COMPLAINTS PROCEDURE

The Charity is committed to providing excellent levels of service. We are constantly striving to meet the rising expectations of our members, and we welcome feedback on where our services can be improved or where your expectations have not been met.

Issues of concern to our members can usually be resolved by talking them through with one of our telephonists. A telephone log sheet is completed at the same time of the call, detailing the callers contact details, who took the call, nature of the complaint and how the complaint was resolved. However, we recognise that sometimes this may not be appropriate, or you may feel your concerns have not been properly addressed after talking them through with us.

We actively encourage our members to use our Complaints Procedure so that issues and concerns can be raised with management and addressed appropriately. This publication explains how the Complaints Procedure works, what you need to do and what you can expect. There are two levels – head of department and senior management.

Head of Department Level (1st level)

Desiree Edwards

If we haven’t reasonably met your expectations or you wish to make a complaint relating to services or facilities provided by one of our staff you should write or e-mail in the first instance to the head of department.

In expressing concerns it is helpful to include all relevant details such as nature of complaint, date, people contacted and the other circumstances relating to your complaint. This helps us to quickly and fully understand the nature of your complaint and begin our investigations.

Once we have received your complaint the head of department or one of his/her colleagues will acknowledge receipt of your letter in writing within 48 hours and you can normally expect a full written response within 10 working days of this acknowledgement. Our aim is to resolve the complaint to your complete satisfaction at this level.

Senior Management Level (2nd level)

David Gardiner

If, after receiving our response at the 1st level you feel that your concerns have not been fully addressed you can ask for your complaint to be referred to the Senior Management.

You can normally expect a full written response to your complaint within 10 working days of our acknowledgement of the complaint reaching the 2nd level. It may be necessary for additional information to be sought from an external source. When this is necessary and we feel it may not be possible to respond to your complaint within 10 working days we will contact you again. We will explain our reasons for asking for a time extension and seek your approval.

Arbitration

If a satisfactory resolution can not be reached then the matter can be referred to an alternative dispute resolution (ADR) entity. We use IBAS (Independent Betting Adjudication Service) for this purpose. IBAS are on the Gambling Commission’s approved ADR list. This service is free of charge – www.ibas-uk.com

PO Box 62639LONDONEC39 3AS

Telephone 0207 347 5883Fax 0207 347 5882e-mail adjudication@ibas-uk.co.uk

SOCIAL RESPONSIBILITY POLICY

Introduction

The Charity operates a Society Lottery for the general public in UK and the surrounding area, for the sole purpose of raising funds for the Electrical Industries Charity.

The Society is committed to ensuring that the lottery is operated in a secure, fair and socially responsible way and to endorse responsible gambling amongst its members.

The Gambling Commission regulates gambling in the public interest. The regulatory framework introduced by the Gambling Act 2005 is based on three licensing objectives:

• 1. Preventing gambling from being a source of crime and disorder, being associated with crime and disorder, or being used to support crime.
• 2. Ensuring that gambling is conducted in a fair and open way.
• 3. Protecting children and other vulnerable persons from being harmed or exploited by gambling.

This document sets out the Societies policies and approach to ensuring we approach any gambling activities in a socially responsible way. Lottery staff are familiar with this document and read it upon appointment and every six months thereafter.

When an individual joins the lottery we will ensure that:

• The individual is aged 16 or over.
• We do not suspect money laundering in any way, in line with the Proceeds of Crime Act.
• We also retain the right to cancel any membership should we suspect criminal activity.
• We do not accept cash
• We limit the maximum number of entries to £40 per person per month.
• We will record any incidents for future reference.
• Ensuring that gambling is conducted in a fair and open way

We will ensure that:

• Players have access to clear information on matters such as the rules of the lottery, the prizes that are available and the chances of winning.
• The rules are fair.
• Any advertising and promotional material is clear and not misleading.
• The results are made public.
• A complaints procedure is in place including an independent arbitration service.
• Protecting children and other vulnerable persons from being harmed or exploited by gambling

We will use our best endeavours to address the following issues:

Under age Gambling. It is illegal for individuals under the age of 16 to enter into a lottery. We reserve the right to ask for proof of age from any customer and customer’s’ accounts may be suspended until satisfactory proof of age is provided. If for whatever reason, upon winning any individual is unable to prove that they are 16 or over then any winnings will be forfeited.

Gambling Limits. The Society may impose limits on the value of entries into a lottery that can be purchased by an individual.

Self Exclusion. On request, we will close any player’s lottery membership(s) for a minimum period of six months during which time the membership(s) cannot be reinstated. During this period we will also try to ensure that the individual does not try and open a new membership. 

All attempted breaches of underage gambling and self-exclusions will be recorded.

Access to Player History. We will provide any player with a full history of their lottery membership, including complete payment and winnings history upon request.

Provide Information on Gambling Support Organisations. We will provide contact details or links on any lottery websites or via other appropriate media to Gamble Aware and other relevant / appropriate organisations. We also provide financial support to the Responsible Gambling Trust, which raises funds to support research, education and treatment of problem gambling.

