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18 January 2018 - Minutes of the meeting of the Board of Commissioners


  • John Baillie
  • Sarah Harrison (CEO)
  • Alison Hastings (by phone. Left meeting 12:15)
  • Bill Moyes (Chair)
  • Sarika Patel
  • Trevor Pearce
  • Simone Pennie
  • Jonathan Scott
  • Catharine Seddon

Executive Directors:

  • Sarah Gardner
  • James Mackay
  • Neil McArthur (General Counsel)
  • Tim Miller
  • David Pemberton

In Attendance:

  • (REDACTED) – Senior Manager, Lotteries Maximisation (item 3)
  • (REDACTED) – Senior Manager, Consumer Policy (item 4.2)
  • (REDACTED) – Senior Manager, Business Planning (item 6.2)
  • (REDACTED) – Manager, Sector and Thematic (item 4.1)
  • James Holdaway – Head of National Lottery Licensing (item 3)
  • Paul Hope – Programme Director (item 4.2)
  • Anna Howe – Programme Director (item 8)
  • Simon Knee – Head of Finance (item 6.1)
  • Tamsin Morgan – Head of Communications (item 9)
  • (REDACTED) – Senior Manager (item 3)
  • Oliver Sweeney – Head of Legal (left meeting 1:30)
  • Helen Venn – Programme Director
  • Mark Wagstaff – Head of Governance (notes)
  • Richard Watson – Programme Director (left meeting 12:00-1:30)

External attendees:

  • (REDACTED)– Chair, RGSB (lunch guest)
  • (REDACTED)– Abberton Consulting (item 4)


  • Carol Brady (left meeting at 10:00)


  • Stephen Cohen

Item 1: Welcome, apologies and declarations of interest

  1. The Chairman welcomed Carol Brady, who would join the Board from the February meeting. There were no new declarations of interest.

Item 2: Minutes and actions from the meeting on 7 December 2017

  1. The Board agreed the minutes of the meeting held on 7 December 2017 subject to minor revisions and noted the rolling actions.

Item 3: National Lottery 4th Licence

Competition governance GCP(18)01

  1. The Board noted the paper.

Operating model and business case GCP(18)02

  1. The Board noted the paper.

  2. An Expert Advisory Group had been established to support thinking and provide challenge around development of the competition framework. This group would provide updates on its work to the Board periodically.

  3. The Executive would give further consideration to the time commitment required for a Committee to oversee the 4th licence competition and how this would fit with other commitments.

Item 4: National Lottery 3rd licence

Update on Camelot’s board effectiveness review GCP(18)03

  1. The Board noted the paper.

Camelot’s marketing investment proposal GCP(18)04

  1. The Board noted the paper and the matter was considered.

Item 5: Consumer protection

Consumer Interest Assessment GCP(18)06

  1. The Chairman welcomed Abberton Consulting to the meeting, who had been working with colleagues on proposals to strengthen consumer insight, to help deliver the Corporate Strategy.

  2. Abberton Consulting set out the importance both of organisational mechanisms and an effective culture to recognise consumer outcomes. This included developing skills and capacity in the organisation to ensure that consumer interests were central to policy thinking.

  3. The work also proposed establishing a standing panel of consumers to test out policy ideas. The Board considered that any such panel should include a broad range of voices, for example those who experienced no difficulties with their gambling, noting also that it would be ethically difficult to include those with gambling problems on the panel.

  4. The panel could help the Commission understand how the market works as a whole, including the nature of positive experiences from gambling. Establishing a panel would also assist in challenging any asymmetry around the Commission engaging more actively with industry than with consumers.

  5. The Board was broadly content with the recommendations, subject to further thought about the panel’s composition and role.

LCCP: addition to Fair and Open consultation GCP(18)07

  1. In December 2017, the Board had agreed consultation on various changes to LCCP to support work to ensure that gambling was conducted in a fair and open way.

  2. The change would improve our ability to enforce service standards for ADR providers, to ensure that consumers received consistent levels of service.

  3. The Board agreed that this issue should be included in the consultation to be launched in January 2018.

  1. The Commission undertook a procurement in 2012 to appoint external legal advisers. In light of upcoming contract expiry, Oliver Sweeney updated the Board on the tender process and presented recommendations for the appointment of preferred legal advisers.

