Policies and Procedures Lotteries guidance September sea-cadets.org ms-sc.org. Telephone Fax

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1 202 Lambeth Road, London SE1 7JW ms-sc.org Telephone Fax Policies and Procedures Lotteries guidance September 2016 sea-cadets.org ms-sc.org Patron: HM The Queen A charity registered in England and Wales and in Scotland SC037808

2 Law and disorder policy Marine Society and Sea Cadets employees, volunteers or supporters must be vigilant for any suspicious or fraudulent transactions. Any suspicious or fraudulent transactions will not be accepted. This includes the taking or giving of anything that could be deemed to be a bribe for the benefit of the charity or of individuals associated with the charity which is not, under any circumstances, acceptable. Any attempted suspicious transaction will be logged and reported to the police or SOCA, where appropriate. Marine Society and Sea Cadets will only conduct its lotteries with a registered External Lottery Manager (External Lottery Manager Group Limited). Marine Society and Sea Cadets will keep a record of all tickets that have been distributed and sold. Marine Society and Sea Cadets will be able to provide information on police checks of a Lottery Ticket seller that may be carried out. We will also be able to provide address details and information of any monies sent in for tickets received. External Lottery Manager Group Limited operates from secure premises, with fire safes in situ, and contractors such as Securicor. Our ELM and response handling house, External Lottery Manager Group (contact Alex.Hartley@External Lottery Managergroup.co.uk) will process all entries and handle all monies received for a lottery, however all monies are paid directly into our own bank account and banking reports will be issued by External Lottery Manager Group on a daily basis. In addition to this, Marine Society and Sea Cadets will only sell tickets by the following methods: via direct mailed raffle packs, telephone and online. Marine Society and Sea Cadets will keep a record of all tickets distributed and sold by these methods. Marine Society and Sea Cadets will advise supporters not to sell tickets in the street, as well as stressing age and problem gambling restrictions. This advice appears on the reverse of all tickets. All players must have a declared permanent address with an accepted territory: UK mainland, Scottish Islands and Isle of Wight. Marine Society and Sea Cadets will ensure that addresses in the Channel Islands, Northern Ireland and Isle of Man will be removed from any mailing lists. Marine Society and Sea Cadets will send cold recipients no more than a maximum value of 20 worth of tickets. Marine Society and Sea Cadets will monitor their staff and self-employed agents on an ongoing basis, particularly regarding their direct or indirect association with potential criminal activities.

3 Marine Society & Sea Cadets will ensure that it reports any actual or suspected criminal activities to the police. Marine Society and Sea Cadets will expect that any suppliers or consultants who are associated with their lottery/raffle will report any potential and actual criminal activities to Marine Society and Sea Cadets as soon as possible. Marine Society and Sea Cadets will expect that any suppliers or consultants who are associated with their lottery/raffle will cooperate fully with the police and Gambling Commission should any actual or suspected criminal activities arise. Marine Society and Sea Cadets staff involved in promoting lotteries/raffles or selling lottery/raffle tickets face to face or via telephone will be trained to a satisfactory standard to ensure compliance with Marine Society and Sea Cadets gambling policy and procedure. Marine Society and Sea Cadets will not enroll any person into any of its lottery schemes if that person is suspected of any potential or actual criminal activities. As a part of our Law and Disorder Policy the below policies are specifically targeted at money laundering and proceeds of crime Extra tickets (beyond 60 tickets) will not be made available to players until all monies have been received for existing tickets within that draw, unless customer interaction has occurred. Without customer interaction additional online chances above this limit will not be entered into the draw and additional paper tickets will not be dispatched. Interactions will be recorded and where the tickets are purchased beyond the limit, records will be kept for 3 years. For supporters who have a proven track record of selling and returning tickets, an additional 60 tickets (on top of the original tickets) may be sent out without customer interaction, but if tickets are requested beyond this limit customer interaction must occur. Without customer interaction additional online chances above this limit will not be entered in to the draw and additional paper tickets will not be dispatched. Interactions will be recorded and where the tickets are purchased beyond the limit, records will be kept for 3 years. Staff will be trained to spot suspicious activity, patterns of play and customer behaviour. We will report any actual or suspected criminal activity in line with the Proceeds of Crime Act Staff are trained on the implications of the Proceeds of Crime Act and their obligation to report. Other than in the circumstances set out in the self-exclusion and protection of children and the vulnerable policies, refunds are only available at the discretion of the Marine Society and Sea Cadets. We monitor entries received both online and via paper tickets.

