Policies
Policies
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
Allwyn Services UK Limited and its subsidiaries Tax Strategy for the year ended 31 March 2023.
This paper sets out the Tax Strategy for Allwyn Services UK Limited and its UK subsidiaries Allwyn UK Holding C Limited, 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 companies.
Our business has a strong focus on corporate responsibility, and we see responsible administration and payment of taxation as a responsibility of our business.
Allwyn Services UK Limited’s overriding Tax Strategy is:
- To fulfil all of its tax reporting and payment obligations as they fall due
- 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.
Approach of Allwyn Services UK Limited’s risk management and governance arrangements in relation to UK taxation:
- Our statutory directors understand the importance of tax compliance, and how it is achieved.
- There is a constant dialogue between those directors and individuals tasked with the operation of our finance function, regarding the way our businesses manage their tax risk.
- 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.
Tax planning:
- We undertake appropriate tax planning as part of our overall business strategy.
- We do not undertake aggressive tax planning, or deploy artificial arrangements to
obtain a tax advantage. - We aim to minimize any tax compliance risk.
- 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.
Attitude towards risk:
- The Board sees compliance with our tax obligations as key to managing our tax risk.
- 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. - Allwyn Services UK Limited is committed to complying with all applicable tax laws.
- Allwyn Services UK Limited has a low appetite for risk in relation to tax matters,
assessing tax risk and making tax decisions with regards to its reputation and
integrity.
Relationship with HM Revenue & Customs (HMRC):
- Allwyn Services UK Limited is committed to developing and fostering good working
relationships with HMRC. - Allwyn Services UK Limited proactively manages this relationship by being open, honest and transparent in all dealings with HMRC.
- Allwyn Services UK Limited seeks to keep HMRC aware of significant changes in the business and seeks to discuss any issues at an early stage.
This updated Tax Strategy was approved by the Board in July 2023.
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 Lottery Solutions (‘Allwayn 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 Allwyn North America. The majority of Allwyn North America’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.
Our suppliers are generally chosen based on the following criteria;
- 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. 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 2022/23
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 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.
