As the steward of a national asset, we have a duty to operate The National Lottery responsibly to ensure its sustainability for years to come. For us, that starts with our tens of millions of players. Without them, we wouldn’t be able to return around 95% of every pound spent on National Lottery games to winners and society. We have a responsibility to keep our players safe by preventing underage play and playing too much.
To this end, we shifted our focus during the year from player protection to an emphasis on healthy play. We developed a new framework with four key areas – player, product, place and leadership – through which we will achieve our ambitions to promote healthy play and make The National Lottery the safest place to play.
While healthy play is a top priority, it is not the sole strand of our commitment to doing business responsibly. We’re proud of the fact that corporate responsibility extends across every one of our teams and at every level of our business.
And, during 2019/20, we set out to expand our work in a wide range of areas – from the support we offer employees, the way we advise big winners and the work we do to address our environmental impact to the way we treat suppliers, the investment we make in the community and the training we offer to help identify signs of modern day slavery.
Be the Safest Place to Play
Promote Healthy Play
Talent, Engagement and Development
Modern Slavery Act
Energy, Waste and Consumption
Raising Internal Awareness
We’re proud to say that around 60% of UK adults play our games and we’re proud of the fact that The National Lottery is ranked just 59th in the world in terms of per capita spend, despite being the fifth largest lottery in the world in terms of sales. Both achievements underline the ongoing effectiveness of our approach in this area. (Source: La Fleur’s World Lottery Almanac 2020)
We know, however, that we can’t take anything for granted. Even though the inherent risk of unhealthy play associated with National Lottery products remains very low, we recognise that, because of our scale, we must continue to do everything we can to encourage and support healthy play wherever possible.
Our new healthy play strategy enables us to do this by focusing on four key areas:
Our employees are key to delivering the strategy effectively, so, in January 2020, we launched an internal campaign to raise awareness of our ambitions to promote healthy play to all players and to make The National Lottery the safest place to play.
The campaign succeeded in putting healthy play firmly in the spotlight. As well as creating a short film featuring employees from different departments talking about what healthy play means to them, we added complementary new content to our intranet and presented the strategy at team meetings across the business. Following the campaign, we rolled out our new healthy play training module, which all employees were required to complete and pass with a score of 80% or higher.
We have a legal and moral responsibility to ensure that National Lottery products are not bought or played by anyone under the age of 16. It’s therefore critical that we work closely with our retail partners – all of whom are independent of Camelot – to educate them on how and when to ask for ID, to train their staff and on how to record refusals.
Our mystery shopper programme, which we have been running since 1999, uses young people who are aged 16 or over, but who look younger, to make sure that retailers are asking for ID where appropriate and not selling to anyone under the age of 16.
If a retailer fails a mystery shopping visit, they are given additional training and support before they receive another visit. If a retailer fails a visit on three occasions, their National Lottery terminal will be suspended and is likely to be removed.
During the year, we continued with a range of measures to reinforce retailer awareness of their responsibilities. This included distributing our ‘Being A Responsible Retailer’ leaflet during sales visits, together with a refusal register, which enables staff to record any sales they have refused as a result of the customer not having suitable – or any – identification.
We also emphasised the importance of responsible selling and supporting healthy play through articles in our bi-monthly retailer magazine, Jackpot, messaging on our dedicated retailer website, during face-to-face retailer visits and in telephone calls.
As a result of the measures we have put in place, the programme once again delivered excellent results in 2019. Of the 11,600 mystery shopping visits that took place, 91% of retailers correctly asked for ID as proof of age on the first visit – exceeding our target of 90%.
Jenny Blogg, Retail Director at Camelot
Our activities to prevent underage play are not limited to our retail channel. If a player wants to set up an online National Lottery account, they must go through a rigorous registration process, and pass an identity and age verification check by Experian. This enables us to ensure that the individual is who they claim to be and is legally old enough to play National Lottery games.
If somebody fails the Experian check but still wants to open an online account, they are required to post certain evidence to us. We would then review the evidence to see if it satisfies the necessary requirements. If it does, we would remove the block on the proposed account. If it doesn’t, the applicant would be prevented from accessing any National Lottery products.
