Module 2 - SR

Question 1

What does Module 2 cover?

Answer 1

For this Personal Management Licence (PML) course – Social Responsibility and Safer Gambling we will be looking at our social responsibility compliance obligations in terms of the Licensing Conditions and Code of Practice (LCCP), the Gambling Commission’s guidance, GC compliance work and our policies. The issues that we will consider include: Part A - Gambling Commission Strategy, guidance, expectations and enforcement; Part B - Social Responsibility and Safer Gambling Policies; Part C - Protection of the Young and Vulnerable; Part D - Remote and non-remote Guidance on Interactions and Self Exclusion; Part E - Gaming Disputes process and ADR compliance; Part F - Licencing Act 2003, the objectives and where it sits within the licensing regime.

Question 2

What are the three licensing objectives?

Answer 2

1. Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime. 2. Ensuring that gambling is conducted in a fair and open way. 3. Protecting children and other vulnerable persons from being harmed or exploited by gambling.

Question 3

What is problem gambling?

Answer 3

‘Problem gambling’ means gambling to a degree that compromises, disrupts or damages family, personal or recreational pursuits.

Question 4

What is the PGSI and who developed it?

Answer 4

The PGSI was specifically developed for use among the general population rather than within a clinical context by Ferris and Wynne (2001). The PGSI consists of 9 items and each item is assessed on a four-point scale: ‘never’ to ‘almost always’.

Question 5

What PGSI score represents problem gambling?

Answer 5

PGSI score of 8 and over represents problem gambling by which a person will have experienced adverse consequences from gambling and may have lost control of their behaviour. Involvement in gambling can be at any level, but it is likely to be heavy.

Question 6

What PGSI score represents moderate-risk gambling?

Answer 6

PGSI score of 3 to 7 represents moderate risk gambling by which a person may or may not have experienced any adverse consequences from gambling but may be at risk if they are heavily involved in gambling.

Question 7

What PGSI score represents low-risk gambling?

Answer 7

PGSI score of 1 to 2 represents low risk gambling by which a person is unlikely to have experienced any adverse consequences from gambling but may be at risk if they are heavily involved in gambling.

Question 8

List the 9 PGSI questions.

Answer 8

1. Have you bet more than you could really afford to lose? 2. Have you needed to gamble with larger amounts of money to get the same feeling of excitement? 3. When you gambled, did you go back another day to try to win back the money you lost? 4. Have you borrowed money or sold anything to get money to gamble? 5. Have you felt that you might have a problem with gambling? 6. Has gambling caused you any health problems, including stress or anxiety? 7. Have people criticized your betting or told you that you had a gambling problem, regardless of whether or not you thought it was true? 8. Has your gambling caused any financial problems for you or your household? 9. Have you felt guilty about the way you gamble or what happens when you gamble?

Question 9

How are PGSI responses assessed?

Answer 9

Each item is assessed on a four-point scale ranging from: never, sometimes, most of the time, almost always.

Question 10

What are gambling-related harms?

Answer 10

Gambling-related harms are the adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society. These harms impact on people’s resources, relationships and health.

Question 11

What negative effects can gambling-related harm include?

Answer 11

Negative effects can include loss of employment, debt, crime, breakdown of relationships and deterioration of physical and mental health. At its worst, gambling can contribute to loss of life through suicide.

Question 12

Who can be affected by gambling harms?

Answer 12

Harms can be experienced by those who gamble themselves, but can also affect their children, partners, wider families and social networks, employers, communities and society as a whole.

Question 13

What did the statistics slide show about the general population?

Answer 13

If Great Britain were 100 people: 52 people don’t gamble at all; 43.5 gamble but are not problem or at risk gamblers; 3 people are low-risk gamblers according to PGSI; 1 person is a moderate-risk gambler; 0.5 people is a problem gambler.

Question 14

What did the statistics slide show about 16–24 year old gamblers?

Answer 14

If Great Britain were 100 16-24 year old gamblers: 80.5 gamble but are not problem or at risk gamblers; 11.5 are low-risk gamblers; 6.5 are moderate-risk gamblers; 1.5 are problem gamblers.

Question 15

What did the statistics slide show about people who gamble in lots of different ways?

Answer 15

If Great Britain were 100 people who gamble in lots of different ways: 71 are not currently problem or at-risk gamblers; 14 are low-risk gamblers; 9 are moderate-risk gamblers; 6 are problem gamblers.

Question 16

What did the gambling typologies slide say about why people gamble online casino?

