Consultation response
Changes to the licence conditions and codes of practice on High Value Customers
Response to consultation on strengthening controls on how licensees incentivise high spending customers.
1 - Executive summary
The Gambling Commission is committed to identifying and acting to make gambling fairer, safer and crime free. Strengthening controls on how licensees incentivise high spending customers is a priority area.
High Value Customers (HVCs), also labelled as Very Important Person (VIPs), are customers identified as being of high commercial value to licensees. These customers are provided with enhanced customer service unavailable to the wider customer base.
HVC schemes often have a dedicated team of staff responsible for managing these customers and it is common for them to be offered benefits including personalised incentives, gifts, hospitality, and preferential service due to their high spend.
We have seen repeated instances of HVC schemes being linked to gambling harm with people incentivised to increase their gambling activity and spend beyond what they can afford.
Too many customers have been assumed to have high disposable income or time to spend on gambling without action to confirm whether that is the case.
The operation of HVC schemes has rightly become a focus of regulatory and external scrutiny. For HVC schemes to have a place in the gambling industry, they must be offered in a manner which is consistent with the licensing objectives.
Where licensees cannot apply effective controls including effective due diligence, senior oversight, clear accountability, and a culture of responsibility around these schemes they should not be operating them.
Earlier this year, the Betting and Gaming Council published a new industry code, which included several actions and related guidance specific to HVCs. We proposed formalising elements of that code to ensure these minimum requirements are enforceable across the whole industry
We have considered the responses to the consultation proposals and made some amendments to provide greater clarity to licensees of our expectations.
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HVC Response - 2 - Introduction
Last updated: 27 September 2020
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