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Policy

Corporate Governance Framework

Our corporate governance framework sets out the necessary responsibilities and procedures that guarantee we operate properly.

Shareholdings

82. You are not permitted to have direct shareholdings or to trade in companies operating in the gambling industry, whether or not those companies are licensed by the Commission. This restriction extends to your close family. The restriction on shareholding does not include investments through funds where the precise composition of holdings in the fund at a given time is not visible to investors or where investors have no direct control on individual investment decisions.

83. Where you hold shares in third party companies which might bid to supply products or services to the gambling industry, you should consider carefully whether any conflict might arise or be perceived to arise, owing to potential influence over business decisions in the industry. As a broad example, influence over business decisions is less likely with a maintenance or payroll contractor, say, but could be more likely with a computer hardware or data services provider.

84. Where you hold shares in other leisure sector businesses, such as pub chains, hotels or theme parks, you should consider the potential for any interaction with the gambling industry and whether any conflicts might arise.

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Private interests and public duty
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