Gambling Policy

CLIC Sargent Cancer Care for Children, trading as Young Lives vs Cancer (“Young Lives vs Cancer”) and its subsidiary CLIC Sargent Lottery Limited (“CSLL”) are committed to ensuring that all our lottery activity is operated in a secure, fair and socially responsible way. CSLL is licensed to operate lotteries by the Gambling Commission. CSLL holds a remote licence and a non-remote licence issued by the Gambling Commission in order to enable it to operate and promote lotteries. CSLL has two Annex A holders on these licences.

This policy details the measures in place to ensure that our lottery activities are conducted in line with the regulatory framework set out by the Gambling Act 2005 (the “Act”) by:

• Preventing gambling from being a source of crime and disorder, being associated with crime and disorder, or being used to support crime;
• Ensuring that gambling is conducted in a fair and open way; and
• Protecting children, problem gamblers and other vulnerable persons from being harmed or exploited by gambling.

Our gambling licences are held by CSLL, a wholly-owned subsidiary of Young Lives vs Cancer. This policy applies to lotteries operated on behalf of the Young Lives vs Cancer by External Lottery Managers (“ELMs”) engaged by CSLL.

Fundraising activity involving gambling at CSLL is limited to lotteries (including raffles) and although these activities are generally considered to be low risk for problem gambling, as a holder of a licence which promotes and operates lotteries, CSLL will at all times adhere to the legal requirements of the Act. This policy is in place to ensure that people take part in CSLL Lotteries responsibly and in accordance with the requirement of the Act.

Supporters and members of the public may refer to this policy to understand the control framework we have put in place to manage our lottery activity.

Members of the workforce must familiarise themselves with their responsibilities where they are directly engaged in managing our relationships with ELMs.

This policy also sets out the responsibilities we have put in place with our ELMs.

Annex A holders: Those individuals identified on gambling licences as the licence holders. The licensees must comply with specific responsibilities outlined by the Gambling Act (2005).

CSLL Lottery: any lottery (Remote or Non-remote) operated by or on behalf of CLIC Sargent Lottery Limited.

External Lottery Managers: Third party companies engaged by CSLL to manage out lottery operations.

Gambling Commission: the regulatory body responsible for overseeing and regulating all forms of gambling, including charity gambling.

Members of the workforce: includes all employees and volunteers employed or engaged by Young Lives vs Cancer in the delivery of any lottery activity unless otherwise stated.

Non-remote Lottery: a lottery in which persons are invited to participate through door-to-door canvassing or by normal letter post or in person.

Remote Lottery: a lottery in which persons participate by use of remote communication including the internet, telephone or any other electronic or technological method of communication.

Supporters: individuals or entities who actively participate in or contribute to gambling activities in support of Young Lives vs Cancer.

5.1 Promoting Responsible Gambling

We have put in place the following procedures to encourage you to gamble responsibly and seek help should gambling become a problem:

• BeGambleAware helpline number and website address will be published on CSLL Lottery advertising collateral and on websites where gambling is advertised, as well as where a Supporter can purchase CSLL Lottery tickets.
• You cannot purchase entries into a CSLL Lottery using credit cards via remote means; debit cards are permitted.
• You can request a self-exclusion from CSLL Lotteries at any time by contacting us via telephone, email or post. Anyone wishing to self-exclude will be excluded for a minimum period of 6 months. Self-excluders will not receive any future gambling-related marketing materials, unless after the minimum period of 6 months has expired and the self-excluder takes positive action in order to gamble again and has specifically agreed to such materials. You can also opt out of hearing about gambling-related products and this option will be available in any lottery promotion emails as well as general unsubscribe options.
• If you want to gamble again you must take a positive action after the 6 months have passed. A 24-hour cooling off period will be given where an additional positive action will be required before you are permitted to gamble again.
• We will signpost you to additional support, e.g. BeGambleAware, if you choose to self-exclude.
• Where you have self-excluded we will remove you from future gambling-related marketing for the duration of your self-exclusion.
• You cannot purchase more than £5 worth of tickets per draw.
• We will make a payment each year to the Lotteries Council to fund research, education and treatment activities in relation to problem gambling.
• We will declare on our annual regulatory return to the Gambling Commission the number of Supporters who self-exclude because of problem gambling.

