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ARGO
1.
ARGO’s Memorandum of Association includes the following objectives:
“3 (e) To encourage high standards of probity and integrity within the betting and gaming industry, both for the benefit of its members and the public generally.
3 (f) To encourage social responsibility within the betting and gaming industry, effected through various means including support for charities and initiatives to help those who have gambling problems.”
2.

3.
The purpose of this code is to help members of ARGO achieve these aims in a consistent manner. It is intended for use in whichever jurisdiction the ARGO member is operating and not just for those parts of the business which are based in Britain. Irrespective of where the customer is located, he or she should be provided with the tools to help them monitor and control their gambling behaviour. Although there are places in the code which relate exclusively to internet gambling it is believed that the underlying principles hold good for all forms of remote gambling. However, ARGO’s position is that, for practical reasons, different delivery channels will in due course need certain provisions tailored exclusively to them. An obvious example of this is that while information about problem gambling may be made available on a betting operator’s website there is no facility to provide that as part of a telephone betting service. This is an area where further work needs to be done in collaboration with experts in the field of problem gambling and with regulators. It must be a code that is flexible and capable of development in line with any emerging best practice.
Compliance with Codes of Conduct
4.
The need to demonstrate that a business is run in a socially responsible manner is an important aspect of regulation. Operators will also have their own rules and procedures designed to protect their businesses, enhance the customer experience and minimise harm to the vulnerable. It is therefore important that:
* All relevant staff are made aware of, and understand, this code of practice; and
* due consideration is given to the code when company policies and procedures are being developed.

Advertising and Promotion
5.
It is appropriate that gambling activities are advertised and that an operator is able to promote the facilities available. Any such advertising and promotion must comply with the laws and regulations of the jurisdiction in which the operator is licensed.

General Principles
* Advertisements should be legal, decent, honest and truthful.
* Advertisements should be prepared with a sense of responsibility to consumers and to society in general.
* Promotional email should only be sent in accordance with relevant regulations and legislation.
* No advertisement should bring the advertising industry into disrepute.
* Advertisements and promotions should be socially responsible.

Betting and Gaming specific
* Care should be taken not to exploit the young, the immature or those who are mentally or socially vulnerable.
* Advertisements should not be directed at people under the age of 18 through the selection of media, style of presentation, content or context in which they appear. ·
* Persons portrayed gambling should not be, nor appear to be, under 18.
* There should be honesty at all times with regard to the chances of winning, and the odds or payout ratio that applies to the gambling on offer. Free play games should operate to the same payout ratio as cash games.
* Operators should always gain permission before carrying any 3rd party logo (eg the Gamcare logo should not be used without its consent) and ensure that logos and links are valid and appropriate.
* Consumers should be offered advice about the gambling facilities on offer. It should not encourage them to re-stake their winnings; increase the amount they have decided to gamble; chase their losses; continue gambling when they have indicated that they wish to stop; or enter into continuous play for a prolonged period of time.

Underage Gambling
6.
Even though it is illegal for anyone under the age of 18 to engage in betting or gaming, it is not always easy to ensure that children are excluded. Operators should adopt reasonable measures to minimise underage gambling, including:
* Clear notices on gambling websites stating the minimum age to use the facilities.
* Investigating, identifying and applying an appropriate age verification procedure (as more sources of information may become available over time, operators should review their procedures regularly to ensure they remain robust and reliable).
* Monitoring which payment methods, for example which debit cards might be or might become available to children.
* Registering with a filtering service that enables parents and other responsible adults to prevent access to gambling sites.
* Having a clear policy and procedure for dealing with underage gambling and ensuring that it is followed.
* As far as is reasonably possible, not making the appearance of the website attractive to children.
* Particular care should be taken with payment methods which are readily available to children (eg certain debit cards). ARGO will continue to liaise closely with The Association for Payment Clearing Services (APACS) to determine which cards are available to children and to encourage the banking sector to play a full part in the prevention of underage gambling.

Staff Training
7.
Training on social responsibility and problem gambling should be available for all customer services and other relevant staff. The aims of such training should be to raise the awareness of these issues for frontline staff who deal with gamblers. They should be fully appreciative of their companies’ policies and able to refer suitable cases to external bodies that are in a position to provide qualified help and counseling. Working with problem gamblers is a specialised skill and it would be wrong and potentially dangerous for staff in the gambling industry to seek to fulfil any part of that role.

Player Protection Measures
8.
In order to prevent and combat problem gambling there are a range of measures that operators can take to help their customers. These include:
* Where available an up-to-date account balance will help customers monitor their spending.
* Their betting history should be available on request.
* The current time, derived from the customer’s computer, will help customers monitor the time spent on the operator’s website.
* A facility to limit the amount deposited so that a customer can specify a daily or weekly amount beyond which further deposits will not be accepted. There should be a delay of at least 24 hours before any request to increase a limit comes into force.
* The provision of a self-exclusion facility for any customers who wish to exclude themselves from gambling on the operator’s website. During the chosen period the customer will also be excluded from all forms of communication from the operator. The chosen period should be for a minimum of 6 months.
* When online a link should be easily accessible which will take the customer to information about the protections available on the site.

Customer Communication
9.
Without compromising the principle that customers are responsible for their own gambling, the nature of the activity is such that information should be made available to empower them to gamble responsibly. Related customer communication should therefore:
* Give clear guidance that in order for gambling to be a fun, social activity, the customer needs to ‘stay in control’.
* Make information available about player protection and responsible gambling.
* Indicate sources of help and how they can be accessed.
* Either provide a self assessment test or a link to one (such as that on the Gamcare website) to help customers gauge whether or not they are developing a problem.
10.
Gambling operators must be able to direct customers to sources of help where they can address concerns about their gambling should they wish to do so. The availability of such assistance can be brought to the attention of customers in the following ways:
* Displaying the logo of, and a link to, appropriate problem gambling organisations on the website’s home page.
* The display of an appropriately worded link to the area of the website where sources of help can be found.
* Providing an area of the website that sets out the operator’s policy, that emphasises the need to keep gambling under control and shows where to seek help should anyone be concerned about their own or someone else’s gambling. There is already some best practice in this area and ARGO members can be put in touch with specialists in this field if they would find that useful.
* By having staff who can supply such information and contacts (see staff training above).

Conclusion
11.
Gambling is a mainstream leisure activity for adults. For the vast majority of customers it is a harmless pursuit, but all socially responsible gambling operators must be mindful of the problems that can develop and, of course, it is never acceptable for a child to be able to take part in any adult gambling activity.
12.
Although no procedures can ever be foolproof, operators should empower their customers to help them ensure that their gambling does not become a problem and that, if they fear it might be, there is information available for them about sources of support and advice.
13.
In addition, ARGO will continue to work with all interested parties so that its members can be kept fully informed of any new practices or procedures that might be useful in combating problem gambling, helping problem gamblers, and preventing children from gambling.