POLICY STATEMENT
Our mission is to put into effect policies and procedures intended to promote socially responsible gambling and to create a regulatory compliant environment for adults to place bets within our race tracks situated at Chester and Bangor-on-Dee.
Betting is regulated by the Gambling Act 2005 which became fully operational on 1 September 2007 with the Gambling Commission (the Commission) becoming responsible for the licensing and regulation of all forms of commercial gambling within Great Britain with the exception of Spread Betting which is regulated by the Financial Conduct Authority.
The Commission works in conjunction with Local Authority Licensing departments who have responsibility for issuing and enforcing gambling Premises Licences.
To ensure regulatory compliance the Commission has wide ranging powers of enforcement, which include powers of entry, search and seizure together with a rigorous licensing regime which applies to both operators and to certain individuals who hold appropriate management responsibilities within certain gambling businesses. Both Local Authority Licensing Officers and Police Officers hold similar powers.
The Chester Race Company Ltd trading as Chesterbet and BangorBet hold a Non-Remote General Betting Licence issued by the Commission and Track Premises licences issued by Chester and Cheshire West and Wrexham local authorities.
Our Compliance Manager, Patrick Chesters will be responsible for all aspects of regulatory compliance.
The Commission works in conjunction with the industry and under the authority of the Gambling Act has produced its Licence Conditions and Codes of Practice (LCCP), which we, as the holder of a General Betting Operator’s licence, must comply with. The latest version was produced in April 2018. A copy of this document can be obtained from the Commission’s website at www.gamblingcommission.gov.uk
We will also have regard to the requirements of the respective Local Authority “Statements of Gambling Policy,” which are produced every three years.
Key events which could have a significant impact on the nature or structure of our business will be reported to the Gambling Commission as soon as practicable or in any case within 5 working days.
In order to comply with the requirements of the LCCP we have produced a set of Social Responsibility policies and procedures. Our policies will be reviewed and amended annually and when appropriate LCCP changes are required to be made. Policy or procedural changes will be recorded in an appropriate policy control document and signed off accordingly.
The document is a ‘living’ policy and procedure guide used to determine operational and training requirements for compliance with statutory and regulatory licence conditions and codes of practice as well as our own procedural changes. As such it is intended that this document is used by the Gambling Commission as a tool to audit our compliance regime.
Our policies also comply with the appropriate Local Authority Track Pemises Licensing requirements.
Where reference is made to “Chester” that shall be taken to mean Chester Race Company Limited; the body corporate responsible for general betting services at both Chester and Bangor-on-Dee Racecourses.
Our expectation is that all our employees will co-operate fully with Commission and Local Authority Licensing Officers who have responsibility for licensing, monitoring and enforcement in relation to our betting operation. Visits can be made both on race days and at other reasonable times. Our Compliance Manager, Patrick Chesters, will normally be the first point of contact with Commission Compliance Managers and Local Authority Licensing Officers.
As we hold Track Premises Licences which allow individual licensed bookmakers to provide additional betting facilities at our racecourses within the betting rings we will ensure that they and their representatives are properly licensed by the Commission and procedures are in place to facilitate this requirement.
Our policies and procedures will be consistent, with and implemented with due regard to the health safety of our staff.
Staff will co-operate with the Commission’s Compliance Managers and Local Authority Licensing Officers in the proper performance of their compliance functions and will be made aware of their rights of entry to premises contained in Part 15 of the Act.
The provision of our betting facilities will be strictly in accordance with the three Licensing Objectives which are outlined in Section 1 of the Gambling Act 2005.