5.2 Responsible Gambling Information for Supporters

While the majority of our Supporters gamble within their means, we recognise that, for some, it can be more difficult.

Our intention is to present you with opportunities to enjoy the chance of winning prizes, whilst raising money to support our charitable work. These prizes do not encourage problem gambling and are set within sensible spending limits.

We encourage you to bear the following principles in mind before you engage in any lotteries run by or on our behalf:

• You are buying fun, not investing money.
• You should set strict limits on how much time and money you are willing to spend.
• You should quit while you are ahead.
• You should only gamble with money you can afford to lose.
• You should not spend more money in the hope of winning back what you have lost.
• You should keep up other interests and hobbies, not let gambling take over your life.
• You should not gamble in order to escape from stress or boredom.
• Gambling in moderation is okay.

5.3 When gambling can become a problem

If you are concerned about the amount you are gambling, (or you are concerned for a friend or relative) then the following questions may help give some guidance.

• Have you been criticised for your gambling?
• Have you lied to cover up the financial amount or the time you have spent gambling?
• Do arguments, stressful situations or disappointments make you want to gamble?
• Do you gamble alone for long periods?
• Do you stay away from work or college to gamble?
• Do you gamble to escape from a boring or unhappy life?
• Are you reluctant to spend ‘gambling money’ on anything else?
• Have you lost interest in family, friends or pastimes due to gambling?
• If you lose, do you feel you must try to win back losses as soon as possible?
• When you run out of money while gambling, do you feel lost and in despair, and feel the need to gamble again as soon as possible?
• Do you gamble until your last penny is gone?
• Have you lied, stolen or borrowed just to get money to gamble or to pay gambling debts?
• Does your gambling ever make them feel depressed or even suicidal?

If you feel you are answering ‘yes’ to the majority of the questions above, then it is likely a gambling problem exists. Sometimes just telling someone about your concerns can be a relief and the first step toward dealing with your problem.

For friendly and helpful advice and support you can call The National Gambling Helpline on 0808 8020 133 or visit begambleaware.org for information or to use their live chat feature. Both the helpline and live chat are available 24 hours a day, 7 days a week.

6.1 Promoting responsible gambling

Members of our workforce are responsible for attending training on our lottery arrangements which includes promoting responsible gambling and applying it where relevant in their roles. This training includes, amongst other topics, spotting behaviours which may indicate a Supporter is a problem gambler.

6.2 Prohibition on participation

The following members of our workforce and their families are prohibited from participating in any lotteries which are run by or on behalf of CSLL:

We will take appropriate action, as per Young Lives vs Cancer’s disciplinary policy, if we become aware of any member of staff directly or indirectly associating in criminal activities, whether that activity is confirmed or alleged.

6.3 Protecting Children and Vulnerable People

To prevent underage players from participating in any lotteries promoted by us we will:

• Check our databases, where possible, to ensure people are above the legal age limit before data is supplied for the use of a lottery.
• Detail the minimum age for play (which is 18) on the websites where lottery tickets can be purchased.
• Quarterly select at random three smaller prize winners from our lottery and retrospectively verify their age (either by phone or open-source material) and record that age verification has occurred on their record.
• If suspicion arises that a player may have been dishonest about their age we will try to obtain age verification by telephoning the player (where we have their number and permission), consulting other open-source material such as the electoral register and finally by writing to the individual. If we are still unable to obtain this verification, we will terminate the individual’s account and return all monies paid.
• Ensure lotteries are not intentionally designed to appeal to children or young people who are underage by making it clear on all material that a player must be 18 or over to play.
• Continuously review where and how we advertise our lotteries to ensure we do not intentionally appeal to children or young people who are under 18.
• Mark a record as ‘Opt-Out’ on our database where a request to cease sending lottery marketing material is received from either an individual or a vulnerable person’s carer in relation to the vulnerable person, as long as we have suitable permissions or Power of Attorney for the carer to make decisions on behalf of the individual.

