The importance of responsible gaming
Putting the customer first is one of our core values. We want everyone who registers and plays on our websites to have fun and be entertained in a safe and supportive environment.
As a responsible operator committed to player welfare, it is important for us to build relationships with our customers, understand their behaviours and recognise any gaming problems that may arise. During 2018 we invested significant time, energy and resources into developing and putting in place appropriate policies, systems and tools across our organisation to protect customers, detect potential problems and support our employees in dealing with customer issues.
We put compliance at the heart of our business and strive to ensure that we meet all the regulations and requirements in every market where we operate. This commitment is led and supported by our executive team. During 2018 we invested in education for all our business units to ensure they are able to run their own compliance programmes, supported and supervised by the central compliance function.
Gamesys Group plc holds gaming licences in Gibraltar, Isle of Man, Malta, Spain, Sweden, and the UK, which are all monitored through local gaming authorities. We are committed to operating to the highest standards of compliance and are subject to rigorous and regular checks and audits from the authorities in those jurisdictions.
Our compliance framework will continue to evolve to ensure that we meet all the requirements in a rapidly evolving environment.
We aim to get to know our customers so we can provide the support they need. During 2018 we adopted a more proactive approach to our engagement including regular communications with customers and research and collaboration with key stakeholders to ensure player welfare.
During the year, we have invested significantly in technology and software to assist in detecting problem gaming behaviour. In May 2018 we implemented a model, designed with the input of a data scientist, which uses a number of variables to calculate the probability that a customer is developing risky gaming behaviours. These variables are monitored to identify customers at risk and we have put operational processes in place to support at risk customers. All customers flagged as at risk receive a personal interaction ranging from an email raising awareness to responsible gaming tools such as deposit limits and self-exclusion on a temporary or permanent basis, depending on the severity of the case.
Our dedicated responsible gaming team in place has been trained to provide specialist support to our customers and is available around the clock seven days a week. This means that we are able to respond to customer interactions, provide guidance and take action where necessary at all times. Tools to help our customers include:
- A wide range of deposit limits.
- Session reminders and time played triggers.
- Access to account history.
- Self-assessment tests to assess the current risk level.
- Account cool off periods of between 24 hours and 30 days.
- Account self-exclusion of between six months and 5 years.
Additionally, we have introduced a communications initiative which aims to build relationships with our customers and make them aware of support available to them should they need it. All our customers receive quarterly communications which incorporate responsible gaming messages and draw attention to the tools available to keep them safe. This programme is initially focused on the UK but will be rolled out across the Group in the coming year.
Our dedicated VIP team is required to undertake a responsible gaming review when onboarding any potential Account Managed VIP customer in the UK. Even if no concerns are identified, the player will receive an email within seven days of the initial review bringing all responsible gaming tools to their attention followed by a call to check the customer is comfortable with the time and money they are spending on the site.
We undertake responsible gaming reviews of our Account Managed VIP customers’ activities on a monthly basis to ensure there are no material changes to their behaviour. Where risks are identified we follow up with interaction with the customers concerned and take action as appropriate.
In addition, we build relationships with our Account Managed VIP customers through regular interaction so we are aware of any relevant changes to their circumstances. All Account Managed VIP customers globally also receive a quarterly communication drawing attention to the tools and support we provide.
Our support staff
During 2018, Gamesys Group plc has significantly enhanced its training programmes, especially in relation to money laundering and responsible gaming. As part of our induction process, all our employees receive mandatory training covering these areas which is supplemented by advanced and refresher online training every six months.
We provide responsible gaming training to all of our employees, including those who do not have customer exposure. Our highly skilled customer service employees undergo further advanced responsible gaming training. We also provide enhanced responsible gaming training to customer service team leaders and introduced the SAFE TALK initiative during the year to provide suicide alertness training to all members of our customer services and responsible gaming teams.
Responsible marketing initiatives
Gamesys Group and our divisions were primary sponsors of Responsible Gambling Week, a cross-industry initiative to promote responsible gaming in the United Kingdom and Ireland through a variety of channels which took place in November 2018.
We assisted in the creation of communications materials and channels including website pages and regular social media posts and sponsored the media panels which promoted Responsible Gambling Week on the London Underground. During the week, Pedro Romero, our head of Customer Operations, ran certified training sessions which fellow operators were invited to participate in, enabling us to share best practice across the industry and raise awareness of the risks associated with responsible gaming and how to respond when dealing with people in crisis. Over 20 representatives from different B2B and B2C operators attended the training. We received excellent feedback and are developing further cross-industry training initiatives to improve knowledge and standards.
In April 2018 the UK Gambling Commission launched GamSTOP, an online self-exclusion scheme to enable people with gaming problems to exclude themselves from online betting platforms. We are committed to this initiative and assisted with launching the programme by raising customer awareness through our customer interactions and on our websites. We have also signed up to the scheme as an online operator to allow players to exclude themselves from our websites.
We also updated all our divisional websites during the year, removing any graphics that would appeal to children, making our terms and conditions more readily accessible and adding a link to the responsible gaming page on all our sites.
Industry involvement and engagement
We are an active participant in the Remote Gambling Association, a London and Brussels based trade association which is committed to promoting a regulated and non-discriminatory environment for responsible licensed operators in Europe.
Gamesys Group plc representatives additionally took part in a number of industry conferences on responsible gaming during the year including the BigDeal Young People and Problem Gaming conference in London (August 2018), the 12th European Conference on Gaming Studies and Policy Issues in Valetta (September 2018) and the Sustainable Gaming Conference in Stockholm (October 2018).
We work with GamCare, a charity that provides support and counselling to prevent and treat problem gaming, to ensure our training programmes on responsible gaming are effective in improving our employees understanding and reflect good practice.
We also obtained in August 2019 the Safer Gaming Standard, a GamCare certification which recognises gaming operators who have both met and exceeded the requirements of gaming industry Codes of Practice in respect of their player protection measures.
Going forward, we intend to develop further collaborations with charities and other key stakeholders that work to prevent harm to support their work and ensure our employees continue to receive specialist training and knowledge.
In 2018 we increased our contribution to Gamble Aware, an independent charity which provides research, education and treatment to help to reduce gaming-related harm in Great Britain.
In November 2018 we refreshed and updated our anti-money laundering (‘AML’) policy to ensure we have adequate controls in place to prevent the business from being used for money laundering.
In addition to our Know Your Customer checks, we also conduct checks to help identify any illegal sources of funds. We undertake enhanced source of funds and wealth checks on customers on a risk sensitive basis. Activities for establishing sources of wealth and source of funds include: procedures aimed at assessing consumer affordability, procedures aimed at determining the source and origin of funds deposited and enhanced staff training to ensure that staff undertaking account reviews make the best use of the information that is available to them. In addition, our systems include a variety of reports and alerts which trigger customer account AML reviews and ongoing due diligence to check that customers are playing within their means.
We also conduct reviews and ongoing monitoring of all active accounts which have been successfully verified for sources of funds. This review takes place every three to four months and allows the business to keep under review whether the player’s deposits and losses remain consistent with our understanding of their financial position, and whether the relevant player presents a different level of risk. Updated documents are requested where necessary. At the same time, a responsible gaming review is undertaken on the account to check for indicators of problem gaming.