SECTION 1
THE THREE LICENSING OBJECTIVES
1.1 The Gambling Act identifies three Licensing Objectives as follows;
A. Preventing gambling from being a source of crime and disorder, being associated with crime or disorder or being used to support crime
B. Ensuring that gambling is conducted in a fair and open way, and
C. Protecting children and other vulnerable persons from being harmed or exploited by gambling
SECTION 2
PERSONAL MANAGEMENT LICENCES – Licence Condition 1.2.1
2.1 Gambling Commission Personal Management Licences (PML) are held by the Directors and employees of the company who are responsible for;
A. The overall management and direction of the Licensee’s business
B. The licensee’s finance function as head of that functio
C. The licensee’s gambling regulatory compliance function as head of that function
D. The licensee’s marketing function
E. The licensee’s information technology function
F. Oversight of the day to day management of the licensed activities both at Chester and Bangor-on-Dee
2.2 These PMLs may be reviewed by the Gambling Commission at any time under Section 116(2) of the Gambling Act.
2.3 Any changes to the holders of any relevant management office will be notified to the Commission and appropriate replacement PMLs applied for.
SECTION 3
GENERAL BETTING LICENCES
3.1 Our betting licence is subject to the condition that bets may be accepted on behalf of Chesterbet and Bangorbet only by:
A. The licensee
B. A person employed by the licensee under a written contract of employment. or
C. The holder of another general betting operator’s licence
3.2. All employees will, therefore, be employed under a written contract of employment. A copy of the contract has been made available to the Commission.
SECTION 4
STAFF TRAINING
4.1 All staff who are employed to take bets will receive both induction and annual refresher training which will include their obligations under our Social Responsibility policies and procedures including their personal obligations under the Proceeds of Crime Act 2002 and the Terrorism Act of 2000. Supervisors will receive additional training commensurate with their responsibilities.
4.2 All members of our betting staff will receive their own personal copy of the Staff Training Module and will be tested on their knowledge and understanding.
4.3 A record of staff training will be maintained and made available to the regulatory authorities on request.
4.4 All staff will be made aware of the powers of Enforcement Officers including rights of entry contained within Part 15 of the Act, and will be instructed to co-operate in the proper performance of the respective officer’s powers. Owing to the nature of our betting provision we would normally expect the appropriate regulator to liaise with our Compliance Manager, Patrick Chesters in the first instance.
SECTION 5
KEEPING CRIME OUT OF GAMBLING
5.1 As a licensed betting operator we are subject to the provisions of the Proceeds of Crime Act 2002 and Terrorism Act 2000 which specifically include Money Laundering considerations. Our legal obligation is to be alert to attempts by customers to gamble with money acquired unlawfully, either to obtain ‘clean’ money in return or simply to spend it as a leisure activity. Whilst we only offer betting facilities on race days and have a large number of people betting with relatively small amounts of money our exposure to money laundering is not considered to be high risk. Furthermore, we do not operate customer accounts and so there is no opportunity for us as an operator to build up a personal profile of customers like traditional high street betting offices.
5.2 A Money Laundering Risk Assessment will be carried out which will identify, analyse and evaluate the money laundering and Terrorist risks associated with our business. This risk assessment will be reviewed annually and as and when other regulatory or legislative requirements apply to ensure that it remains effective particularly if other betting products are offered in the future i.e. Pool Betting.
5.3 Our nominated Anti- Money-Laundering Officer will be responsible ensuring that Anti-Money laundering legislation is complied with and will report suspicious transactions to the Serious Organised Crime Agency.
5.4 Anti-Money Laundering training will be given to all relevant staff and a training record kept. Training will incorporate the information provided within the Commission’s “Duties and responsibilities under the Proceeds of Crime Act 2002- Advice to operators,” document last published in 2017.
5.5 A maximum stake of £200 or more will only be accepted once a supervisor has authorised the transaction. In order to do so the supervisor will be required to satisfy themselves that the money has been obtained from a legitimate source.
5.6 Specific provision will of course, be made for VIP customers to allow for higher bets to be placed.
5.7 Staff will be trained to identify cheating by customers i.e. slow counting, unusual betting patterns, slow counting. Any such incidents will be brought to the attention of a supervisor and in the case of unusual betting patterns our Compliance Officer.
5.8 Any person found to be conducting unlicensed betting within the race course will immediately be removed by stewards.
5.9 Money-lending within the race course is strictly forbidden and any persons found doing so will be removed by stewards. Staff will be trained with regard to organised money-lending.
5.10 No account or credit facilities will be provided to any customers wishing to bet.
5.11 As part of our internal controls and financial accounting systems we will only accept cash and debit cards transactions.