Answer 16

Research published for GC (2019) ‘Why people gamble’ identified key typologies including ‘Me time’ and ‘Feeling lucky’. The slide says players are more likely to be younger (18-34), more likely to be from middle to higher income households, and more likely to be identified as a moderate to high risk problem gambler.

Question 17

What are typical occasions, motivations and intended behaviours for online casino in the typologies slide?

Answer 17

Typical occasion: typically lasts 30 minutes - 1 hour; solo activity; more likely that occasion is planned, but not the specific activity or taking opportunity to gamble is also planned. Motivations & triggers: motivated by me-time enjoyment; triggered by spare money in online account, being given free goodybag, or having just been paid. Preferred intention: more not likely want intention of some kind; suggested pass popular. Sources of information: the company’s website; social media influencers; online chat rooms/forums.

Question 18

What are the Gambling Levy Regulations 2025?

Answer 18

The statutory levy has now been introduced via the Gambling Levy Regulations 2025 (‘the Regulations’) and commenced on 6 April 2025. 3.—(1) Starting with the first levy period, a person who is a holder of an operating licence during a levy period must pay a levy to the Commission in respect of that levy period.

Question 19

What is social responsibility in the context of this business?

Answer 19

Social responsibility, in the context of our business, principally concerns protecting people from gambling-related harm, otherwise referred to as ‘Harm Minimisation’.

Question 20

Why is proactive interaction important?

Answer 20

Proactively interacting early enough and in the right way, can help someone keep control of their gambling and you will retain them as a customer, instead of them choosing to opt for a self-exclusion or closing their account entirely. In the long term this approach is more sustainable for your business.

Question 21

What is the Betting and Gaming Council (BGC) and what is its aim?

Answer 21

The Betting and Gaming Council (BGC) launched in November 2020. Its aim is to help build consumer and public trust in the gambling industry, and assure government and the regulator that we are moving in the right direction and that responsible gambling is our top priority.

Question 22

What does the marketing slide say Section 5 of the codes of practice deals with?

Answer 22

The LCCP contains a number of social responsibility codes that are drafted to promote responsible marketing and advertising of gambling. Section 5 of the codes of practice deals with Marketing: rewards and bonuses; restriction on free or discounted alcohol during gambling; third parties (agents); compliance with advertising codes and industry codes; online marketing.

Question 23

What does SRC 3.3.1 require about responsible gambling information?

Answer 23

Licensees must make information readily available to their customers on how to gamble responsibly and how to access information about, and help in respect of, problem gambling.

Question 24

What must responsible gambling information cover?

Answer 24

The information must cover: any measures provided by the licensee to help individuals monitor or control their gambling, such as restricting the duration of a gambling session or the amount of money they can spend; timers or other forms of reminders or ‘reality checks’ where available; self-exclusion options; information about the availability of further help or advice.

Question 25

Where must responsible gambling information be displayed in gambling premises?

Answer 25

For gambling premises, information must be available in all areas where gambling facilities are provided and adjacent to ATMs. Information must be displayed prominently using methods appropriate to the size and layout of the premises.

Question 26

What does the GamCare venue code say?

Answer 26

GamCare’s Industry Code for the Display of Safer Gambling Information (Gambling Venues) was published in September 2022. It provides businesses with minimum requirements as well as some guidance to improve the display of Safer Gambling information in their venue. The code has been incorporated into the policies of the Club.

Question 27

How is safer gambling information displayed in Les A?

Answer 27

Our Responsible Gambling Leaflet is available in all areas where gambling facilities are provided (in each gaming room and the Garden) and adjacent to ATMs. It is displayed prominently appropriate to the size and layout of the premises. These methods do not include the use of posters but there is signposting and information on slots and ERs and on iPads and screens. Information is also be available in a form that may be taken away and is readily accessible in locations which enable the customer to obtain it discreetly. The leaflet is also available in the key languages that are used in the Club, English, Chinese and Arabic.

Question 28

What does the GamCare website code say?

Answer 28

In March 2021, GamCare published a new Code for gambling businesses setting out minimum standards for the display of Safer Gambling information within gambling websites and apps. Members of the BGC committed to implementing the Code by August 2021. The Code covers placement of Safer Gambling information within website or app, Safer Gambling messaging, access to Safer Gambling tools or controls, minimum content requirements for Safer Gambling section or microsite, footers, updating Safer Gambling information, presentation of content and self-excluding customers.

Question 29

What is LAO’s safer gambling approach?

