Annex B
SOCIAL RESPONSIBILITY CODE REMOTE BETTING
AND CASINO GAMING OPERATORS
"The responsibility for an individual's
gambling is their own; the responsibility to exercise a duty of
care is that of the operator."
1. This code of practice details the procedures
and policies that a remote gambling operator should adopt to demonstrate
commitment to being socially responsible.
COMMITMENT
2. Quite apart from the fact that a responsible
gambling company should recognise that it has a duty of care to
its customers, changing legislation will, to some extent, make
it a statutory requirement. It is therefore in operators' interests
to:
— Recognise that social responsibility
is essential to the healthy development of the gambling industry
as a whole, as well as to the individual operator.
— Develop a culture that is supported by
policies and procedures that demonstrate commitment to social
responsibility.
— Strive to achieve an appropriate and
fair balance between maximising opportunity and minimising harm.
COMPLIANCE WITH
CODES OF
CONDUCT
3. The need to demonstrate that a business is
run in a socially responsible manner is an important aspect of
regulation. Operators and the services they offer are subject
to regulation and are likely to be members of a trade association.
They will also have their own rules and procedures designed to
protect their businesses, enhance the customer experience and
minimise harm to the vulnerable. It is therefore important that:
— All relevant staff are made aware of,
and understand, company and trade association guidelines and codes
of practice.
— The requirements of the guidelines and
codes are adhered to.
— Regulatory requirements are met.
ADVERTISING AND
PROMOTION
4. It is appropriate that gambling activities
are advertised and that an operator is able to promote the facilities
available; however all promotion should conform to the Electronic
Communications Directive 2003 and guidelines issued by the Advertising
Standards Authority and the Independent Television Commission,
specifically:
General Principles
— Advertisements should be legal, decent,
honest and truthful.
— Advertisements should be prepared with
a sense of responsibility to consumers and to society in general.
— Promotional email should only be sent
to persons who have agreed to receive it.
— No advertisement should bring the advertising
industry into disrepute.
Betting and Gaming
— Advertisements should contain nothing
that is likely to lead people to adopt styles of gambling that
are inappropriate for them.
— Advertisements and promotions should
be socially responsible and should not encourage excessive gambling.
— Care should be taken not to exploit the
young, the immature or those who are mentally or socially vulnerable.
— Advertisements should not be directed
at people under the age of 18 through the selection of media,
style of presentation, content or context in which they appear.
No medium should be used to advertise gambling if more than 35
per cent of its audience is known to be under 18.
— Persons portrayed gambling should not
be, nor appear to be, under 18.
In addition to the regulatory requirements:
— There should be honesty at all times
with regard to the chances of winning, and the odds or payout
ratio that applies to the gambling on offer. Free play games should
operate to the same payout ratio as cash games.
— Promotional material should carry a reference
to responsible gambling, similar to the cautionary statements
for financial investments.
— Advertising should never suggest or imply
that gambling is a way of getting out of financial difficulty.
PRODUCT PURCHASE
5. It is appropriate that customers are made
to feel welcome, are offered advice about the gambling facilities
on offer and given help on anything they don't understand. Such
assistance should not encourage customers to:
— Re-stake their winnings; that should
always be their decision.
— Increase the amount they have decided
to gamble.
— Chase their losses.
— Continue gambling when they have indicated
that they wish to stop.
— Enter into continuous play for a prolonged
period of time.
UNDERAGE GAMBLING
6. Even though it is illegal for anyone under
the age of 18 to engage in betting or gaming, it is not always
easy to ensure that children are excluded. Operators should adopt
measures to minimise underage gambling, including:
— Clear notices on the website stating
the minimum age to use the facilities.
— Publicising and operating an appropriate
age verification scheme.
— Registering with a filtering service
that enables parents and other responsible adults to prevent access
to gambling sites.
— Having a clear policy and procedure for
dealing with underage gambling and ensuring that it is followed.