5.12 A condition of accepting bets is that for a bet to be valid, customers placing bets must not be in breach of any rules about irregular and/suspicious betting or misuse of insider information. Staff will receive appropriate training in this regard.
5.13 All betting terminal sites are secure with access to authorised persons only.
5.14 Internal cash handling procedures are in place which includes appropriate reconciliation of cash to transactions with each individual cashier being responsible for their own till. Collections of cash will be made at appropriate times by two security employees and removed to a secure area within the main administrative buildings of the courses.
5.15 Police officers will normally be present on race days and our Compliance Manager will liaise with them in relation to any intelligence regarding pickpockets etc. If necessary the Public Address system will be utilised to inform customers of their presence.
5.16 Counterfeit currency scanners will be utilised and any notes believed to be counterfeit will be retained and provided to the Police.
SECTION 6
ENSURING THAT GAMBLING IS CONDUCTED IN A FAIR AND OPEN WAY
6.1 Betting will be conducted under Tattersall’s Rules which are fully comprehensive and a copy of the rules will be displayed at each entrance to individual betting rings where customers have unrestricted access. Copies of the rules will be available on request and will be displayed within the racing section of the Chester Race Company website. Tattersalls rules can also be obtained from their own website.
6.2 An accurate summary of contractual terms on which betting is offered will be made available to customers on request. Any changes to our terms will be notified in advance. We are aware of our obligation to comply with the requirements of the Consumer Protection from Unfair Trading Regulations 2008 and will ensure that our terms are fully compliant.
6.3 We will ensure that the terms under which the provision of our betting is provided to customers is not unfair and is transparent within the meaning of the Consumer Rights Act 2015 and we will ensure that no unfair commercial practices will be carried out in breach of the Consumer Protection from Unfair Trading Regulations 2008. (This conforms with a new Licence Condition 7.1.1 which applies from 31 October 2018)
6.4 Should changes take place to betting rules or terms under which betting is offered they will they will be published before they come into force and before betting begins.
6.5 As the holder of a Track Premises licence we will ensure that only licensed bookmakers and their representatives who are listed under Schedule Y of their operating licences are permitted to trade within the prescribed betting areas. The charge for admission to a betting area for the purpose of carrying on business in connection with providing facilities for betting shall not exceed five times the cost of the highest charge paid by members of the public who are authorised to enter that part of the track.
6.6 Independent Bookmakers must display on their joints any rules which differ from Tattersalls Rules.
6.7 Chester Bet and Bangor Tote do not have customer accounts and do not hold customer’s money save for the stakes for each individual race. In the unlikely event of insolvency customer stakes and winnings will be protected.
6.8 All customers will be provided with a betting slip which will include;
A. The operator’s name and contact details
B. The race day name or code, date and race number
C. Name and number of their selection
D. The stake, and the fact that the bet will be 10% less than the Starting Price.
E. The type of bet
F. Consideration will be given to providing a ‘Bet Responsibly’ message on betting slips.
6.9 Should bets be taken on other sports staff will be made aware of the appropriate rules that apply.
SECTION 7
PROTECTING CHILDREN AND OTHER VULNERABLE PEOPLE FROM BEING HARMED OR EXPLOITED BY GAMBLING
7.1 It is an offence for Children and Young Persons under the age of 18 to bet or attempt to bet under any circumstances which includes having a bet placed for them by a parent or adult. This includes being accompanied by a parent or adult. If a child or young person has been able to bet their stake money will be returned to them and the bet will be voided and any winnings forfeit. This will also apply to an adult placing a bet on behalf of a child or young person. That adult or child or young person will be advised that the return of stake is a statutory requirement under Section 83(1) of the Gambling Act 2005. As an operator we will reserve the right to exclude such persons from the race course should circumstances dictate i.e. various attempts are made to place illegal bets by either the adult or the child or young person.
7.2 A notice stating that no person under the age of 18 years will be displayed in a prominent place at each entrance to all public areas of the race course and at the entrance to areas restricted to adults only. Persons who appear to be under-age will be required to produce appropriate identification before being allowed into adult only areas.