During the year, we launched our new online behavioural analytics model – Mercury V2 – which took into account learnings from our earlier models and previous player interventions. Mercury V2 includes enhanced identification of at-risk players based on their playing behaviour and considers a range of indicators of unhealthy play.
We also introduced a refreshed interventions programme, with targeted, escalating communications to at-risk players to encourage positive changes in their playing behaviour and greater use of our range of healthy play tools to help them stay in control.
In the coming year, we will continue to enhance both our behavioural analytics model and our interventions programme, looking closely at how we can identify at-risk players and engage with them even more effectively. We will also be furthering our efforts to promote healthy play in retail, including looking at new ways to best support our retail partners in feeling confident and equipped in this respect.
Our games are designed to be both safe and fun to play – and it’s widely recognised that the inherent risk of problem play associated with National Lottery products is very low.
However, we continue to take our responsibilities in this area seriously, as reflected in our decision last September to remove £10 Scratchcards from sale after our healthy play research showed that they over-indexed among problem gamblers. Although these players equate to less than 1% of all National Lottery players, our decision underlined our commitment to healthy play and ensuring that The National Lottery is the safest place to play.
Even though we are confident that National Lottery games pose a very low risk of causing harm to players, we aim to minimise this as much as possible. We do this by putting all of our games through a robust ‘Responsible Game Design Process’ to ensure that they are fun to play and don’t overly appeal to vulnerable groups.
As part of the process, we assess the level of risk of all of our games using two tools:
If either of these tools identifies a potential risk to players, we will modify the game to reduce the risk to an acceptable level. If the risk remains too high, we will not launch the game.
Overseeing the whole process is the Game Risk Evaluation Action Team, which is made up of representatives from key internal departments from across the business. The process is supplemented by an enhanced research and review programme for any games that are significantly new and different, while the Gambling Commission also approves all new games before they launch.
To further support the process in 2019/20, we provided relevant employees with additional training to help them develop a better understanding of product-related risks, and potential opportunities to develop safer and more sustainable games.
We also engaged with an independent research consultancy to evaluate and validate the risk factors we use in our Responsible Game Design Process. Validating our approach, the research found that the majority of factors that we use to assess our games’ risk levels were relevant, especially in the case of Scratchcards and Instant Win Games. It also helped us to identify additional risk factors to consider for further investigation and integration into our game design process as it evolves.
To further promote healthy play, we ensure that all of our products include the helpline details for GamCare – the leading national provider of free information, advice and support for anyone affected by problem gambling – while a number of our products and adverts feature our ‘DREAM BIG PLAY SMALL’ messaging.
In addition, all of our advertising and marketing is checked to ensure that it complies with the Advertising Standards Authority’s CAP Code and BCAP Code. These promote safe marketing and, in particular, the need to prevent young people under the age of 18 from being harmed by any unsafe advertising.
In the coming year, we will continue to focus on ensuring that our Responsible Game Design Process remains fit for purpose. As part of this, we will carry out further exploratory work into the outcomes of the independent review of the process that took place this year.
As part of our work to promote healthy play to all players, we launched our ‘DREAM BIG PLAY SMALL’ messaging, which reflects and reinforces our guiding principle – lots of people playing a little.
‘DREAM BIG PLAY SMALL’ first appeared in August 2019 on in-store digital media screens, on the front of draw-based games tickets, and in all of our marketing and service emails. In September, we spread the word even more widely, with the messaging included in a Scratchcard advert on national television and radio. It also appeared for the first time on in-store posters and point-of-sale material for our ‘£250,000 Birthday’ Scratchcard.
The following month, our website went through a brand transformation – with ‘DREAM BIG PLAY SMALL’ integrated across the player journey and appearing on more than 30 different pages. We also added a QR code, which links to the healthy play page on our website, to our Players’ Guide. As a result of this work, we’ve seen a significant increase in the number of visits to the webpage.
In November, the wording was featured on our Christmas Scratchcard posters and point-of-sale material across our retail estate. And, in February 2020, we began printing ‘DREAM BIG PLAY SMALL’ on the reverse of all new Scratchcards, with the messaging due to be visible on all Scratchcards by the end of 2020/21.
Looking ahead to the coming year, we plan to roll out the ‘DREAM BIG PLAY SMALL’ message on even more of our products and in more above-the-line advertising to ensure that we are continuing to promote our healthy play message as extensively as possible.