6.4 Preventing Gambling from Becoming a Source of Crime

When gambling becomes mixed up with illegal activities like money laundering or organized crime, it damages trust in the charity and harms society. To prevent our lotteries becoming a source of crime, members of our workforce must:

• Refuse to be associated with any proposed Lottery scheme or gambling activity that may breach the law and report any concerns immediately to the Head of Finance Operations so that reporting to the Police or SOCA (Serious Organised Crime Agency) can be considered and actioned, where appropriate.
• Refuse to contract with any contractors or agents who we suspect may be associated with any potential or actual criminal activities and report any concerns immediately to the Head of Financial Operations so that reporting to the Police or SOCA (Serious Organised Crime Agency) can be considered and actioned, where appropriate.
• Where required by law, only use suppliers who are licensed by the Gambling Commission to run all or part of our own lottery business.
• Require all suppliers to:
  • ensure they provide suitable employees and obtain references from all prospective employees that are likely to be associated with our gambling business.
  • ensure all staff working on behalf of CSLL must complete training on our policies and understand their responsibilities on working within the law.
  • monitor their employees on an ongoing basis, particularly regarding their direct or indirect association with potential criminal activities.

CSLL performs careful review of suppliers and regularly monitors their performance to ensure they meet the requirements of this policy.

7.1 Preventing Gambling from Becoming a Source of Crime

We engage external lottery mangers to manage the administration of lotteries on our behalf. To ensure our lotteries are do not become mixed up in illegal activities we require our ELMs to:

• Ensure all monies received for lotteries are held in trustee status by our ELM to maintain a separation from their own trading income. Our ELM will pay the full lottery proceeds into the CSLL bank account weekly.
• Ensure no person is enrolled into any of our lottery schemes if that person is suspected of any potential or actual criminal activities.
• Freeze any transaction that appears to be suspicious, and any other transaction made by the same supporter.
• Conduct and regularly review an assessment of the money laundering risks to its business and record the outcome on the risk register.
• Ensure they investigate unusual patterns of transactions and very high account turnover thoroughly as and when they occur.
• Prevent Supporters from purchasing more than £5 worth of tickets per draw.
• Ensure any actual or suspected criminal activities are reported internally, to us, to the Gambling Commission and, if deemed necessary, to the police.
• Ensure only Supporters residing in Great Britain are permitted to enter lotteries run by CSLL.
• Ensure all transactions on a player’s account are recorded and securely stored.
• Use payment provider(s) that have experienced risk and fraud teams who scan, validate and monitor payment card transactions for potentially suspicious transactions.
• Obtain references from all prospective employees who are likely to be associated with CSLL’s gambling business.
• Take appropriate action as per their own disciplinary policy, if made aware of any member of employees directly or indirectly associating in criminal activities.
• Train all employees involved in promoting lotteries or selling lottery tickets to a satisfactory standard to ensure compliance with CSLL Lottery policy and procedures and keep an up-to-date checklist of employees who have read the policy and signed a form to confirm.
• Operate from secure premises, with fire safes in situ, and use approved security service providers.
• Ensure they have in place and keep maintained their own Anti-Money Laundering Policy.

7.2 Protecting Children and Vulnerable People

To prevent under age players from participating in any lotteries promoted by us our ELM will:

• Detail the minimum age for play (which is 18) on the websites where lottery tickets can be purchased.
• Require any player entering via remote communication to provide a valid DOB and affirm their age.
• Ensure any form of acquisition activity to purchase lottery tickets contains:
  • a request for the applicant’s date of birth;
  • a statement that underage gambling is an offence.
• Age verify first and second place prize winners from our lottery by phone, before issuing the prize and record that age verification has occurred on their record.
• Return monies paid in relation to the lottery to any player that is found to be under age.
• Include in the rules that any prizes will not be provided to anyone who is found to be under-age.
• Ensure lotteries are not intentionally designed to appeal to children or young people who are underage by making it clear on all material that a player must be 18 or over to play.