7.3 Under 18 Prohibition notices will be displayed at each set of betting terminal sites.
7.4 A log will be kept of incidents involving attempts to place under-age bets. A log will also be kept of the number of attempts to by children and young persons to enter adult only areas. These logs will be in the form of a loose-leaf sheet which will be collected and collated at the end of each days racing and scrutinised by a Supervisor or Compliance Manager. Logs will be signed off by a Supervisor and made available to the Gambling Commission, Local Authority Officers or the Police on request. We will monitor the effectiveness of our under-age provisions and address any identified areas where further training or policy changes are required.
7.5 A “Think 21” policy is in operation and all employees taking bets will require any person who appears to be under the age of 18 to provide photographic identification such as a Photocard Driving Licence or Passport which clearly shows their date of birth. Others documents such as the ‘PASS (Proof of Age Scheme, Citizen Card or Validate) card is acceptable. Employees taking bets will wear a Think 21 badge.
7.6 No person who is employed to take bets or be indirectly exposed to the provision of betting will be under 18 years of age. This includes back office duties or being employed in adult only areas and includes any duties with regard to gaming machines.
7.7 Persons who cannot produce satisfactory ID will not be allowed to bet. This will also apply should the ID appear to be a forgery. There is no power for our employee to seize forged documents, however, details will be supplied to the Police who may present at the race course.
7.8 “Think 21” and Under 18 prohibition on betting posters will be clearly displayed at all betting terminals and at entrances to areas where children and young persons are permitted.
7.9 Race Cards, in particular on ‘Family Days,’ will include reference to our under-age betting restrictions and advise adults that they cannot place bets on behalf of children or young persons.
7.10 An independent firm of ‘Mystery Shoppers’ will be engaged to test staff under-age betting compliance at various meetings. Details of their findings may identify further training needs and will be made available to the regulatory authorities on request.
7.11 All betting race course advertising will be sensitive to under-age betting considerations and will comply with the Gambling Industry Code for Socially Responsible Advertising. Particularly the new standards which came into force on 2 April 2018.
7.12 All betting staff will be trained in respect of identifying problem gamblers and should a customer interaction be required this will be carried out at supervisor level in a private area. Details of the signs of problem gambling are dealt with in our Training Module. Whilst we acknowledge the importance of identifying problem gamblers, it is unlikely that the level of our betting provision on race days only will allow our staff to have sufficient ‘Know your Customer’ capability, unlike traditional high street betting offices.
7.13. The health and safety of our staff will be paramount in any customer interaction scenario.
7.14. Should evidence of a clear case of problem gambling occur we will operate a Self-Exclusion policy, should a person who is identified as a problem gambler refuse to self-exclude we reserve the right to bar them permanently from the racecourse.
7.15 Dedicated Self-Exclusion forms will be provided at all of our betting terminal sites and where a customer agrees to self-exclude they will be dealt with by a supervisor in a private area. Ideally a photograph of the customer should be obtained. The self-exclusion will be for a minimum of 12 months and will apply both to the Chester and Bangor on Dee race courses. Customers will be required to sign a copy of the exclusion and will be provided with a copy. Once agreed the self-exclusion is irrevocable during the excluded period. Should a person who is identified as a problem gambler refuse to self-exclude we reserve the right to bar them permanently from the racecourses. Customers can self-exclude immediately or be offered a cooling off period commensurate with race day meetings.
7.16 A register of Self-Exclusions including names and addresses will be maintained and details of persons who have been self-excluded will be made available on race days at each of our betting terminal sites. Customers will be encouraged to self-exclude from other betting premises within the appropriate local areas.
7.17. No marketing material will be sent to self-excluded persons.
7.18. Problem gamblers can self-exclude without having to visit either of the racecourses by telephoning the main reception centre at the Chester race course on telephone number 01244 327900.
7.19 Problem gambling information leaflets will be made available at each set of betting terminals. These will include contact information for the National Gambling helpline and other problem gambling helplines. It will also details of relevant websites such as www.gambleaware.co.uk , www.ygam.org and www.gamcare.org.uk
7.20 The company will make an annual contribution to the RESPONSIBLE GAMBLING TRUST to aid the treatment, education and research into problem gamblers.