Self Help and Awareness Information. We will provide self help and awareness information on any lottery websites or other appropriate media together with links to or contact details of Gamble Aware and other relevant / appropriate organisations.

Staff Training. All relevant staff receive awareness training on problem gambling issues.Our commitment to our potential and existing members means we actively encourage responsible gambling and in this regard abide by the following statement:-

RESPONSIBLE GAMBLING

Whilst the majority of people do gamble within their means, for some gambling can become a problem. It may help you to keep control to remember the following:

• Gambling should be entertaining and not seen as a way of making money
• Avoid chasing losses
• Only gamble what you can afford to lose
• Keep track of the time and amount you spend gambling
• If you want to have a break from gambling you can use our self-exclusion option by emailing us at fundraising@electricalcharity.org with your name, address and membership number(s). We will then close your membership(s) for a minimum period of 6 months, during which time it will not be possible for the account(s) to be re- opened for any reason.
• If you need to talk to someone about problem gambling then contact Gamble Aware.
• Gamble Aware is a registered charity that provides confidential telephone support and counselling to anyone who is affected by problem gambling. Gamble Aware can be contacted on 0808 8020 133 (Freephone).

Problem Gambling. If you are concerned that gambling may have taken over your (or someone else’s life) then the following questions may help you find out:

• Do you stay away from work, college or school to gamble?
• Do you gamble to escape from a boring or unhappy life?
• When gambling and you run out of money, do you feel lost and in despair and need to gamble again as soon as possible?
• Do you gamble until your last penny is gone, even the fare home or the cost of a cup of tea?
• Have you ever lied to cover up the amount of money or time you have spent gambling?
• Have others ever criticised your gambling?
• Have you lost interest in your family, friends or hobbies?
• After losing, do you feel you must try and win back your losses as soon as possible?
• Do arguments, frustrations or disappointments make you want to gamble?
• Do you feel depressed or even suicidal because of your gambling?

The more you answer ‘yes’ to these questions, the more likely you are to have a serious gambling problem. To speak to someone about this contact the Gamble Aware confidential helpline on 0808 8020 133 or visit their website www.begambleaware.org for further information.

SELF EXCLUSION POLICY

The Charity complies with the Licence Conditions and Code of Practice governing the procedures for self-exclusion. We will take all reasonable steps to prevent an individual who has entered a self-exclusion agreement with ourselves from participating in our lottery.

Should a member of our staff receive correspondence from an individual who wishes to be self-excluded they will send out a Lottery Exclusion form to be completed and returned. Upon the return of the form the individuals details will be entered onto the self exclusion register. This will then be cross referenced against the existing membership and any new members signed up for the lottery for the period of the exclusion.

We will not target the individual with marketing material at any time during the self-exclusion. We will take steps to remove the name and details of a self-excluded individual from any marketing databases used by ourselves.

We will close any membership of an individual who has entered a self-exclusion agreement and return any funds held in their name.

We have put into effect the following procedures to ensure that an individual who has self-excluded cannot gain access to the lottery.

A register of those excluded with appropriate records (name, address, lottery number, and any other appropriate comments).

• Staff training to ensure that staff are able to recognise and enforce the system.
• An individual must take positive action in order to self-exclude by way of a signature.
• The self-exclusion period is a minimum of six months (giving members the option of extending this if they so wish)
• The self-excluded member must take positive action to be removed from the self-exclusion and be able to enter the lottery at a future date.
• Upon notification the player will be given a one day cooling off period before being allowed access to the lottery.
• The record of the self-exclusion will remain on file until the agreement has been formally ended.

KEY EVENTS POLICY

A key event is an event that could have a significant impact on the nature or structure of a licensee’s business. Licensees must notify the Commission, or ensure the Commission is notified, in such form or manner as the Commission may from time to time specify, of the occurrence of any of the following key events as soon as reasonably practicable and in any event within five working days of the licensee becoming aware of the event’s occurrence.

Operator status

1. In the case of licensees which are companies, a petition being presented for their winding up or the winding up of any group company of theirs, or they or any group company being placed in administration or receivership or their directors proposing to creditors a composition in satisfaction of its debts or a scheme of arrangement of its affairs.

2. In the case of licensees which are bodies corporate, but not companies, any event substantially equivalent to those listed at 1 above.

3. In the case of a licensee who is an individual (or a partner in a partnership licensee) their being presented with a petition for their bankruptcy or sequestration or their entering into an individual voluntary arrangement.

Relevant persons and positions

4. In the case of licensees who are companies or other bodies corporate having a share capital, the name and address of any person who (whether or not already a shareholder or member) becomes a shareholder or member holding 3% or more of the issued share capital of the licensee or its holding company.

5. Any investment in a licensee which is not by way of subscription for shares.

6. The taking of any loan by the licensee, or by a group company who then makes an equivalent loan to the licensee, from any person not authorised by the Financial Conduct Authority: a copy of the loan agreement must be supplied.

7. The entering into an arrangement whereby a third party provides services to, or grants any licence concession or permission to, the licensee other than for full value: full details of the arrangements must be supplied.