As well as wanting to raise awareness of healthy play with our players, we want our retailers to feel supported and confident in having conversations with customers about their play.
We therefore continued rolling out our ‘Supporting Healthy Play’ training to around 44,000 retailers. The training promotes a consistent approach on how to respond to a customer if they directly ask for help, and also provides retailers with the appropriate resources to be able to offer further information or support if they are concerned about a customer.
In September 2019, we added a new ‘Responsible Play’ button to National Lottery terminals, giving retailers the ability to print out a pink ticket – much like a Lotto or EuroMillions ticket – for players which contains details of where support is available. As a result, retailers can instantly and discreetly provide details of GamCare and The National Lottery’s healthy play webpage.
We also provided retailers with a new ‘Supporting Healthy Play’ leaflet, which outlined the key aspects of the training, and a ‘Responsible Play’ terminal sticker to remind store employees to press the ‘Responsible Play’ button if a customer asks for support with their play.
To monitor and evaluate the success of the training, our Contact Centre team has been conducting knowledge-check calls, in which retailers are asked questions on how they can support their customers to play in a healthy way and the resources available to them. The results have been very positive – we have seen an average pass rate of 87%, which is 2% higher than our target.
Creating a safe environment to play is also dependent on the ability of our employees to support players. We have therefore continued to provide additional training – including monthly knowledge checks and accreditations – to our Contact Centre employees on how to spot signs of potentially unhealthy play and how to promote healthy play more effectively.
We have also developed new onboarding sessions for Contact Centre staff, with an enhanced focus on our healthy play strategy and ambitions. In these sessions, new starters conduct reviews of conversations with players and learn how they can support them to play in a healthy way through the use of our online tools.
As we continue to make The National Lottery the safest place to play, in 2020/21 we plan to bring in problem gambling specialists and experts to further strengthen the training we offer our Contact Centre employees.
Alison Gardner, Head of Corporate Responsibility at Camelot
We want to support new and existing players to play in a healthy way. With over 7.5 million active registered online players, national-lottery.co.uk is Europe’s largest online lottery in terms of sales and one of the top e-commerce sites in the UK.
This platform gives us the opportunity to provide players with a range of online healthy play tools. Even though we already offer a wide selection of carefully developed, practical tools to enable our online players to manage their play – including deposit and play limits, session time reminders and transaction histories – enhancing our healthy play toolkit was a central focus for us during the year.
As a result, we added three new complementary tools to further strengthen it:
Although our players can already use our existing tools to take a break from playing or fully exclude themselves from all National Lottery games, we have also voluntarily joined GAMSTOP. This free gambling self-exclusion service lets people put controls in place to restrict their online gambling activities with websites and apps run by companies licensed in Great Britain.
We strive to be leaders when it comes to healthy play and are therefore proud to have been awarded Advanced Level 2 of GamCare’s Safer Gambling Standard, a social responsibility quality standard for licensed gaming operators. It aims to increase overall standards of social responsibility practice across the industry, helping to make play safer for all.
We led and contributed to a number of industry working groups during the year, including fulfilling leadership roles with both the European Lotteries and World Lottery Association. We also continue to hold the highest level of the European Lotteries’ Responsible Gaming Standard, as well as Level 4 – the highest level possible – of the World Lottery Association’s Responsible Gaming Certification, and have been certified against both for over 11 years in recognition of our commitment to continuous improvement.
In 2020/21, we plan to achieve Advanced Level 3 of GamCare’s Safer Gambling Standard, and will repeat the assessments required to maintain the highest levels of European Lotteries and World Lottery Association accreditation for a 12th year.
Our suppliers are managed on a daily basis by our Relationship Managers who are, in turn, supported by our Group Procurement Team. The majority of our expenditure with suppliers is associated with IT and marketing.
We always carry out appropriate due diligence when considering taking on new suppliers, with selections based on a range of factors: quality, completeness and scalability of service; management systems, processes and flexibility; relevant service experience and track record and social considerations; risk transfer and management; and cost and value for money.