7.21 Staff will also be trained in relation to vulnerable persons, which could include someone who is mentally impaired and those whose judgement made be impaired by alcohol and drugs.
SECTION 8
COMPLAINTS AND DISPUTES
8.1 Complaints and disputes relating to the betting provision (licensing activity) made by Chesterbet or Bangorbet will be dealt in a timely, fair, open and transparent manner.
8.2 Initial complaints will be dealt with by the customer facing operative.
8.3 If the complaint remains unresolved it becomes a dispute the second stage will be dealt with by a supervisor.
8.4 If no resolution is reached the third stage will be to escalate the dispute to our Compliance Manager or his deputy.
8.5 Should the complaint still not be resolved then the customer will be provided with the details of our Alternative Dispute Resolution (ADR) who is the Betting Adjudication Service (IBAS), an ADR approved by the Gambling Commission, and whose services are free to the customer. They will reject complaints that are of a frivolous or vexatious nature in line with the requirements of The Alternative Dispute Resolution for Consumer Disputes (Competent authorities and Information) Regulations 2015. Decisions made by the ADR will be communicated to the Commission in writing by us via the Commission’s e-Services facility under ‘notifications -LCCP Question: – ‘ADR Disputes.’ Any change of ADR will be immediately reported to the Commission.
8.6 A dedicated information booklet provided details of all stages and relevant contact numbers has been produced and is available at all our betting terminal sites.
8.7 All complaints which are not resolved at stage one will be recorded as disputes.
8.8 We as an operator will abide by any dispute decision made by IBAS.
8.9 Should the complaint relate to any aspect of Tattersall’s Rules, the Tattersall Committee, who are also an approved ADR, will deal with the complaint. Their service is free to the customer and we will abide by any decision made by them.
8.10 We will not restrict ADR services to any terms that are intended to remove or restrict the customer’s right to bring proceedings against the Chester Race Company Ltd in court.
8.11 We will respond to an ADR’s request for advice within 10 working days.
8.12 Examples of betting complaints could include; the outcome of a betting transaction; the way in which the transaction was managed; concerns about the way we operate our business in relation to the three Licensing Objectives. The complaint must relate to the licensed betting provision only. Incidental complaints which do not fall under the scope of the requirements of the LCCP will be dealt with by our Compliance Manager.
8.13 Complaints/Disputes can be made either in person or in writing, telephone or email and can be made up to six months after the incident took place. We will provide the customer with a written acknowledgement of their complaint together with our procedural information booklet, and a written decision. Full details of where to send the complaint are contained within the booklet.
8.14 All complaints/disputes must be made in a timely manner and in any case completed within 8 weeks of the initial dispute taking place. Our decisions will be communicated in writing with a statement that this concludes our involvement and providing details of the ADR.
8.15 Leaflets outlining the Complaints/Disputes procedure are available at each set of betting terminals. The leaflet is written in plain English and simple to understand. The document provides details of the procedure required to make a complaint/Dispute and to whom it should be addressed.
8.16 A record of customer complaints will be maintained and will include the details outlined in Social Responsibility Code 6.1.1.7.
8.17 All complaints/Disputes referred to ourselves will be dealt within 8 weeks unless the customer fails to co-operate in a timely manner.
8.18 The numbers of complaints/disputes will be communicated to the Commission by way of our Regulatory Return.
8.19 A link or signposting to our Complaints Policy will be provided within our Terms and Conditions document.
SECTION 9
MARKETING
9.1 All our advertising will be made in a socially responsible manner and will comply with the advertising codes of practice issued by the Committee of Advertising Practice (CAP) particularly the requirements contained within Section 16 and the Gambling Industry Code for Socially Responsible Gambling. In addition, we will adhere to any gambling related advertising issued by the Advertising Standards Association. None of our marketing will mislead and will not be targeted at vulnerable people.
9.2 Our marketing advertisements for betting will clearly state any significant limitations or qualifications. The conditions of any promotions will be clearly stated.
