Policy
Corporate Governance Framework
Our corporate governance framework sets out the necessary responsibilities and procedures that guarantee we operate properly.
Gambling by employees
6. We recognise that gambling is a legitimate leisure activity and that a total ban on gambling activity by all Commission employees would be unduly restrictive and could be an obstacle to the recruitment and retention of people with direct experience of the sectors they are regulating. However, because of the Commission’s role as the industry regulator, we have to place restrictions on the gambling that you can undertake to protect you and the Commission from the risk, actual or perceived, of bias, lack of objectivity, or impropriety.
Restrictions on gambling and playing the National Lottery
7. No gambling of any kind (including spread betting, raffles, lotteries, phone or on line betting) is permitted on Commission premises, or using Commission equipment (including IT equipment whether at work or home and Commission-supplied mobile or BlackBerry type devices), at any time.
8. For gambling off Commission premises or using non Commission equipment, you will fall into one of two categories:
- employees considered to be in a position to influence regulatory decisions or Commission employees having domain administrator privileges and/or access to software source code
- other employees.
9. If you are unclear as to your status, you should seek guidance from your manager in the first instance or, failing this, the Commission’s internal compliance officer which role is carried out by the Commission’s Intelligence lead.
Employees in a position to influence regulatory decisions under the National Lottery etc. Act 1993
10. You are prohibited from playing the National Lottery if you are in a position to influence regulatory decisions. You are in position to influence regulatory decisions if you are a Director or Programme Director or employee who has delegated authority to make decisions about the Licensing, Legal, Compliance or Enforcement functions in relation to the National Lottery.
11. Depending on their particular responsibilities, other employees may also fall into this category and, if you do, you will be informed of this by your manager.
12. The prohibition on playing the National Lottery does not extend to family members, but employees are encouraged to notify the Intelligence lead in the event that a member of the family were to win a substantial amount – subject always to the rights to anonymity afforded to winners.
Employees in a position to influence regulatory decisions under the Gambling Act 2005
13. You are in a position to influence regulatory decisions if you are a Director or Programme Director or employee in the Intelligence, Licensing, Legal, Compliance and Enforcement functions. Also included are employees working in the ICT department having domain administrator privileges and ICT employees with access to software source code. Depending on their particular responsibilities, other employees may also fall into this category and, if you do, you will be informed of this by your manager.
14. If you are in a position to influence regulatory decisions, or you appear to be in such a position, you are not permitted to gamble in non-remote casinos, bingo halls, bookmakers premises, family entertainment centres, adult entertainment centres or with on-course bookmakers in Great Britain, or accept winnings from lotteries licensed by the Commission. If you are in this category, you are also encouraged to be aware of the potential risks to the Commission and yourself of gambling by members of your close family (which means partners and dependants).
15. If you are in a position to influence regulatory decisions, you may gamble remotely, for example by phone, television or internet, as there is a clear audit trail that would stand up to challenge. In addition, you may gamble whilst abroad. In all instances, however, you:
- must gamble only as a private individual and not identify your connection with the Commission
- must notify the Commission’s Intelligence lead as to:
- which operators you gamble with
- any accounts opened
- any significant individual wins or losses (for example above £500).
- are encouraged to notify any significant wins by members of your close family or by those you are with if visiting gambling premises, see Visits to gambling premises by employees in a position to influence regulatory decisions section
- must provide such additional relevant information as the Commission may need from time to time. Such information will be held in confidence, but will be available for any properly constituted investigation.
Other employees
16. All other employees are permitted to gamble without restriction, but you:
- must not identify your connection with the Commission
- must notify the Commission’s Intelligence lead of any significant individual wins or losses (such as above £500)
- are encouraged to notify any significant wins by members of your close family or by those you are with if visiting gambling premises
- must provide such additional relevant information as the Commission may need from time to time. Such information will be held in confidence, but will be available for any properly constituted investigation.
Visits to gambling premises by employees in a position to influence regulatory decisions
17. If you are in the Intelligence, Compliance or Enforcement functions, you may only visit non-remote casinos, bingo halls or bookmakers’ premises in Great Britain in an official capacity or with prior agreement from a Director (for example for a special family occasion which it would be unreasonable for you to miss).
18. If you are in the other groups (such as Directors and Programme Directors and those in the Licensing, Legal function or applicable ICT role) to which the restrictions on gambling in non-remote casinos, bingo halls or at bookmakers etc apply (see paragraph 13), you may still visit (but not gamble on) such premises on official business or in your private capacity. Such visits may include unannounced visits, but these must be cleared in advance with a Director. Private visits should not take place if you are involved in any impending regulatory decision involving the relevant premises or operator. Any official or private visits must be notified as soon as possible to the Commission’s Intelligence lead.
19. If you are visiting gambling premises in any capacity, whether in Great Britain or abroad, you should ensure that neither you, nor anyone with you, receive preferential treatment nor any form of hospitality not available to other players or visitors.
20. All employees are permitted to visit licensed racecourses or greyhound race tracks (subject to the restrictions on gambling described above). If you work in the Intelligence, Compliance and Enforcement functions, however, you should notify the Commission’s Intelligence lead if you visit bookmakers’ premises within a racetrack.
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Confidentiality and conflicts of interest
Last updated: 27 February 2023
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