Policies

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Policies

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Responsible Gaming

Our purpose

Our purpose at Allwyn Lottery Solutions is to responsibly engage players, grow lotteries, and benefit communities through increased returns to good causes. We do this through the products and services we build, deploy, and provide to our customers.

Our Commitment

We want people to play the lottery because it is a fun and rewarding experience, and one that gives back to local communities, while also offering the chance to win. We believe that lotteries grow best, and communities benefit most, when players are responsibly engaged. Our suite of data and intelligence-led products and services are designed with player safety at the forefront. We are committed to being the leader in lottery intelligence, which includes using available data to drive best practice responsible gaming and supporting the responsible gaming initiatives of our customers.

Our Ownership

Allwyn LS is wholly owned by Allwyn AG, which has a strong focus on promoting safer play. Allwyn works diligently to prevent player harm and targets the following activities: risk-based design, knowing its digital players, intervening with and educating players, achieving accreditation, and investing time and funding for training and safety-related product development.

Research

We cooperate with our stakeholders on responsible gaming research, including the regular sharing of information. This ensures that our staff have the most up-to-date knowledge of responsible gaming topics and study outcomes, relevant to their areas of expertise.

People

We regularly engage our people to raise awareness of, and provide education about, responsible gaming and social responsibility through a sustained program of events and initiatives, in addition to a robust training module for all staff.

Products and Services

Player safety is the starting point for any product or service we design, build, and deploy. Our products and services operate in some of the strictest regulatory environments in the global lottery ecosystem, and we uphold responsible gaming principles throughout our operations to protect the interests of players and staff alike.

Our gaming studio assesses the risk profile of each of our online instant-win games using the external game evaluation tool ASTERIG. ASTERIG measures the possible dimensions of risk potential of gambling products on the basis of numeric scores. It allows a comparison to be drawn between the risk potential of different gambling products.

The ten dimensions that the ASTERIG framework examines to determine the risk potential of different gambling products are:

  • Event frequency
  • Interval of payback
  • Jackpot size
  • Continuity of playtime
  • Chances of winning a profit
  • Availability
  • Multiple playing/stake opportunities
  • Variable stake amounts
  • Sensory product design
  • Near wins

Remote Gaming Environment

We believe that using data and intelligence will help lotteries deliver greater benefits to their local communities. This belief is driven by the increasing move towards the digital space by lottery operators and, especially, their players.

To ensure we are building products and delivering services that are safe for our customers to deploy to their players, we implement some of the most stringent safeguards to promote responsible lottery gameplay online.

The websites and mobile apps that we build have a number of in-built responsible gaming tools , including age and identity checks, geo-location verification, deposit and wallet limit functionality, session timers, financial and gaming history monitors, in addition to self-exclusion options.

Advertising / Marketing

The advertising, marketing and storytelling primarily undertaken by Allwyn Lottery Solutions is through our owned and earned channels (such as social media or allwyn-lottery-solutions.com), supported by paid print advertisements in lottery industry B2B publications. Our marketing material is designed to appeal to an audience who is likely to already be working in the lottery industry.

We align all of our storytelling activity to the Advertising Standard Authority guidance on Responsibility and Problem Gambling, a copy of which can be found here.

Stakeholder Engagement

Allwyn Lottery Solutions core stakeholders include: employees, customers, the wider lottery industry, suppliers, vendors, and partners. Regular discussions with these key groups helps identify any issues that may be of concern to our stakeholders and of strategic relevance. These issues inform our business strategy, priorities and communications.

Reporting and Data

We align our activity to the UK’s Data Protection Act 2018, the UK and EU’s GDPR legislation to ensure we provide a safe and secure environment for any and all data that we collect and hold.

KPIs and Progress

Our Responsible Gaming KPIs are set and monitored by the risk management working group, which meets formally every quarter and also has a remit to deliver the Allwyn LS responsible gaming engagement programme for all Allwyn LS staff. A critical component of these KPIs is to maintain a >85% completion rate of responsible gaming training across all staff. Allwyn Lottery Solutions is a certified responsible gaming supplier aligned to the World Lottery Association framework, having achieved the standard in June 2020.

Tax Strategy

This paper sets out the Tax Strategy for Allwyn Services UK Ltd and its UK subsidiaries, Allwyn UK Holding C Ltd, Allwyn Lottery Solutions Limited, and Allwyn Technology Services Limited, in accordance with paragraph 19 and 25 of Schedule 19 of the Finance Act 2016. This applies to all taxes applicable to the subgroup for the year ended 31st December 2024.

Allwyn Services UK Ltd’s overriding Tax Strategy

The subgroup’s overriding Tax Strategy is to fulfil all its tax reporting and payment obligations as they fall due. Additionally, to pay the right amount of tax at the right time, and to structure its tax affairs in an effective and efficient manner ensuring all transactions have a commercial rationale.

 

Allwyn Services UK Ltd’s approach to risk management and governance arrangements in relation to UK taxation

  • Day to day responsibility sits with the Tax Department, which is a central part of the Finance function. The Tax Department is a team of experienced and appropriately qualified professionals. All members of the Tax Department seek to operate in line with the Tax Strategy.
  • Tax risk is managed in a manner consistent with the management of other risks. Key tax risks are identified, and appropriate controls and procedures are implemented to mitigate these risks.

 

Attitude towards tax planning

  • The subgroup is a responsible taxpayer.
  • The subgroup aims to minimise any tax compliance risk by seeking to fulfil all its tax reporting obligations by completing all tax returns on their due date and paying the right amount of tax as it falls due.
  • Professional advice is sought on certain transactions, with the extent of such advice being driven by our assessment of the risk presented by each relevant transaction.
  • The subgroup will structure its tax affairs in an efficient manner and all transactions will at their core have a commercial rationale.

 

The level of risk in relation to Taxation that Allwyn Services UK Ltd is prepared to accept

  • The subgroup has a low-risk appetite in relation to tax matters, assessing tax risk and making tax decisions with regards to its reputation and integrity. The subgroup observes all applicable laws, rules, regulations and disclosure requirements.
  • We understand the importance of tax in the wider context of business decisions and have processes in place to ensure tax is addressed appropriately as part of our decision-making process.
  • Where tax law is uncertain or subject to interpretation, the subgroup will obtain specialist tax advice or seek the views of Tax Authorities including HMRC to ensure that the correct treatment is adopted.

 

Relationship with HM Revenue & Customs (“HMRC”)

  • The subgroup is committed to developing and fostering good working relationships with Tax Authorities including HMRC. The subgroup will proactively manage these relationships by being open, honest and transparent in all dealings with the HMRC with the aim of minimising the risk of challenge, dispute or damage to the subgroup’s credibility.
  • The subgroup seeks to keep HMRC aware of significant changes in the business and seeks to discuss any issues at an early stage.

 

This Tax Strategy was approved by the Board

Responsible Disclosure

As a responsible and security conscious company protecting our data and that of our customers is a top priority for Allwyn Lottery Solutions. We are happy to work with security researchers to identify weaknesses in any technology we develop. If you believe you’ve found a security vulnerability in Allwyn LS software or services, please notify us by emailing compliance@allwyn-lotterysolutions.com. We will work with you to resolve the issue promptly. *Please note if you believe you have identified a weakness in a live lottery system please contact that lottery’s operator directly.