9.3 We will also abide by the requirements of the new Advertising Standards Agency guidance on responsible gambling advertising.
9.4 Any incentive, inducement or reward will be set out clearly set out with information made readily available to customers. Neither the receipt nor the value or amount of the benefit is dependent on the customer gambling for a pre-determined length of time or frequency, altered on increased if a qualifying activity or spend is reached within a shorter time than the period over which the benefit is ordinarily offered. If the value of the benefit increases with the amount the customer spends it will do so at a rate no greater than that at which the amount spent increases.
9.5 If the benefit comprises free or subsidised travel or accommodation that facilitates a customer’s attendance at the racecourse, the terms of the offer will not be directly related to the level of the customer’s prospective gambling.
9.6 The terms and conditions of each marketing incentive will be made available for the full duration of the promotion.
9.7 No dedicated betting advertising will feature children or young persons or indeed anyone under 25 years of age.
9.8 Any digital advertisement on websites will not infringe copyright content.
9.9 We do not advertise any third-party activity on our betting section of the home website of the Chester Race Company Ltd.
9.10. We will also comply with any relevant betting guidelines from the Consumer Marketing Authority
SECTION 10
INFORMATION REPORTING
10.1 We will report to the Gambling Commission any suspicion of relevant offences as outlined within Licence Condition 15.1.2 of the LCCP. This will include reporting appropriate information to relevant sports governing bodies as outlined in Part 3 of Schedule 6 of the Gambling Act 2005. In particular the Jockey Club,
10.2 We will notify the Commission of any a of the relevant changes which are contained within Licence Condition 15.2.2 of the LCCP and those Key events will be reported to the Commission via e-Services facility i.e
10.3 The appointment of a person to, or a person ceasing to occupy, a ‘key position’:
A. a ‘key position’ in relation to a ourselves is:
B. a ‘specified management office’ as set out in (current) LCCP licence condition 1.2
C. a position the holder of which is responsible for the licensee’s anti-money laundering procedures, including suspicious activity reporting
D. any other position for the time being designated by the Commission as a
E. ‘key position’. (Notification is required whether or not the person concerned is required to hold a personal management licence and whether or not the event notified requires the Chester Race Company Ltd., to apply for a variation to amend a detail of their licence.)
10.4 Any change to the structure or organisation of our business which affects a ‘key position’ or the responsibilities of its holder.
Financial events
10.5 Any material changes in the Chester Race Company’s banking arrangements, in particular the termination of such arrangements or a particular facility and whether by the ourselves or the provider of the arrangements.
10.6 Any breach of a covenant given to a bank or other lender.
10.7 Any default by ourselves as a group company in making repayment of the whole or any part of a loan on its due date.
10.8 Any court judgments (in whatever jurisdiction) which may be made against us remaining unpaid 14 days after the date of judgment.
10.9 We have our accounts audited by an independent qualified auditor and we will produce those as required by the Commission.
10.10 Any other position for the time being designated by the Commission as a
‘key position’. (Notification is required whether or not the person concerned is required to hold a personal management licence and whether or not the event notified requires the Chester Race Company Ltd to apply for a variation to amend a detail of their licence.)
10.12 Any change to the structure or organisation of the licensee’s business which affects‘key position’ or the responsibilities of its holder.
Any court judgments (in whatever jurisdiction) against the Chester Race Company Ltd remaining unpaid 14 days after the date of judgment.
10.14. Any change in our arrangements as to the methods by which, and/or the payment processors through which, the licensee accepts payment from customers using their gambling facilities Where the licensee holds customer funds in a separate bank account, any deficit on reconciliation of such bank account.
10.15 Any change in our arrangements as to the methods by which, and/or the payment processors through which, the licensee accepts payment from customers using their gambling facilities
SECTION 11
REGULATORY RETURNS
11.1 The company will submit a Regulatory Return to the Commission in accordance with Licence Condition 15.3.1.
SECTION 12
BETTING TERMS AND CONDITIONS
A copy of the full betting rules can be found here. Regulated by the Gambling Commission. See Gambling Commision Operating Licence. See a copy of our Track Licence. See a copy of Bangor Sport Rules.