Answer 29

Les Ambassadeurs Online is committed to providing a culture of care for our customers and we aim to provide an environment that supports responsible and safer gambling. We acknowledge our responsibility to minimise the potential harm that gambling can cause, and we are committed to working to ensure that all our staff understand their role in looking after our customers. Les Ambassadeurs Online is committed to a program of harm minimisation and player protection, which is embedded within its operating processes and training.

Question 30

What are the main multi-operator self-exclusion schemes mentioned?

Answer 30

GAMSTOP: an online self-exclusion tool that allows individuals to exclude themselves from all UK-licensed online gambling websites and apps. SENSE: a self-exclusion program specifically for land-based casinos in the UK. MOSES: used for betting shops so individuals can exclude themselves from multiple betting shops with a single application.

Question 31

What does SRC 3.5.1 require for non-remote self-exclusion?

Answer 31

Licensees must have and put into effect procedures for self-exclusion and take all reasonable steps to refuse service or to otherwise prevent an individual who has entered a self-exclusion agreement from participating in gambling. They must take all reasonable steps to prevent any marketing material being sent to a self-excluded customer, remove the details of a self-excluded individual from any marketing databases within two days, close any customer accounts and return any funds held in the customer account, maintain a register, obtain photo identification and a signature, ensure staff training, remove excluded persons found in the gambling area, take account of the structure and layout of the premises, and signpost the individual to counselling and support services.

Question 32

What does OC 3.5.2 add for non-remote self-exclusion?

Answer 32

Individuals must take positive action in order to self-exclude. Individuals should be able to self-exclude without having to enter gambling premises. Customers should be given the opportunity to discuss self-exclusion in private, where possible. The minimum self-exclusion period offered is not less than 6 nor more than 12 months; any self-exclusion may be extended; self-exclusion remains in place for a further 6 months unless the customer takes positive action to gamble again; post exclusion the customer is given one day to cool off before being allowed access to gambling facilities; no marketing material should be sent; records must be retained for 6 months after length of exclusion.

Question 33

What do SRC 3.5.6 and 3.5.7 require on multi-operator self-exclusion?

Answer 33

Licensees must offer customers with whom they enter into a self-exclusion agreement the ability to self-exclude from facilities for the same kind of gambling offered in their locality by any other holder of an operating licence to whom this provision applies, by participating in one or more available multi-operator self-exclusion schemes. Licensees should contribute to and participate in the development and effective implementation of multi-operator self-exclusion schemes.

Question 34

What is SENSE and how is it used in Les A?

Answer 34

SENSE is a system which has been developed in order to provide easy access for people who believe they have a problem with their gambling and wish to voluntarily self-exclude nationally from any land based casino in the UK. Whenever a customer self-excludes from a casino they must be asked if they wish to join SENSE. A manager (PML holder) speaks to the customer and registers the customer on the SENSE iPad ensuring that the customer information on CMS is correct and then takes a photograph and signature.

Question 35

What does the presentation say about SENSE leaflets in the club?

Answer 35

The SENSE leaflet is also prominently displayed and available in the 3 languages. This customer information is available alongside the Responsible Gambling leaflet. It is still possible for a problem gambler to exclude just from Les A but this must be specifically requested and the reasoning recorded. Managers are trained to offer the National Self Exclusion first.

Question 36

What does SRC 3.5.3 require for remote self-exclusion?

Answer 36

Licensees must have procedures for self-exclusion and take all reasonable steps to prevent an individual who has entered a self-exclusion agreement from participating in gambling. They must prevent marketing material being sent, remove name and details from marketing databases within two days, close any customer accounts and return any funds held, maintain a register of those excluded, keep a record of the card numbers to be excluded, ensure effective staff training, remove access from those found to have gambled or attempted to gamble, signpost the individual to counselling and support services, and allow self-exclusion by contacting customer services and in addition by entering an automated process using remote communication.

Question 37

What does OC 3.5.4 add for remote self-exclusion?

Answer 37

Self-exclusion procedures should require individuals to take positive action over the internet or by telephone. Before an individual self-excludes, licensees should provide information about what the consequences of self-exclusion are. They should encourage the customer to extend their exclusion to other remote gambling operators and provide a statement explaining that software is available to prevent an individual computer from accessing gambling internet sites. The minimum self-exclusion period offered is not less than 6 nor more than 12 months; customers must be able to select up to at least five years; at the end of the chosen period, self-exclusion remains in place for a minimum of 7 years unless positive action to gamble again is taken; and where a customer makes a positive request to begin gambling again, the customer is given one day to cool off.

