of winning, prizes and odds etc.
        • exclude any content that is designed to exploit an individual's financial anxieties
        • do not state or suggest that playing9 is an alternative to work or a way out of financial difficulties
        • do not encourage discrimination on the basis of ethnicity, nationality, religion, gender or age
        • exclude any content that includes or encourages violence, sexually exploitative themes or illegal behaviour
        • do not cooperate and support links or other commercials that are offering quick loans that can be drawn upon immediately for the purpose of playing
      • vii. Treatment referral

        Members shall actively engage with problem gambling organisations, treatment centres and/or health professionals in order to understand the problem gambler's perspectives on the impact of lottery products and related advertising on their situation.

        Where treatment services exist in a jurisdiction, members shall (unless an alternative organisation has been selected for this purpose in a jurisdiction) provide relevant information to players and sales agents and cooperate with providers regarding services available for problem gamblers. Such information (contact details/helpline numbers) shall be available in printed form and should be clearly visible in gaming venues, as well as being available on members' websites.

        The applicability, adequacy and effectiveness of these arrangements shall be reviewed at least annually by members.

      • viii. Player education

        Members shall include these features in information designed for players (including on remote channels):

        • detailed information on the odds of winning on each game which allows people to assess the risks and benefits of playing
        • age restriction measures (if applicable)
        • Responsible Gaming information and information on where to get help in cases of problem play (see (2) vii)
        • 9 Members are free to use the winning experience as a positive aspect of advertising and marketing. The risk is that the act of playing may be presented as an alternative to work, rather than playing for fun with the hope of winning.

        If the above information is not available in printed form in gaming venues (e.g. retail stores) members shall ensure that details of how to obtain such information is clearly available to players/retailers (agents). Where material is available in printed form it shall be placed where it can be taken discreetly. If ATMs are located in the location, leaflets shall be placed near to those.

      • ix. Stakeholder engagement

        Members shall regularly engage with their stakeholders formally and informally and include this in their reporting mechanisms. Engagement shall cover issues that are material to the stakeholders and the individual member. In the breadth of stakeholders that are being invited members shall be inclusive.

        The engagement shall provide an opportunity for stakeholders to voice relevant concerns or questions.

        Members shall integrate the results of stakeholder engagement into their strategic-decision-making processes and shall feedback to relevant stakeholder(s) on the outcomes from engagement processes.

      • x. Reporting, Measurement & Certification

        Members shall report (or have agreed to begin reporting from a specified date) on the impact and breadth of their Responsible Gaming programmes to their stakeholders. The reporting shall include policies for responsible gaming, targets, commitments and indicators and shall occur periodically.

        Reporting shall be transparent using channels which are most appropriate and accessible for the targeted stakeholder audience.

        Members shall arrange independent verification of their Responsible Gaming activities against these standards as specified in separate guidance relating to the EL certification process.

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