Virtual Corporation Limited (“VCL”) is committed to assisting in the prevention of gambling from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime.
In order to maintain the integrity of the business and assist the Gambling Commission in fulfilling this objective under the Gambling Act 2005, VCL has drawn up the following policies and procedures which will be strictly adhered to. This is not an exhaustive list and will be reviewed at regular intervals.
• VCL will conduct its’ business in accordance with UK legislation and the authoritative guidelines produced by the Gambling Commission with integrity, due care, skill and diligence.
• All frontline staff will be trained on induction with an overview of current gambling legislation and licence conditions and codes of practice.
• VCL will work closely with the Gambling Commission and other industry bodies in order to develop best practice and to share information that may help with the delivery of this key objective.
(ii) Money Laundering
• All Frontline staff will be trained and instructed twice yearly on the Code of Practice relating to the prevention of and detection of money laundering as issued through the Gambling Commission.
• Where relevant, all staff will be trained to be made aware of what may constitute a suspicious transaction that would prompt a Suspicious Activity Report (“SAR”).
• A designated Money Laundering Reporting Officer (“MLRO”) will take responsibility for SAR’s made to the Serious Organised Crime Agency (“SOCA”) in respect of the prevention and detection of money laundering, counter-terrorism financing, and fulfil VCL’s obligations under the Proceeds of Crime Act 2002.
• All SAR’s will be forwarded to the MLRO who will always report any transaction to SOCA unless instructed by them not to do so.
• The MLRO will decide on ‘suspicion based reports’ as to whether a SAR to SOCA is required.
• Should the Gambling Commission, SOCA or any relevant recognised body alter or amend the codes of practice, then VCL will adopt the new policies with immediate effect.
(iii) On Line Security
VCL understands the importance of information security and the techniques needed to secure information to prevent online fraud. The following measures will be put in place immediately:
• All personal information which is received directly from customers will be stored in a password protected database and will be fully protected by Thawyte Encrypted Security Certificates. Fully encrypted payment gateways will be used to prevent fraud.
• Protected databases will reside within VCL’s secure network behind active state of the art firewall software.
• VCL will take steps to ensure its subsidiaries, agents, affiliates and suppliers also employ adequate levels of online security to ensure customer data protection.
• VCL will have a stringent identity verification process to assist in money laundering prevention and fraudulent use of the website. Immediate checks will be made against all new customers, checking the age of the players, their email validity and home address.
• Secure credit card payments will be insured by using a leading transaction provider to process online payment transactions.
The ‘Football Buster’ website is based on a very simple and straightforward concept. It is easy to understand with limited possibility to be misleading to a consumer.
Nevertheless VCL is committed to high standards of customer service and to giving its customers all the information which they require in order to make a considered decision in relation to their gambling.
The following measures will be taken to ensure compliance with this key objective:
• VCL will make available to its customers on each page of its website a full set of rules to the game ‘Football Buster’ together with details of the regulatory body to which we are subject and the full terms and conditions upon which our gambling services are offered.
• VCL will provide customers with easily accessible information about their account balances online.
• The website will provide full descriptions of the way the game works and the likelihood of winning to ensure that customers are not unfairly disadvantaged.
• VCL will continue to work with third party suppliers with the objective of ensuring that it operates in compliance with the high standard of online technical requirements.
• VCL will publish a clear and transparent complaints procedure, which will be available to all customers. Complaints will be dealt with efficiently and customers will be helped to resolve any issues they may have.
• VCL will continue to cooperate fully with the Gambling Commission. All employees will be trained and be aware of the rights of the Gambling Commission’s enforcement officers and to cooperate with them at all times.
• Any advertising and promotional material will be clear and transparent and not at all misleading.
• Considerable time and effort has been put into the conception of the website. The rules of ‘Football Buster’ are fair.
Protection & Exclusion
VCL intends to provide a responsible gaming environment. Whilst it is VCL’s intention for all of its customers to bet with responsibility and within their means, we acknowledge that gambling can create problems for some people.
As a service provider we further acknowledge our responsibility to the service user to ensure that such problems are not realised.
To this end, we will put in place the following measures to protect children and other people who are vulnerable to gambling:
(i) Protection of Children
• It is against the law for those under the age of 18 to gamble. VCL will have several security systems in place to make checks against the age of customers who register on the website in accordance with our terms and conditions of business.
• Upon registration customers will also be required to acknowledge that they are over 18 by checking a box. This confirms that we do not accept registration from any customer under the age of 18.
• VCL will place symbols throughout the website indicating that gambling on the site is only permitted to those aged 18 or over and that we reserve the right to ask for proof of age from the customer at any time.
• Customer’s accounts may be suspended until satisfactory proof of age is provided when requested.
• In the event of actual or potential underage gambling, no winnings will be paid to the customer and their stakes will be returned. The police will be informed accordingly.
(II) Protection of Vulnerable People
• Whilst it is difficult to compile a fully comprehensive list of indicators of a gambling problem, staff at VCL will be trained to identify a number of characteristics which are widely accepted as being such indicators and which will be recognisable from the VCL’s databases. Once indicators are recognised, intervention will take place whenever it is deemed necessary.
• Facilities will be provided for customers to ‘self exclude’ themselves from gambling should they, or VCL, believe that they are no longer in control of their gambling. On request, we will close any customer’s account for a minimum period of six months during which time their membership cannot be reinstated. During this period we will also try to ensure that the individual does not try and re-open his/her account.
• VCL will provide the facility for customers to limit the levels of gambling which they wish to undertake by the placing of ‘deposit limits’. This can be done on registration and throughout the customer’s membership. Deposit limits cannot be changed without the completion of a period of notice.
• VCL will provide information on gambling support organisations. We will provide contact details and links to the following organisations:
o Gamcare – www.gamcare.org.uk
o Gambling Therapy – www.gamblingtherapy.org
o Gamblers Anonymous – www.gamblersannonymous.org
• In addition to the above, we will also provide self help and awareness information on our website in the form of a mini questionnaire.
Marketing and Advertising Policy
Virtual Corporation Limited (“VCL”) is committed to the complete compliance of all of its advertising and marketing activities with the provisions of the LLP. Having duly considered such provisions, VCL has drawn up this policy which it will adhere to. This policy will be reviewed at regular intervals.
In conducting its marketing and promotion activities, VCL will ensure that it does not mislead or misrepresent products or target potential vulnerable customers.
VCL will ensure that its advertising and promotion is not misleading about outcomes of gambling or at any point misrepresent the odds of winning or losing.
VCL will ensure that its advertising does not target or depict people with gambling problems.
VCL will clearly articulate its commitment not to mislead or target people with gambling problems or minors.
VCL will ensure that all advertising and promotion is reviewed by one of its directors to ensure adherence to this policy.
Regulatory Enforcement Policy
VCL is committed to ensure that at all time it is fully compliant with its legal and regulatory requirements in respect of its holding of an operating licence.
In order to ensure such compliance:-
The directors of VCL shall ensure that they keep abreast of the relevant legal and regulatory requirements and shall ensure that appropriate policies as to the management and actions of VCL are formalised (and adhered to) from time to time.
VCL shall ensure that all of its policies from time to time are explained at length to its employees, together with any other codes of practice, self-exclusion procedures and other relevant regulations.
VCL shall ensure that its employees are trained in the above in their induction and retrained regularly.
VCL shall introduce a formal evaluation process in regard of such training.
VCL shall ensure that its staff are taught about the problem gambling and its impact on individuals and on society.