We review our existing suppliers through a combination of periodic review meetings, surveys and audits. This ensures that our agreed terms of business and required operating standards are being implemented and delivered, which helps us as we strive to make sure that there is compliance with all relevant legislation and regulations.
Our Procurement Team also conducts an annual Supplier Conduct Review with a select subset of around 25 suppliers. The survey, which helps us to understand how our suppliers manage their own businesses, covers areas such as business ethics, supply chain management, human rights and environmental management, together with broader corporate governance issues. We analyse the responses received and measure them using a predetermined scoring system to identify where improvements can be made.
We review the survey’s format each year and update it as necessary to include relevant questions, such as our suppliers’ approach to preventing and monitoring risks in modern slavery and human trafficking.
Raising awareness of the issue of modern slavery and human trafficking continued to be a key priority for us. We communicated our commitment to preventing such practices within our supply chain to all of our suppliers and our network of National Lottery retailers, and reminded them of our standards and expectations in this area.
We also repeated relevant training to ensure that all of our employees are aware of best practice, and are able to take appropriate action to monitor and prevent any instances of modern slavery or human trafficking. We continue to prioritise our Retail Sales Team due to their supplier-facing role.
With integrity at the heart of everything we do, we wholeheartedly embrace our commitment to treating our suppliers fairly and paying them promptly in line with our agreed terms. We continue to observe our obligations as set out in our duty to report on payment practices and performance, and we are committed to working with our suppliers to ensure that we are in keeping with the spirit of the legislation.
We realise that much of what we do in running The National Lottery and raising huge sums of money for Good Causes is only made possible thanks to the excellent work carried out by our suppliers and other stakeholders. We therefore continue to seek out ways of supporting these relationships in a mutually acceptable and productive manner.
In the coming year, we will be using the Supplier Conduct Review, together with a detailed questionnaire, to gain a better understanding of our ‘tier one’ supply chain.
Through our ‘Living Life Changing’ programme, employees can take up to two days a year to volunteer with any National Lottery-funded charity. We also have three charity partners with whom we encourage employee engagement: Watford Mencap, The Peace Hospice and The Conservation Volunteers.
During the year, over 300 of our employees dedicated 2,052 hours of their time – the equivalent of over 250 working days and an almost 70% increase on the previous year – to give something back to local communities by volunteering at a wide range of organisations.
One such organisation is The Peace Hospice in Watford, which has been providing care to support the community across South West Hertfordshire, and the wider area, for more than 25 years. In addition to supporting people at the end of their life, the charity focuses on helping people to manage their illness and empowering them to achieve the best quality of life possible.
But volunteering isn’t the only way that our employees can interact positively with communities. We offer match funding for fundraising activities and events, meaning that employees who participate can claim up to £500 in the financial year in match funding. In 2019/20, our employees raised over £89,700 through match funding – up from £35,200 in 2018/19.
Employees also have the opportunity to sign up to the Give As You Earn payroll scheme, enabling them to donate to charity through their salary every month. In 2019/20, our employees gave over £5,200 through the scheme.
Since 2018, our employees have been donating to local food banks and, in 2019/20, they contributed more than 106kg of food and non-food items.
Gemma Norris, Senior Fundraising Manager at The Peace Hospice
During the year, we have made various positive changes to our office buildings. For example, we have stopped purchasing single-use plastic cutlery and provide only reusable metal cutlery; we have removed all single-use plastic cups from drinks points; and we have switched to biodegradable takeaway food containers. To encourage greener behaviour, we offer employees a discount when they buy coffee using a reusable mug and we have also continued to replace standard light bulbs with more efficient LED ones.
We’ve also been working hard in our distribution centre, investigating and implementing more environmentally friendly alternatives to our product packaging. In 2019/20 we were able to change the bags used for Scratchcard packaging to a product that clearly displays that it is both fully recyclable and only manufactured from recycled material.
In addition, the cardboard boxes used to post our Scratchcards now clearly show that they are fully recyclable and carry the FSC stamp. Throughout the coming year, we will continue to look for greener alternatives to the rest of our packaging products.
As part of our work to raise greater awareness of environmental issues, we took part in World Environment Day in June. This saw us run a companywide campaign on effective recycling and waste management, as well as host a large-scale volunteering event where employees were able to take part in an environmental activity with one of our charity partners, The Conservation Volunteers.
