Fourth National Lottery Licence: Regulatory Handbook
14. Condition 13: The National Lottery Brand and reputation
14.1 This section provides examples of the factors and types of evidence we may have regard to in the context of compliance with Condition 13.
14.2 Whilst Condition 13 concerns the National Lottery Brand and reputation in the context of the Licensee’s overall running of the National Lottery, similar obligations and outcomes are set out in Section 6 Licences regarding the National Lottery Brand and reputation in the context of the promotion of specific Games. As such, the material in this section also applies to Section 6 Licence obligations where relevant. Section 20 provides some additional guidance in relation to subject matters, images and themes used in the promotion of Games and their potential impact on the National Lottery Brand and reputation.
14.3 Specifically, this section covers:
- general guidance on demonstrating compliance
- guidance on the use of brand performance measures.
General guidance on demonstrating compliance
14.4 In considering compliance with this condition, we expect to have regard to specific brand performance measures, as set out below, as well as other relevant factors. Examples of such factors may include:
- the Licensee’s conduct in response to any change in circumstances that may be outside of the control of the Licensee (for example, broader shifts in consumer perception, or changes in legislation, regulations or codes related to advertising)
- any changes in circumstances associated with the Licensee’s conduct (for example, changes in its Brand Management Plan)
- the Licensee’s approach to identifying and monitoring risks to the National Lottery Brand
- qualitative evidence of the effectiveness of marketing and advertising campaigns (for example, this evidence might capture issues related to specific demographics which may not be captured by brand performance measures at the aggregate level).
14.5 We recognise that brand measures may be subject to fluctuations, for example due to the timing of marketing campaigns. Therefore, in monitoring performance we will have regard to performance over longer periods as well as shorter periods. We would typically expect to have regard to the performance of the National Lottery over timeframes of at least six months when considering whether there is an indication of potential non-compliance with the conditions of the Fourth Licence, though we may have regard to shorter timeframes in the event of particularly significant or unusual changes in brand performance.
14.6 We expect to have regard to brand measures calculated at aggregate UK-wide level, as well as measures that capture brand performance across UK regions.
Use of brand performance measures
14.7 As part of our approach to monitoring brand health, we expect to consider evidence capturing the extent to which the National Lottery Brand is distinctive, instantly recognisable and associated with core values including:
- being a safe place to play and participate
- operating with trustworthiness and integrity
- generating positive sentiment among people
- engendering diversity and inclusion
- funding Good Causes
- having a national profile
- offering life-changing Prizes.
14.8 In relation to the link between the National Lottery Brand and funding of Good Causes, and consistent with Condition 13.4, we will have regard to the Licensee’s approach to engaging, collaborating and sharing relevant information with key stakeholders such as Distributors and the National Lottery Promotions Unit (NLPU), who can contribute towards maintaining and strengthening this link.
14.9 The above core values inform the measures we will use to monitor the Licensee’s compliance with Condition 13.1 – indicative examples of which are listed in Table 1 on this page. We will finalise this list before the start of the Fourth Licence after considering proposed measures, and any indicative values, included in the Licensee's Brand Management Plan.
14.10 As the use and value of the National Lottery Brand during the Fourth Licence Term will follow, and build upon, the use and value during the Third Licence, we will have regard to the brand health monitoring measures and associated methodology used during the term of the Third Licence, with a view to ensuring a degree of continuity where this is appropriate.
Table 1: Overview of indicative brand performance measures
|Indicative brand measures
|Percentage of respondents who have heard of the National Lottery
|Net Promoter Score, which measures the loyalty of the Licensee’s relationship with Participants
|Percentage of respondents who agree the National Lottery supports Good Causes
|Percentage of respondents who agree the National Lottery changes lives
|Percentage of respondents who agree the National Lottery has a national profile
|Percentage of respondents who agree the National Lottery is a safe place to play
|Percentage of respondents who feel positive about the National Lottery
|Percentage of respondents who agree the National Lottery is trustworthy
|Diversity and inclusion
|Percentage of respondents who regard the National Lottery as inclusive and engaging with the full range of diverse communities in society
|Unprompted brand recall
|Percentage of respondents who can recall information about the National Lottery without being prompted
14.11 The Licensee will regularly report brand performance measures, as set out in our Assurance and Regulatory Reporting Requirements (see volume three).
14.12 We expect to review performance targets at the mid-point of the Fourth Licence in 2028. However, we may review and adjust targets at other times, if this is necessary in order to ensure these are aligned with the objective as set out in Condition 13.1.
14.13 We acknowledge brand performance measures are backward-looking. Therefore, we may still request additional information from the Licensee, including towards the end of the Fourth Licence, if we require further confidence it will meet its obligations under Condition 13 and related Condition 1.2(c).Previous section
13. Condition 11: Having an appealing but safe portfolio of Games Next section
15. Condition 17: Licensee and its operations to be Fit for Purpose
Last updated: 1 February 2024
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