Bill Galston Managing Partner Galston Associates Managing Director Gambling Governance Ltd
Corporate Compliance Structures and Responsibilities An effective compliance structure must be implemented to ensure that the Company’s policies and procedures to meet Licence Conditions and the Commission’s Code of Practice are being fully complied with. A FORMALLY AGREED ACTION PLAN MUST BE PREPARED TO DEAL WITH BREACHES REPORTED OR DETECTED BY OPERATIONAL STAFF OR THE COMPLIANCE TEAM
Licence Conditions relevant to the particular activity Part 2 - Commissions conditions Part 3 - Statutory conditions Part 4 - Commission’s general conditions Part 5 – Secretary of State general conditions
Gambling Commission’s Code of Practice (Casinos) Financial requirements Protection of children and other vulnerable persons ‘Fair and open’ provions Marketing Complaints and disputes Gambling licensees’ staff Access to casino premises for children and young persons
The Compliance Officer - Appointment Experience PML holder Role and function defined Dedicated function Unfettered access to all areas Reporting line to CEO/Compliance Committee/Director Direct access to Chairman/CEO Non interference by operational management
Compliance Officer - Duties Audit and test company policies and procedures to ensure compliance Discuss with Operational Management Compliance Report findings and agree action points Report to CEO/Compliance Committee Provide advice to operational management and staff Maintain liaison with Gambling Commission Compliance Manager
The Compliance Committee – Membership Independent Chairman Non-Executive Directors CEO Finance Director In attendance: Compliance Director, Compliance Officer, others by invitation
Meetings Quarterly Action/non action fully recorded Minutes approved and circulated
Scope of Reviews Compliance Audits Changes in PML position holders Financial robustness Key events Regulatory returns Due diligence reports Security and Surveillance Health and Safety Foreign Gaming