Control and accountability
There is no prohibition in the Act on lottery operators coming together under a single brand and the results in those lotteries being determined by a single draw. However, the individual lotteries must remain separate, distinct entities. Indicators that may help make judgements in these circumstances include the following.
In cases where a number of societies come together to promote their lotteries under one brand, whether an ELM is involved or not, the extent to which each individual society is able to demonstrate that they retain overall management control of their lottery will be important. This will include the society demonstrating that they retain overall control of management and strategic decision-making relating to the promotion of the lottery, including control over social responsibility policies and the marketing of the lottery.
The extent to which the proceeds of individual society lotteries are separated, for example through ring-fencing individual bank accounts from other operators, from the ELM and from any other related company or body.
In cases where a number of societies come together to promote their lotteries under one brand, whether an ELM is involved or not, the extent to which each society has control of the proceeds of the lottery including how those proceeds are apportioned and distributed will be an important factor. Where multiple society lotteries are promoted under one brand, the proceeds cannot be pooled and distributed among all societies promoting their lottery under that brand.
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Last updated: 7 June 2021
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