High Value Customers: Industry guidance
1 - Introduction
This provides guidance for licensees in relation to social responsibility code provision (SRCP) 5.1.1 on rewards and bonuses for high value customers (HVCs), also known as ‘VIPs’. It is designed to help licensees assess whether they can provide HVC schemes with the necessary safeguards as set out in SRCP 5.1.1(2), which provides that:
Social responsibility code provision 5.1.1
Rewards and bonuses – SR code
All licences (including ancillary remote licences), except gaming machine technical and gambling software licences
- If a licensee makes available incentives or reward schemes for customers designated by the licensee as ‘high value’, VIP or equivalent they must be offered in a manner which is consistent with the licensing objectives. Licensees must take into account the Commission’s guidance on high value customer incentives.
SRCP 5.1.1(2) places responsibility on licensees to assess the risks of incentivising HVCs. This guidance sets out the minimum standards we expect licensees to adopt and evidence in policies, procedures, and practices to mitigate those risks. Licensees will need to be able to explain the reasons for any departures from these standards and evidence how alternative approaches are equally effective at preventing outcomes contrary to the licensing objectives. Where a licensee cannot meet these minimum expectations, they should not be operating HVC incentive schemes.
Licensees are required to apply player protection controls, affordability checks, and due diligence consistently to all customers at appropriate stages of the customer relationship, or in response to specific concerns. This guidance supplements existing requirements related to customer protection, the prevention of crime or fair and open gambling. In particular, it supplements guidance for licensees on how to meet their customer interaction requirements. It does not supersede existing requirements but sets out the minimum standard that must be met to achieve the intended outcomes for HVC schemes. Licensees should seek independent legal advice where further clarity is required.
To minimise duplication, section 3 of this guidance is used to signpost licensees to relevant material, most notably the customer interaction guidance, which covers themes such as affordability, vulnerability and evaluation.
Scope of this guidance
There is no single definition of what constitutes an HVC. The categorisation and management of HVCs is determined by a licensee’s business model and is relative to their overall customer base.
This guidance covers those customers identified as being of enough commercial value to warrant enhanced customer service unavailable to the wider customer base. Specifically, schemes that offer tailored or personalised incentives linked to high value spend or frequency of play. Such treatment may include but is not restricted to:
i. Invitation to hospitality, events, dinners, or other enhanced services ii. Personal account management/dedicated point of contact with the licensee iii. Individualised bonuses, benefits, or gifts.
This guidance is not intended to capture ad hoc, non-personalised bonus offers or promotions that are made available to large numbers of consumers. High value prizes linked to promotions such as customer free prize draws are also not considered in scope where they are made available to the wider consumer base.
Whilst this guidance does not provide a single specific definition of HVCs, we would expect a licensee to be able to provide a clear explanation of how HVCs are defined in their business and how this guidance has been applied.
This guidance may be amended periodically to take account of emerging good practice or regulatory changes. Minor amendments will be consulted on informally, for example, through industry trade bodies, with more substantive changes subject to public consultation.Previous section
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High Value Customers: Industry guidance - High Value Customer reward programmes
Last updated: 29 September 2020
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