7.3 Keeping Draws Fair and Open

Our ELMs will:

• Ensure all lottery-related websites comply with the Licence Conditions and Codes of Practice (LCCP) and include:
  • The charity’s name, address, company registration number and charity registration number
  • The name and address of the member responsible for promoting the lottery
  • The ticket price
  • The date of the draw, or sufficient information to enable the date of the draw to be ascertained
  • The Gambling Commission account number and link to the Gambling Commission’s register
  • A clear statement that persons under the age of 18 may not sell or purchase tickets, and will be unable to receive a prize

• Ensure that the following information is detailed within the rules of each lottery and is signposted to supporters prior to them entering the draw:
  • The prize list for each lottery draw
  • A description of how winners are determined and how prizes are allocated
  • The likelihood of winning a prize, which can be based on current or previous year
  • The percentage of the proceeds spent on prizes (including prizes rolled over) – can be based on previous year
  • The percentage of the proceeds spent on expenses related to promoting and running the lotteries – can be based on previous year
  • The percentage or amount of the proceeds applied directly to the purposes of the society and the total proceeds from all tickets sold.
• Use a certified random number generator to conduct all draws.
• Notify winners within 7 days of the draw taking place.
• A list of winners, including winning numbers, will be published on the CSLL Lottery mini-website. The winner’s list will also be available on request, in hard copy or via email.
• If a first or second lottery prize winner has moved and cannot be located our ELM will not be able to fulfil the requirements of the insured prize and it must therefore be returned to the ELM’s insurance company as an unclaimed prize.
• If a lottery prize winner wishes to donate their prize to CSLL they must bank the prize and then donate this directly to Young Lives vs Cancer. This can be done via the Charity’s website or by cheque.
• Prohibit any employees who are involved in the lottery operations from playing CSLL’s lottery.

To comply with the Act and the LCCP, CSLL’s licence holders (and any individual with responsibility delegated by the licence holders) will:

• Ensure any promotional materials for the lottery are clear and not misleading, and all advertising for the lottery complies with the advertising code of practice applicable to the form and media the advert is in.
• Ensure we publish lottery rules on the Charity’s lottery website and ensure that any significant changes to how the Lottery is run will be communicated to all players by post or email.
• Ensure CSLL and our ELM comply with the Gambling Commission’s remote technical standards.
• Publish the proportion of money raised from ticket sales in the previous year that was returned directly for the purposes of the Charity.
• Keep a record of all remote ticket sales for a minimum of 3 years.
• Keep a record of all lottery submissions for a minimum of 3 years, these records will include:
  • Lottery draw date
  • Branded / non-branded lottery
  • Type of lottery (raffle or subscription)
  • Ticket cost
  • Largest prize
  • Total prizes
  • Total proceeds of the lottery
  • Expenses incurred for each lottery and details of those expenses
  • Percentage of proceeds allocated directly to the purpose(s) of the Charity (at least 20% of the gross proceeds)
  • Percentage allocated to prizes in each lottery
  • Number of unsold tickets in each lottery
  • Statement of confirmation

All complaints relating to lotteries and gambling will be handled in accordance with Young Lives vs Cancer’s Complaints Policy and will be reported to the Gambling Commission on an annual basis, via the Annual Regulatory Returns.

This Policy will have a minor review every year and a major review every 3 years. However, it may be reviewed at any time to reflect changes to law, guidance, regulations or licencing requirements.

All members of the workforce who are directly engaged in managing our relationship with External Lottery Managers are required to read this policy before they start working on CSLL Lotteries, and whenever the policy is updated. All relevant staff are required to sign a document to confirm that they have read and understand their responsibilities under this policy.