Social Responsibility Policy

THAMES HOSPICE LOTTERIES – SOCIAL RESPONSIBILITY IN GAMBLING POLICY

Author Date - Campaigns Manager

Version No - One

Valid from October 2025

This policy should be read in conjunction with the Thames Hospice suite of Lottery and Raffle Policies

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

• Preventing gambling from being a source of crime and disorder, being associated with crime and disorder, or being used to support crime.

• Ensuring that gambling is conducted in a fair and open way.

• Protecting children and other vulnerable persons from being harmed or exploited by gambling.

This document sets our approach to ensuring we operate any gambling activities in a socially responsible way. Thames Hospice Lottery staff are familiar with this document and read it upon appointment and at least every six months thereafter.

All Fundraising staff are annually briefed on the three licensing objectives of the Gambling Act 2005. This will extend to our contracted lottery provider staff.
For the purposes of this policy, the term lottery covers both raffle and lottery, unless stated otherwise.

See Appendices A & B in our LOTTERY OVERVIEW POLICY (FR-P-0001).

The Hospice is committed to ensuring that the lotteries are 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:

• Preventing gambling from being a source of crime and disorder, being associated with crime and disorder, or being used to support crime.

• Ensuring that gambling is conducted in a fair and open way.

• Protecting children and other vulnerable persons from being harmed or exploited by gambling.

Preventing gambling from being a source of crime and disorder 

Lottery

- When an individual joins a Lottery we will ensure that:
- The individual is aged 18 or over. We will ask the supporter to confirm this at sign up.
- The individual is resident in Great Britain.
- 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 for subscriptions.
- We limit the maximum number of subscription entries into the Lottery to £10 per
person per Draw, Single Entry Chances to £10 per Draw.
- We will record any incidents for future reference.

Thames Hospice requires all staff and volunteers, as well as canvassers who are employed either directly or through an agency to have had the appropriate background checks.

As part of the staff recruitment processes at our canvassing agency(ies) a minimum of two references are required.

All Fundraising staff are annually briefed on the three licensing objectives of the Gambling Commission Objectives. 

This will extend to our contracted Lottery provider staff.

We will only use a random number generator (RNG) which has been provided by an External Lottery Manager and that has been approved by the Gambling Commission.

Raffle

In relation to our raffles, we have a limit of 100 tickets per individual per Draw. We record all tickets that are sent out and returned.

For the raffle we will not send in excess of 60 tickets to an individual without customer interaction.

Ensuring that gambling is conducted in a fair and open way.

Lottery

Our External Lottery Managers keep a record of all tickets that have been distributed.

Extra tickets will not be made available to players until all monies have been received for existing tickets within that draw.

Our External Lottery Managers operates from secure premises, with fire safes in situ, and with contractors such as G4S.

Our External Lottery Managers process all entries and handle monies received for our lotteries, although some monies are paid directly in to the dedicated Thames Hospice’s
Lottery and Raffle bank accounts, and banking reports are issued by our External Lottery Manager on a weekly basis.

Thames Hospice Staff involved in promoting lotteries/ raffles or selling Lottery/ raffle tickets face to face or via telephone will be trained to a satisfactory standard to ensure compliance with Thames Hospice gambling policy and procedure.

Thames Hospice will not enrol any person into any of its Lottery schemes if that person is suspected of any potential or actual criminal activities.

We will ensure that:

- Players have access to clear information on matters such as the rules of the Lottery or raffle, the prizes that are available and how winners are selected.
- The rules are fair.
- Any advertising and promotional material is clear and not misleading.
- The results are made public.
- All Lottery or raffle draws are conducted using a Random Number Generator, all raffle draws are conducted using a blind draw in sight of witnesses.
- A complaints procedure is in place including an independent arbitration service.
- Terms and conditions of the Lottery are published on the website and promotional materials. Rules for raffles are printed on tickets and provided on the website.
- Thames Hospice staff who work directly on the Lottery or raffle and the staff of our Lottery supplier are not eligible to enter the Lottery.

Raffle

All draws are conducted at the External Lottery Manager’s premises in plain sight of staffand ourselves.

Draws are conducted at random using either a random number generator or using a blind draw.

Speed prize draws (e.g. Early Bird and Fast Replies) will be drawn before any ‘main’ prize draw takes place. All speed prize draw entries will then be added to the ‘main’ prize draw.

Thames Hospice will not accept liability for any incomplete, damaged, illegible entries. In such cases monies associated with tickets will be treated as donations to Thames Hospice.

Any ticket payments received after the closing date of the draw will be considered as donations to Thames Hospice and treated as such.

Winning numbers associated with the raffle will be published on the Thames Hospice website. Winning numbers shall also be available by contacting the Thames Hospice
Fundraising Team.

Rules are published on the Thames Hospice website and on the reverse of raffle tickets.

Printed versions of rules are available on request.

Thames Hospice have a complaints procedure in place (please see above).

A record is kept of both online and ticketed sales, as well as tickets not purchased but distributed regardless of whether they are returned or not.

There are no alternatives to any of our raffle prizes, unless otherwise stated in the Terms & Conditions of the relevant draw.

Protecting children and other vulnerable persons from being harmed or exploited by gambling.

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

Underage gambling. It is illegal for individuals under the age of 16 to enter into gambling. The current minimum age for participating in the Thames Hospice prize-led fundraising is 18. We reserve the right to ask for proof of age from any customer and customer accounts may be suspended until satisfactory proof of age is provided. If, for whatever reason, upon winning the Thames Hospice Lottery any individual is unable to prove that they are 18 or over then any winnings will be forfeited and their stake returned.

Gambling limits. Thames Hospice may impose limits on the value of Lottery entries that can be purchased by an individual. The current limit to the maximum number of entries is £10.00 per person per draw for subscription and £10.00 per person per draw for Single Entry Chances.

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 make all reasonable efforts to ensure that the individual does not try to open a new membership.

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

Access to Player History. We will provide any player with a full history of their Lottery membership, including complete payment and winnings history and/or their raffle payment
and win 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 Thames Hospice staff receive awareness training on problem
gambling issues, including affordability and awareness of vulnerability at induction and on an
annual basis.