8. The appointment of a person to, or a person ceasing to occupy, a ‘key position’: a ‘key position’ in relation to a licensee is:

• a) in the case of a small-scale operator, a ‘qualifying position’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006
• b) in the case of an operator which is not a small-scale operator, a ‘specified management office’ as set out in (current) LCCP licence condition1.2
• c) a position the holder of which is responsible for the licensee’s anti-money laundering procedures, including suspicious activity reporting
• d) any other position for the time being designated by the Commission as a ‘key position’. (Notification is required whether or not the person concerned is required to hold a personal management licence and whether or not the event notified requires the licensee to apply for a variation to amend a detail of their licence.)

9. Any change to the structure or organisation of the licensee’s business which affects a ‘key position’ or the responsibilities of its holder.

Financial events

10. Any material change in the licensee’s banking arrangements, in particular the termination of such arrangements or a particular facility and whether by the licensee or the provider of the arrangements.

11. Any breach of a covenant given to a bank or other lender.

12. Any default by the licensee or, where the licensee is a body corporate, by a group company in making repayment of the whole or any part of a loan on its due date.

13. Any court judgments (in whatever jurisdiction) against the licensee or, where the licensee is a body corporate, a group company, remaining unpaid 14 days after the date of judgment.

14. Where the licensee is required to have their accounts independently audited, any qualification to an auditors’ report; and any unplanned change of auditor including a change prompted by a dispute or resulting from auditors being unable or unwilling to sign an unqualified audit report.

15. Any change in the licensee’s arrangements for the protection of customer funds in accordance with the general licence condition 4 relating to the protection of customer funds (where applicable).

16. Where the licensee holds customer funds in a separate bank account, any deficit on reconciliation of such bank account.

Legal or regulatory proceedings or reports

17. The grant, withdrawal or refusal of any application for a licence or other permission made by the licensee, or in the case of a licensee which is a body corporate, any group company of theirs, to a gambling regulator in another jurisdiction. In the case of a withdrawal or refusal of the application, the licensee must also notify the reasons for such withdrawal or refusal. (This condition does not apply to applications for licences or other permissions to carry on activities which would fall outside the scope of a Gambling Commission operating licence if carried out in Britain or with customers in Great Britain.)

18. Any investigation by a professional, statutory, regulatory or government body (in whatever jurisdiction) into the licensee’s activities, or the activities in relation to the licensed entity of a personal licence holder or a person occupying a qualifying position employed by them, where such an investigation could result in the imposition of a sanction or penalty which, if imposed, could reasonably be expected to raise doubts about the licensee’s continued suitability to hold a Gambling Commission licence.

19. The receipt of any report from a professional, statutory or other regulatory or government body (in whatever jurisdiction) of the outcome of a compliance assessment in relation to the gambling activity of the licensee or, where the licensee is a body corporate, of any group company in which at least one person who holds a key position in or in respect of the licensee holds a key position: a copy of the report should be provided where available to the licensee.

20. The referral to the licensee’s Board, or persons performing the function of an audit or risk committee, of material concerns raised by a third party (such as an auditor) about the provision of facilities for gambling which are expressed (in whatever terms) as requiring attention as a high priority: a summary of the nature of the concerns must be provided.

21. The imposition by the licensee of a disciplinary sanction, including dismissal, against the holder of a personal licence or a person occupying a qualifying position for gross misconduct; or the resignation of a personal licence holder or person occupying a qualifying position following commencement of disciplinary proceedings in respect of gross misconduct against that person.

22. The commencement (in whatever jurisdiction) of any material litigation against the licensee or, where the licensee is a body corporate, a group company: the licensee must also notify the outcome of such litigation.

23. The making of a disclosure pursuant to section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (a suspicious activity report): the licensee should inform the Commission of the unique reference number issued by the United Kingdom Financial Intelligence Unit of the National Crime Agency in respect of each disclosure and for the purposes of this key event the five working day period referred to above runs from the licensee’s receipt of the unique reference number.Gambling facilities

24. Any breach in the licensee’s information security that adversely affects the confidentiality of customer data or prevents customers from accessing their accounts for longer than 24 hours.

25. Any change in the identity of the ADR entity or entities for the handling of customer disputes, as required by the social responsibility code provision on complaints and disputes.

26. The reference of a dispute to an ADR entity other than one in respect of which contact details were given in accordance with the social responsibility code provision on complaints and disputes; the reason for selection of that ADR entity should be given.

27. In the case of remote gambling, the commencement or cessation of trading on website domains (including mobile sites or mobile device applications) or broadcast media through which the licensee provides gambling facilities.

In this condition:

‘body corporate’ has the meaning ascribed to that term by section 1173 of the Companies Act 2006 or any statutory modification or re-enactment thereof

• a) in respect of a company, ‘holding company’ and ‘subsidiary’ have the meaning ascribed to that term by section 1159 of the Companies Act 2006 or any statutory modification or re-enactment thereof
• b) a ‘group company’ is any subsidiary or holding company of the licensee and any subsidiary of such holding company.

The Charity agrees to abide by these terms and report any key event it becomes aware of to the Gambling Commission within 5 working days.