Policies
Our purpose
Allwyn Lottery Solutions exists to responsibly engage players, grow lotteries, and benefit communities through increased returns to good causes.
Responsible Gaming
Responsible Gaming Principles
Allwyn Lottery Solutions believes lotteries grow best, and communities benefit most, when players are responsibly engaged. Player safety and wellbeing are central to all decisions, supported by data-driven insight, strong governance, and continuous improvement.
Governance and Ownership
Allwyn Lottery Solutions is part of the Allwyn Group. Allwyn AG maintains a strong focus on responsible gaming and sustainable value creation, having increased returns to good causes across its portfolio since 2015.
Responsible gaming governance at Allwyn Lottery Solutions is overseen by the Risk Management Working Group, with quarterly reporting to senior management and the Board. This framework aligns with WLA Responsible Gaming Level 4 expectations and ISO-aligned management systems.
People and Training
Allwyn Lottery Solutions ensures all employees understand their responsibilities in relation to Responsible Gaming. Mandatory training is completed as part of onboarding and refreshed annually. Engagement is supported through learning hubs, webinars, internal communications, and quarterly working group initiatives.
A minimum training completion rate of 85% is maintained, with a strategic objective to achieve 90% plus completion.
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.
Product and Service Design
Player safety is the starting point for every product and service.
All online instant-win games undergo structured risk assessment using the external ASTERIG evaluation tool, measuring ten behavioural risk dimensions including event frequency, continuity of play, jackpot size, and sensory design. All games are reviewed by Product, Risk, and Compliance teams prior to release.
Allwyn Lottery Solutions applies Responsible Game Design Principles aligned with the Betting and Gaming Council Game Design Code of Conduct, prohibiting misleading mechanics and ensuring transparency of outcomes.
Remote Gaming Environment
Allwyn Lottery Solutions supports customers in delivering safe digital lottery experiences by embedding responsible gaming controls, including:
- Age and identity verification
- Geo-location controls
- Deposit, spend, and session limits
- Reality checks and play reminders
- Game and financial history reporting
- Self-exclusion and account controls
- Instant Win Games are designed without autoplay or turbo play functionality, including defined minimum game times supported by wager, prize and payout configurations that wholly comply with applicable Responsible Gaming and player protection requirements, per jurisdiction.
Advertising and Marketing
Allwyn Lottery Solutions is a B2B organisation and does not market directly to players. All marketing and communications are targeted at professional lottery audiences and align with Responsible Gaming, Corporate Social Responsibility, and Advertising Standards Authority guidance.
Stakeholder Engagement
Allwyn Lottery Solutions engages regularly with employees, customers, regulators, suppliers, and industry bodies to gather feedback, share insights, and identify improvement opportunities. Engagement outcomes inform strategy, policy updates, and continuous improvement activities.
Reporting, KPIs, and Continuous Improvement
Allwyn Lottery Solutions monitors Responsible Gaming performance through defined KPIs and annual objectives, with delivery tracked across multiple teams and reported via central governance and performance management tools (including Culture Amp).
Core KPIs
- Zero RG-related compliance breaches
- Zero regulator-mandated game removals
- 100% of games risk-assessed using ASTERIG
- ≥85% RG training completion rate
- Zero substantiated RG-related marketing complaints
Assurance and Certification
Allwyn Lottery Solutions is a certified Responsible Gaming supplier aligned with the World Lottery Association framework. Recertification occurs every three years, with ongoing internal reviews to maintain readiness and compliance.
Tax Strategy
Premier Lotteries Investments UK Limited and its subsidiaries Tax Strategy for the year ended 31 March 2022.
This paper sets out the Tax Strategy for Premier Lotteries Investments UK Ltd and its subsidiaries (‘Group’) in accordance with paragraphs 19 and 25 of Schedule 19 of the Finance Act 2016. This applies to all taxes applicable to the Group. Allwyn Global Lottery Solutions Limited is a subsidiary of Premier Lotteries Investments UK Ltd.
Group’s Tax Strategy
The Group’s overriding Tax Strategy is to fulfil all of its tax reporting and payment obligations as they fall due. Additionally it has a responsibility towards its shareholders to seek to structure its tax affairs efficiently. Approach of the Group to risk management and governance arrangements in relation to taxation Responsibility for the Tax Strategy, its governance and risk management sits with the Chief Financial Officer. 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.
The Group’s attitude towards tax planning
The Group is a responsible taxpayer. The Group seeks to fulfil all of its tax reporting obligations by completing all tax returns on their due date and paying the right amount of tax as it falls due. The Group 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 the Group is prepared to accept The Group has a low risk appetite in relation to tax matters and observes all applicable laws, rules, regulations and disclosure requirements. Where tax law is uncertain or subject to interpretation, the Group will obtain specialist tax advice or seek the views of Tax Authorities including HMRC to ensure that the correct treatment is adopted. The Group’s approach towards dealing with Tax Authorities including HMRC. The Group is committed to developing and fostering good working relationships with Tax Authorities including HMRC. The Group will proactively manage these relationships by being open, honest and transparent in all dealings with the Tax Authorities with the aim of minimising the risk of challenge, dispute or damage to the Group’s credibility. The Group seeks to keep Tax Authorities including 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.
