As we have previously reported, in 2015 the Gambling Commission introduced an Annual Assurance Statement (AAS) pilot process to obtain assurance from gambling operators (restricted to those with a gross yield from gambling of over £25 million per annum) that they “actively embed the objectives of the Gambling Act 2005 and the Licence Conditions and Codes of Practice (LCCP) into their business processes”.
This process requires operators to submit estimates of the proportion of their revenue from problem gamblers or those gamblers deemed “at risk”. When reporting on the template for the second AAS last year, we set out in its entirety the Commission’s answer to its following self-posed question: “What do we mean by ‘at risk’ and ‘problem’ gambling (AR/PG)?”.
Now in the final year of a three-year pilot AAS scheme, the Commission has published its template for the third AAS. That template is accessible on the Commission’s website, but can also be downloaded below. The timescales applicable to this third AAS are as follows:
- 14 December 2018 – Deadline for 2018 AAS submission
- December 2018/January 2019 – Commission to review and analyse all AAS submissions
- January 2019/February 2019 – one-to-one feedback call with licensees on their AAS submission
- February 2019/March 2019 – AAS evaluation interviews
- April 2019 – AAS workshops
- Spring 2019 – announcement about the future of the AAS process
The Commission comments as follows on its website in relation to this latest template:
What are assurance statements for?
Assurance statements are designed to improve the focus on, and accountability for, the delivery of the licensing objectives by the boards, or equivalent senior leadership structures, of large gambling businesses.
The statements are intended to be a relatively concise self-assessment of the risks to the licensing objectives posed by the business, how well you are managing those risks, where you need to improve and how you intend to do so.
While we will hold you to account for what you say in your statements, the main beneficiary of the statement is you, the operator.
Assurance statements provide a means for your board to provide constructive challenge within the business on the effectiveness of your governance and risk management arrangements in facilitating positive consumer protection, addressing gambling-related harm and crime prevention measures.
Good governance and risk management is the foundation of high performing organisations.
Actively manage your risk
We want you to embrace the challenges of the regulatory landscape by actively and effectively managing your risks and issues and to inform key business decisions. In turn, we are committed to a proportionate and risk-based regulatory regime.
If you hold the licensing objectives at the heart of your decision-making, supported by good governance, risk management and a high level of compliance at all levels, and do this in an open and cooperative manner, your business is less likely to present a risk.
If this approach is successful, as we believe it will be, and over time more and more operators incorporate the licensing objectives into their corporate culture, the need for external regulatory scrutiny may well diminish.
The precise governance arrangements of organisations will vary depending on the size, nature and complexity of your operations or on the gambling services you provide. We will take this into account when we receive and review your assurance statements.
Although completion of an AAS is not yet a requirement for all operating licence-holders, we would recommend that all operators licensed by the Gambling Commission (both B2C and B2B) acquaint themselves with the questions posed in the AAS because, in practice, the Commission’s above principles do apply to all operators. As stated on the AAS form itself, answering the questions posed should:
- provide the most senior level assurance that compliance with all of the licensing objectives is at the core of your business,
- cover control systems, risk assessment and risk management, governance, evaluation and culture and
- help you to achieve greater effectiveness in relation to the licensing objectives by enabling you to consider risks, how those risks are managed and how progress is evaluated.