4 Policy on Fair and Open Draws Every draw is conducted at the External Lottery Manager s premises and in plain sight of External Lottery Manager Group staff. Draws are conducted at random using either a random number generator or using a blind draw. Speed prize draws will be drawn before any main draw takes place. All speed draw entries will then be added to the main prize draw. Marine Society and Sea Cadets will not accept any liability for any incomplete, damaged, illegible entries. In such cases monies associated with tickets will be treated as donations to Marine Society and Sea Cadets. Any ticket payments received after the closing date of the draw will be considered as donations to Marine Society and Sea Cadets and treated as such. A list of results will be published on Marine Society and Sea Cadets s website or sent on request. Winner s information is also available on request from the Customer Care team on Rules are published on Marine Society and Sea Cadets s website, entry forms and the reverse of raffle tickets. Printed versions of rules are available on request from Marine Society and Sea Cadets. Marine Society and Sea Cadets has a complaints procedure in place. A record is kept of ticketed sales, as well as tickets not purchased but distributed regardless of whether they are returned or not. Marine Society and Sea Cadets employees cannot purchase tickets in the raffle.

5 Responsible and Problem Gambling Procedure The following procedures have been put in place by Marine Society and Sea Cadets to encourage people to gamble responsibly and to seek help should gambling develop into a problem. GamCare is a UK based charity that offers help and advice on gambling. Their helpline number is and website gamcare.org.uk. These details are included on all Marine Society and Sea Cadets tickets and entry forms as well as the Marine Society and Sea Cadets website. Restrictions are in place regarding the number of books of tickets that can be allocated to an individual. The maximum is six lottery books per person. Players or carers of a vulnerable person can request self-exclusion or exclusion for the vulnerable person, from our database for further lottery mailings. Players can request the number of books they would like for an individual lottery and also the number of lotteries they would like to participate in on a yearly basis. Where customer behaviour indicates problem gambling they will be contacted by our Fundraising team under supervision of senior management and will follow procedures. All relevant sources of information will be used to identify customers at risk of problem gambling. Relevant staff will be given appropriate information for interaction with customers. Marine Society and Sea Cadets makes a contribution each year to help problem gambling via the Responsible Gambling Trust.

6 Players queries and complaints procedure Telephone complaints External Lottery Manager Group advisers deal with initial complaints and queries over the telephone. A telephone log sheet is completed at the time of the call. The callers contact information, details of the telephone adviser who took the call, the nature of the complaint and how the complaint was resolved are recorded on the log sheet. External Lottery Manager Group will keep the telephone log sheets on file for three years. Marine Society and Sea Cadets is notified immediately by External Lottery Manager Group if an initial complaint cannot be resolved. Written complaints External Lottery Manager Group will respond to initial complaints and queries in 48 hours of receipt of the complaint. All complaints are logged on the complaints log sheet. The person s contact information, details of the adviser dealing with the correspondence, the nature of the complaint and how the complaint was resolved are recorded on the log sheet. External Lottery Manager Group will keep written complaints log sheets on file for three years. Marine Society and Sea Cadets is notified immediately by External Lottery Manager Group if an initial complaint cannot be resolved. All general queries will be logged on the log sheets by External Lottery Manager Group and held for future reference. Every complaint will be taken seriously and fully considered by Marine Society and Sea Cadets in order that a satisfactory resolution can be achieved. Telephone and written complaints All general queries will be logged on the log sheets by External Lottery Manager Group and held for future reference. In the event that a satisfactory outcome can still not be reached, in accordance with the agreed protocol arranged on behalf of members by the Lotteries Council the matter will be referred to The Independent Betting Adjudication Service (IBAS) PO Box 62639, London EC3P 3AS, , adjudication@ibas-uk.co.uk. ICAS acts as an impartial adjudicator on disputes that arise between gambling operators and their customers. i. The player will be provided with IBAS referral details. ii. The outcome of IBAS intervention will be reported to the Gambling Commission.

7 Protection of Children and Vulnerable Persons Marine Society and Sea Cadets has taken steps to ensure that its lotteries do not attract young people. Marine Society and Sea Cadets has the following procedures in place to prevent under age players from participating in any lotteries we promote: i. On all cold data used by our ELM, External Lottery Manager Group, it is requested that all persons under 16 years of age are excluded from the list before being supplied for the use of our lotteries ii. iii. iv. Where possible Marine Society and Sea Cadets checks its database to ensure persons are above the legal age limit before data is supplied for the use of a lottery Details of the minimum age to play are listed on the reverse of tickets. Online raffle entrants must tick a box on the raffle website to confirm they are over 16 years of age Any player who provides dishonest information regarding their age automatically forfeits the right to any prize. This fact is also stated on the reverse of all tickets and on all entry forms. We will carry a tick box on our marketing materials for players to confirm that they are over 16 years of age. Any player found to be under 16 years of age will have any monies paid in relation to the lottery returned to them and they will immediately be taken off the available lottery database. In the event of a request to cease mailing lottery packs from a vulnerable person s carer, the vulnerable person s details will be removed immediately from our database. If the lottery pack has been received as a result of their details being supplied to Marine Society and Sea Cadets through a cold list, we will also provide the individual with information on how to have the details removed from the external list owners mailing records.

