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Consultation response

Changes to LCCP on ADR, CI and RET contributions

A summary of the responses to our consultations on changes to LCCP requirements for customer interaction and alternative dispute resolution (ADR) providers.

Consultation proposal

We sought views on our proposal to rewrite social responsibility code 3.4.1 to focus more on the outcomes that we want licensees to achieve, that is, to minimise the risk of customers experiencing harms associated with gambling. The reworded code seeks to address three themes that have consistently emerged through our casework and compliance activity:

  • Failure to identify activity which could indicate the customer was experiencing harms associated with gambling
  • Failure to interact promptly or effectively when a customer exhibits indicators of harm
  • When an interaction has taken place, little or no attempt to monitor activity or understand the impact of the interactions or to evaluate the effectiveness of policies and procedures.

In response to positive feedback from our remote guidance and in order to support licensees in understanding our expectations and sharing some ways to meet them, we proposed a new requirement for licensees to take account of our guidance on customer interaction.

We also proposed to remove ordinary code 3.4.2 and instead require those provisions to be met in different ways, through inclusion in our guidance and more appropriately facilitated through the National Strategy to Reduce Gambling Harms.

Finally, we asked licensees to provide estimates of the costs that might be incurred through implementing the proposed changes, to inform our Business Impact Target (BIT) assessment.

We received 69 responses in total from the following categories of respondents:

  • Licenced operators – 17
  • Members of the public - 30
  • Trade associations – 4
  • Other – 18
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Proposed changes to Social responsibility code 3.4.1 (1a)
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