Question 38

What is GAMSTOP?

Answer 38

GAMSTOP is a free self-exclusion scheme designed to help individuals in the UK manage their online gambling behaviour by restricting access to gambling websites and apps. Users register on the GamStop website, providing personal details and selecting a self-exclusion period of 6 months, 1 year, or 5 years. Once registration and verification are complete, the self-exclusion is activated.

Question 39

What does the customer interaction slide say about LAO process?

Answer 39

When an alert comes through and an SGI is required, CS Team will open the account and immediately disable deposits. Correspondences must be noted and an entry will be added to the SGI log. When the player comes onto the chat, CS Team must check the username and personal details for security reasons, conduct the SG conversation on chat, receive a positive reply before moving to the next question, and if satisfied enable deposits. If a player indicates they have a problem, the account will be FROZEN and the player informed. Treat SG concerns with extra care and sympathy. If CS suspect SG concerns are not explicitly stated, CS must refer to management.

Question 40

What does 6.1.1 require for complaints and disputes?

Answer 40

Licensees must put into effect appropriate policies and procedures for accepting and handling customer complaints and disputes in a timely, fair, open and transparent manner. They must ensure that they have arrangements in place for customers to be able to refer any dispute to an ADR entity in a timely manner if not resolved to the customer’s satisfaction by use of their complaints procedure within eight weeks of receiving the complaint, and where the customer cooperates with the complaints process in a timely manner.

Question 41

What does the presentation say about children and young persons?

Answer 41

Meaning of 'child' under 16 years old and 'young person' 16-17 years old. Principal offences committed by the licensee include s46 invitation to gamble and s47 invitation to enter premises. Principal offences committed by the young person are s48, 49 and 50: gambling, entering premises and provision of facilities for gambling.

Question 42

What do sections 54 and 55 say about employment offences?

Answer 42

Section 55 states a person commits an offence if he employs a child or young person to perform any function on premises in respect of which a casino premises licence, betting premises licence, or adult gaming centre premises licence has effect. Section 54 states a person commits an offence if he employs a child or young person to perform any function on premises where a Category A, B, C or D gaming machine is situated, and the child or young person is or may be required in the course of his employment to perform a function in connection with the gaming machine.

Question 43

What does SRC 3.2.1 require for casinos to prevent underage gambling?

Answer 43

Licensees must have and put into effect policies and procedures designed to prevent underage gambling and monitor the effectiveness of these. They must ensure that their policies and procedures take account of the structure and layout of their gambling premises, designate one or more supervisors for each casino entrance, and supervisors must check the age of customers who appear to be, or are suspected of being, underage and refuse entry to anyone unable to produce acceptable identification.

Question 44

What does 7.1.2 say about responsible gambling information for staff?

Answer 44

Licensees must take all reasonable steps to ensure that staff involved in the provision of facilities for gambling are made aware of advice on socially responsible gambling and of where to get confidential advice should their gambling become hard to control.

Question 45

What are the four licensing objectives under the Licensing Act 2003?

Answer 45

The prevention of crime and disorder; Public Safety; The prevention of public nuisance; The protection of children from harm.

Question 46

What offences are mentioned under the Licensing Act 2003?

Answer 46

It is an offence under s141 Licensing Act 2003 to supply alcohol to an intoxicated person or to allow disorderly conduct on licensed premises (s140).

Question 47

What occupancy restrictions are given under the premises licence?

Answer 47

Annex 2 restricts the following numbers of customers on each floor: Basement 200 persons (excluding staff); Ground Floor 200 persons (excluding staff); First Floor 250 persons (excluding staff).

Question 48

What are key features of the Licensing Act 2003 mentioned in the presentation?

Answer 48

Flexible opening hours for premises; consideration of the impact of opening hours on local residents and businesses; a single Premises Licence authorising premises for multiple licensing activities; personal licences relating to the supply of alcohol; and local residents and businesses have the right to make representations about applications.

Question 49

Who is the Designated Premises Supervisor (DPS) and what does the role involve?

Answer 49

The appointed Designated Premises Supervisor is the person who has day-to-day responsibility for the running of the business in terms of its licensable activity under the Premises Licence 2003. Christophe Thuilot is the DPS – he also has trained deputies. The DPS will act as primary contact for local government and the police. They must understand the social issues and potential problems associated with the sale of alcohol and have a good understanding of the business itself.