March 2, 2016

The new CEO of the Commission, Sarah Harrison, has said that social responsibility and transparency in advertising will be amongst the Commission’s priorities. Now that the glut of ‘point-of-consumption’ licence grants has been dealt with, the Commission is at liberty to turn its attention to monitoring and enforcement. Numerous operators have received requests to submit their written policies to the Commission with a follow-up telephone interview and critique. Part of demonstrating compliance will be to show the Commission that a licensee has not only noticed and digested the recommendations coming out of the Commission’s investigations of third parties, but has actually translated that into compliant practice on the ground. The Public Statement about Paddy acknowledges that they had policies and procedures in place (albeit apparently not ‘fully in line’ with regulation) and had delivered training, but problems seem to have arisen with how it all actually worked: when a ‘senior staff member’ felt it appropriate to encourage a problem gambler to attend a betting shop more, rather than less, then whatever Paddy’s good intentions may have been at a corporate level, the whole organisation found itself ‘grossly at odds with the licensing objectives’ in the words of the Commission.

So the message is not just to ensure that the compliance and compliance policies and structures are in place, but that the people who implement and observe them on a day-to-day practical basis actually understand and follow them, and that the business has at least a sporting chance of picking it up when this fails to happen.