8 Gambling responsibly and problem gamblers The majority of people do gamble responsibly. The following information is in place to help you to gamble responsibly: You re buying fun, not investing your money. Set strict limits on how much time and money you re willing to spend. Quit while you re ahead. Only gamble with money you can afford to lose. Don t spend more money in the hope of winning back what you have lost. Keep up other interests and hobbies don t let gambling take over your life. Don t gamble in order to escape from stress or boredom. Gambling in moderation is okay. For some however gambling can become a problem. If you are concerned about the amount you are gambling, (or you are concerned for a friend or relative) then the following questions may help give you some guidance: Have you been criticised for your gambling? Have you lied to cover up the financial amount or the time you have spent gambling? Do arguments, stressful situations or disappointments make you want to gamble? Do you gamble alone for long periods? Do you stay away from work or college to gamble? Do you gamble to escape from a boring or unhappy life? Are you reluctant to spend gambling money on anything else? Have you lost interest in your family, friends or pastimes due to gambling? If you lose, do you feel you must try to win back your losses as soon as possible? When you run out of money while gambling, do you feel lost and in despair, and feel the need to gamble again as soon as possible? Do you gamble until your last penny is gone? Have you lied, stolen or borrowed just to get money to gamble or to pay gambling debts? Does your gambling ever make you feel depressed or even suicidal? If you feel you are answering Yes to the majority of the questions above, then it is likely a gambling problem exists. Sometimes just telling someone about your concerns can be a relief and the first step toward dealing with your problem. For friendly and helpful advice from trained counsellors you can call GamCare s helpline on The helpline is open 24 hours a day. You can also visit GamCare s website for more information and advice.

9 Self-exclusion policy Players can request a self-exclusion to be added to the Marine Society and Sea Cadets database. Self-exclusion can be selected for an initial period of between 6 and 12 months. Self-excluded individuals will not be permitted to participate in the lottery for a minimum period of six months and a maximum of twelve months and they will not be permitted to buy any tickets within the period of self-exclusion even if they state they wish to return to gambling during this time. Self-excluded individuals are removed from further addressed lottery communications including post, telephone, and SMS. All self-exclusion requests along with the date of the request will be captured on to the record on the Marine Society and Sea Cadets database. All reasonable steps will be taken to prevent any self-excluded individuals participating in gambling activity. Self-excluded individuals will not be entered into a draw and will have any money received refunded to them, including when funds were paid before the selfexclusion notice was received and the draw has not yet been conducted. Self-exclusion can be requested by contacting fundraising on At the end of the period chosen by the customer, the self-exclusion remains in place for another 6 months unless the customer takes positive action in order to gamble again. After the self-exclusion period expires an individual may only recommence entry into the charities raffles and lotteries after contacting the customer services helpline. There will be a 24 hour cooling off period after contact is made before entry into a raffle or lottery is possible. On request, self-exclusion can be extended for one or more further periods of at least 6 months each. Self-exclusion flags will be added to the database within 2 working days of receipt. A record of card numbers to be excluded will also be kept where this is possible and complies with other legislation. Records relating to self-exclusion will be kept as long as the self-exclusion plus a further 6 months. Staff are trained on self-exclusion and will signpost counselling and support services.

10 All staff involved in the raffle will be informed of any attempts by individuals to breach their self-exclusion. Self-excluded customers will have any accounts closed and funds returned to them. Self-exclusion applies only to the cessation of contact on gambling products and ability to enter the draws, to be removed from other charity mailings contact our Fundraising team on In requesting self-exclusion, individuals must agree to provide full and accurate personal details, now and in the future, so as to ensure we are able to restrict their access to our services. If an individual chooses to self-exclude we will use all reasonable endeavours to ensure we comply with your self-exclusion. However, in agreeing to self-exclude individuals accept that they have a parallel undertaking not to seek to circumvent the self-exclusion. Records will be kept of any person who attempts to breach their self-exclusion and retained for a minimum of twelve months.

11 These policies and procedures are published by Marine Society and Sea Cadets. They are current as at September Marine Society and Sea Cadets 202 Lambeth Road London SW1 1JW T: E: sea-cadets.org ms-sc.org MSSC (Marine Society and Sea Cadets) Registered Charity no (England and Wales), SC (Scotland) and Marine Society and Sea Cadets Ltd registered in England no