  2. The Board agreed appointment of the recommended advisers.

Item 7: Business Performance

Finance Report GCP(18)09

  1. The Board questioned the number and duration of outstanding vacancies, in relation to the position on staff costs. David Pemberton confirmed that recruitment was underway in a number of areas, however Birmingham presented an increasingly challenging employment market. There was increased use of panel recruitment in areas such as Licensing where a reliable level of turnover made over-recruitment a cost-effective approach.

  2. Given the wider government agenda to develop regional hubs, it was possible that a larger applicant pool might develop in Birmingham, alongside increased competition. There was also a risk of an inflationary effect on pay. The Board noted a need for strategic workforce planning to look at how these trends would impact the Commission.

Board Performance Report GCP(18)10

  1. The Senior Manager, Business Planning, updated the Board on development of the new performance reporting framework. The framework had been tested with staff in workshop sessions and responses were positive.

  2. The Board commended the new framework as linking clearly to corporate objectives and correlating with strategic risks. There was still work to do in some areas, however the framework showed considerable development since the previous iteration.

  3. The Board suggested that the framework could be improved by highlighting areas where the Commission should pay further attention. On the NL 3rd licence, the Board considered that the framework was effective at showing Camelot’s performance, but needed more information on what we were doing. The NL 3rd licence was one of the most significant areas, alongside performance in Licensing and actions to prevent harm to consumers and the public.

  4. The Board also noted that material presented was the level two report. The level one report (one page summary) would be provided when the framework returned to Board in April. Where additional actions were planned or proposed, these should be SMART and the Board should give further thought to what else it would like to see reported in the framework.

Casework summary update GCP(18)12

  1. Casework remained busy, with remote casino work consuming resource. There was a risk that other things could move into Enforcement action.

Compliance update

  1. The GVC merger was the key ongoing activity. Compliance interaction was moving to a key point of contact approach for larger operators. An update on Annual Assurance Statements was due to come to Board in March. Submissions on the revenue question had dipped into regulatory action for some operators. The ‘show don’t tell’ approach in the AAS had revealed a number of issues.

  2. The Board noted that compliance workload was increasing and questioned the criteria for intervention. Helen Venn explained that corporate evaluations follow up from AAS submissions and risk statements. The number of evaluations of larger operators had increased because of change to the threshold. Workshops were being held for smaller operators.

  3. Sector specialists brought external data into the compliance process and there was increasing use of automated tools.

Chief Executive update report GCP(18)13

  1. The Board noted the report.

Item 8: GDPR: LCCP and operator compliance GCP(18)14

  1. The Head of Legal informed the Board about steps being taken to ensure that implementation of the General Data Protection Regulation (GDPR) did not have a negative impact on the Commission’s regulation.

Item 9: Licensing and contact centre update GCP(18)15

  1. The Board noted the update.

Items 10: Debrief & Builds Raising Standards GCP(18)16

  1. The Head of Communications highlighted to Board the positive feedback received from stakeholders on the November 2017 Raising Standards conference. The parallel fringe event had also proved popular with staff.

  2. To build on the success of the conference, the Communications team proposed that the 2018 event should move to a larger venue and should feature a wider diversity of voices, with more consumer representatives and alternatives to PowerPoint presentations. There was also the potential for more networking opportunities around the main event, perhaps a market place approach with stakeholder stalls. The overall aim was to establish the conference as a major annual event in the sector calendar.

  3. The Board agreed that the range of speakers should be broadened, perhaps with opportunities for industry leaders to interact with consumers. Customers with positive stories about gambling should also be included. There was also scope to promote further the website offering around the conference.

Item 11: Board forward look

  1. The Board noted that the forward look continued to evolve and would feature more briefing sessions and stakeholder engagement through the year.

Item 12: Review of the meeting

  1. Overall, papers for the meeting had been effective at prompting discussion. The Board gave a steer that the most effective papers were concise, with accompanying slides to focus the conversation. There was some concern that papers had insufficient financial context to make clear the full implications of decisions. There should be greater visibility on both process and project costs.
  2. The Board had a clear appetite for more lunchtime discussion sessions.

Paper for information: Financial Action Task Force Mutual Evaluation

  1. The Board noted the paper.

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