Anti-Slavery and Human Trafficking Policy
Introduction
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the anti-slavery and human trafficking statement of Allwyn Global Lottery Solutions Limited (Allwyn LS’) for the financial year ending 31 March 2022. It outlines the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains and sets out our commitments for the next year to combat slavery and human trafficking risk in our business and supply chain. Allwyn LS is the leading solutions and technology provider to lotteries around the world, helping its customers to reach new players and deliver responsible growth through increasing engagement with the lottery brand, leveraging digital technology and providing new ways to play. Via its subsidiary, Allwyn North America it is also the private manager of the Illinois State Lottery under a contract running until October 2027. As a responsible business, Allwyn LS has a zero-tolerance approach to all types of slavery and human trafficking within its business and supply chains.
Our Supply Chains
In 2021/22, Allwyn LS worked with around 400 suppliers, around 185 of which were suppliers to CILL. The majority of CILL’s supplier spend relates to IT and marketing and the majority of the rest of Allwyn LS’ supplier spend relates to specialist technology providers. Suppliers are managed by Relationship Managers with support from Finance, Legal, HR and other colleagues as required.
Quality, completeness and scalability of the service
Management systems, processes and flexibility
Relevant service experience and track record
Diversity, sustainability, environmental and social considerations
Risk transfer and management
Cost and value for money
On-going Supply Chain Due Diligence
Allwyn LS undertakes appropriate due diligence in respect of its supply chains. We do so when engaging with new suppliers, reviewing existing suppliers through periodic review meetings, annual supplier surveys and audits to ensure that our standards are being implemented, and to ensure that relevant legislation and regulations are complied with. To determine the current level of compliance and provide ongoing assurance, Allwyn LS has defined an internal audit/assurance schedule to review key controls, this will help to minimise or prevent quality or performance issues, manage compliance and assess current risk posture.
Allwyn LS has categorised suppliers into High, Medium and Low risk levels;
High – Annual review
Medium – once every three years or at the contract renewal
Low – Contract renewal
During FY 2021/22, Allwyn LS followed the above approach and completed the relevant reviews of our suppliers. As an outcome, we haven’t been made aware of any Modern Slavery activities within the supply chain. Allwyn LS has a zero-tolerance approach.
Our Policy Documents
Whistleblowing policy
We encourage Allwyn LS staff to report any concerns where the interests of others may be at risk. This forms part of our Whistleblowing Policy, which encourages Allwyn LS’ staff and suppliers to assist Allwyn LS in tackling any fraud, corruption, unlawful conduct or other malpractice (specifically including failure to comply with The Modern Slavery Act 2015) which may occur within either our organisation or that of our suppliers. Part of Allwyn LS’ strategy is to provide a way for concerns about malpractice to be raised in confidence. We comply with The Public Interest Disclosure Act 1998 (PIDA) and the guidance it provides for dealing with whistleblowing issues in a safe and constructive way. We will continue to communicate with our employees and suppliers on an ongoing basis to raise awareness of the Modern Slavery Act and Allwyn’s commitments.
Code of Conduct
The purpose of our Code of Conduct is to affirm our strong dedication to the highest standards of business conduct. It applies to all Allwyn LS staff and it details the actions and behaviour expected (i.e. acceptable and unacceptable behaviours) when representing Allwyn LS. This also links to our Whistleblowing policy.
Training and Awareness
It is important that all relevant staff are appropriately trained and kept up-to-date regarding the risks of modern slavery in our business and supply chains and that, where necessary, staff are given additional training. Allwyn LS documents and communicates via an e-learning Platform for mandatory training modules and policy documents to uphold integrity and ethical values. During FY 2021/22, we rolled out a new version of the mandatory online Modern Slavery Awareness training module that covers topics such as best practice and the appropriate actions needed to monitor and prevent any instances of modern slavery or human trafficking in our supply chain and business. All employees are required to complete and pass this module. Alongside this, all employees will be required to read and sign our Modern Slavery and Human Trafficking Statement. We will continue to review all training, making necessary updates where required and ensure it is fit for purpose. We will also continue to clearly communicate our commitments via our website.
Focus for 2025/26
Training and awareness remain a key focus area. We will continue to enhance compliance training to manage the risk of modern slavery. All staff will be required to complete the updated mandatory online training on the Modern Slavery Act. The training will continue to cover best practice and ensure that employees understand the appropriate action needed to monitor, report and prevent any instances of modern slavery or human trafficking risk. Also during 2022/23, we plan to again carry out reviews of selected suppliers based on the assessed High, Medium, Low risk scoring.
Ongoing Commitment
As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in any of our entities and to safeguard employees from any abuse or coercion. We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour. An update on progress in the section will be included in our statement in respect of the year ending 31 March 2023. This statement has been approved by our Board, which will review activities and update this statement as necessary on an annual basis.
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 infosec@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.