— As far as possible, not making the appearance
of the website attractive to children.
STAFF TRAINING
7. All customer-facing staff should be trained
in social responsibility that should:
— Encourage ownership of the operator's
social responsibility policies and procedures.
— Raise awareness of the issues, emphasise
the importance of taking social responsibility seriously and enable
staff to deal with relevant situations in an appropriate manner.
— Give staff the skills and confidence
to respond appropriately when customers express concerns about
their gambling.
— Involve appropriate external organisations
in staff training where in-house resources are not available.
PROBLEM GAMBLING
8. Dealing with a suspected problem gambler is
a delicate matter that needs to be approached sensitively. Appropriate
responses should include:
General
— Written rules and procedures on how to
deal with problem gambling incorporated into the day-to-day operation
of customer services.
— Staff training to deal with situations
that might arise.
— Positive engagement with the customer,
communicating sources of help and the player protection facilities,
where they have admitted to losing control of their gambling or
are showing signs of distress that may be caused by their gambling.
— Where a relative of a customer expresses
concern about their gambling, staff should draw their attention
to the player protection facilities as well the other sources
of available help.
— Supplying telephone numbers of organisations
that provide assistance with problem gambling.
Player Protection Measures
— An up-to-date account balance, displayed
at all times, will help customers monitor their spending.
— The current time, derived from the customer's
computer, will help customers monitor the time spent on the operator's
website.
— A facility to limit the amount deposited
on the operator's website, so a customer can specify a daily or
weekly amount beyond which further deposits will not be accepted.
There should be a delay of at least 24 hours before any request
to increase a limit comes into effect.
— A facility to limit the amount of time
spent on rapid-play games, so that customers can specify how long
they play such games without a break. The minimum session duration
should be 10 minutes. When the limit is reached during play, the
customer should be informed how long he has been playing and be
required to provide acknowledgement before continuing.
— The provision of a self-exclusion facility
for any customers who wish to exclude themselves from gambling
on the operator's website. During the chosen period the customer
will also be excluded from all forms of communication from the
operator.
CUSTOMER COMMUNICATION
9. Without compromising the principle that
customers are responsible for their own gambling, the nature of
the activity is such that they should be reminded of the need
to gamble responsibly. Customer communication should therefore:
— Give clear guidance that in order for
gambling to be a fun, social activity, the customer needs to "stay
in control".
— Draw attention to information on the
website about player protection and responsible gambling.
— Indicate sources of help and how they
can be accessed.
PROMOTING SOURCES
OF HELP
10. At the core of exercising a duty of care
lies the helping of customers to address concerns about their
gambling should they wish to do so. The availability of such assistance
should be brought to the attention of customers in the following
ways:
— Displaying the logo of, and a link to,
the operator's social responsibility partner on the website's
home page.
— The display of a link to the area of
the website where sources of help can be found.
— Providing an area of the website that
sets out the operator's duty of care policy, that emphasises the
need to keep gambling under control and shows where to seek help
should anyone be concerned about their own or someone else's gambling.
SUPPORTING SOCIAL
IMPACT INITIATIVES
11. The gambling industry recognises that the
social impact of gambling is a concern of Government and other
bodies, and that under the new regulations formal codes of social
responsibility will be a likely requirement of obtaining an operator's
licence. ABB believes that the most effective way to address the
concerns is for the industry to work together with the relevant
organisations, which would achieve the following:
— Ensure social responsibility measures
are in place before operating licences are issued or renewed under
the new regulations;
— Recognition that a socially responsible
approach is advantageous to operators as well as to their customers;
— Financial support for the development
of treatment, training, education and research programmes provided
by organisations such as the Gambling Industry Charitable Trust;
— Support and encouragement of the work
of organisations working with the social impact of gambling;
— Ensure that product design and promotion
is in line with these guidelines;
— Involve appropriate organisations in
the development of operators' socially responsible procedures,
including induction and on-going training programmes.
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