Using a three-stage approach – research, engagement and design – we are now in the final phase of developing a new environmental strategy with four key focus areas: energy, waste, responsible production and consumption, and engagement. The strategy, which we are planning to launch in 2020/21, will play a key role in helping us to further reduce our environmental impact.
In an age when cyber-attacks are commonplace, it is vitally important that we try to stay one step ahead, and keep customer and employee data secure. With increased focus on, and regulation of, personal data, we must also ensure compliance with all relevant legislation.
During the year, we continued to follow rigorous security standards and underwent regular independent audits. We successfully maintained compliance with the ISO27001, WLA:SCS and PCI-DSS standards.
We chaired the World Lottery Association’s Cybersecurity Working Group, the EuroMillions Security Working Group and played a key role in government-run industry threat intelligence schemes, such as The National Cyber Security Centre’s ‘Industry 100’. The year also saw us deploy a compliant cookie consent mechanism on The National Lottery website.
Our data protection programme continues to evolve and mature. To this end, we have updated our ‘Data Protection’ and ‘Data Retention’ policies, as well as our ‘Employee Privacy Notice’, and have also revised our ‘Data Privacy Impact Assessment’ form.
Our Head of Corporate Responsibility chaired the World Lottery Association Responsible Gaming Working Group and is a member of the European Lotteries CSR and Responsible Gaming Working Group.
Participating in these groups allows us to spot emerging trends and highlight best practice, as well as work together to tackle some of the most pressing issues facing vulnerable customers.
We also work with a number of other organisations which help to shape our thinking, including:
BUSINESS IN THE COMMUNITY – The Prince’s Responsible Business Network – is a business-led membership organisation made up of businesses that understand that the prosperity of business and society are mutually dependent. Through participation in Business in the Community’s groundbreaking campaigns and programmes, businesses can collaborate and help to bring about lasting change on a wider scale that benefits both business and society.
THE EUROPEAN LOTTERIES is the umbrella organisation of national lotteries across Europe. It promotes responsible and sustainable gaming, and provides a proactive and strategic forum for reflection, discussion and collaboration between members.
THE ADVISORY BOARD FOR SAFER GAMBLING aims to achieve a Great Britain free from the consequences of gambling-related harms. It acts as the Gambling Commission’s expert advisor, and sets the National Strategy to Reduce Gambling Harms and the priorities for research, education and treatment.
THE WORLD LOTTERY ASSOCIATION is a member-based organisation that seeks to advance the interests of state-authorised lotteries.
As well as being a time of extreme excitement and happiness, winning a sudden substantial sum of money can, for many people, be an overwhelming and emotional experience.
We have a dedicated Player Services Team comprising Winners’ Advisors who are responsible for providing the very best winning experience, and we have a huge support network in place to enable us to do this – including private banking, financial and legal advice, life-coaching and a bespoke concierge service.
During the year, our Winners’ Advisors paid out, advised and supported more than 800 high-tier prize winners. The team has also been working with a life coach and is now able to offer one month’s coaching funded by Camelot for winners of over £3 million. The life-coaching initiative helps winners to manage and understand the changes that a National Lottery win might make to their lives, and provides guidance and tips on how to deal with them.
Alongside the coaching, we produced a ‘Winner Wellbeing’ booklet, which is given to all of our winners at their validation appointment. The guide has been designed to help people with the sudden changes a win can bring. It includes an illustration of ‘the change curve’, which helps to demonstrate the different feelings and emotions that people can expect following any big change in their lives, with particular focus on the changes brought about by a large National Lottery win.
We also worked closely with a concierge company to help big winners with anything they need. The confidential service has been able to help our winners with a whole range of experiences that they previously never would have thought possible.
And, in November, we were able, for the first time, to bring together a group of anonymous winners to share their experiences and meet our life coach. Following the hugely popular session, we received very positive feedback:
“It was really good to be able to speak to people who had the same luck.”
“You couldn’t have brought it more to life!”
“It’s been so worthwhile. Please make Camelot do it again.”
Following the success of the event, we are planning to hold another life-coaching session for anonymous winners. We will also be exploring new ways of working to enhance the winning experience further, so that we continue to help and support all of our winners in the very best way possible.