In the final SMP Snack, SMP eGaming Senior Regulatory Compliance Officer Tom Collister explains how proper implementation helps raise standards and can benefit us all.
The Gambling Commission has long warned operators to ensure advertising is not falling foul of social responsibility rules or deceiving consumers. As operators are held accountable for failings by affiliates, the successful implementation of an advertising compliance policy provides a level of comfort that will set you apart from your competitors.
Once you’ve created your advertising compliance policy (as reflected upon in last week’s article), you need to use and manage it effectively. Adopting the policy you have designed is not enough in itself, it’s imperative that it’s implemented correctly and that each requirement set out by your associated operators is adhered to.
It’s advisable you make sure your associates understand it and are provided with sufficient training which supports them. Training should ensure the requirements set out by the ASA code and regulators, such as the Gambling Commission, are understood. If your people fully understand what they are applying then you have a firm foundation upon which to build. This is the basis for a strong compliance culture, which operators will appreciate.
Of course, regularly reviewing your policy, at least annually, is critical as it is essential to be up to speed with any changes to legislation or guidance notes, let alone latest industry enforcement action. Affiliates should keep open lines of communication with operators to keep abreast of relevant changes, ensuring successful management of the policy.
You should work closely with operator’s compliance departments to test adherence to the policy, with potential actions for non-adherence. Whether that be through disciplining employees who fail to comply or via general corporate governance improvements is, of course, up to you.
The effectiveness of the policy should also be monitored, in a similar way as you’d monitor the success of a more immediately commercial project. Have you received any feedback from operators? Were there instances in which your procedures successfully identified non-compliant advertising before it was published? What feedback was received from the CAP Copy Advice Service? Collect as much information on your compliance activity as possible to assist with this stage.
You should document all your efforts and keep records that prove of all your compliance activities. A strong documenting system will have you prepared for any inquiry should an operator or regulator come knocking at your door and allow you to demonstrate your compliance to operators to increase your future prospects.
At SMP eGaming, our compliance team has been working closely with affiliates to create and implement advertising policies which operators will value. Through our Compliance Academy, we also provide specific advertising and media and LCCP training to provide a sound understanding of the requirements of UK operators.