Beyond the baseline

Peter, what convinced you that Elite Competitions – and the prize competition sector more broadly – was the right next challenge after bet365?

Elite Competitions is a really impressive business. They’ve got great people, a positive culture, and you can tell they’ve got a genuine desire to do the right thing. They want to grow, but in a responsible manner, so it’s somewhere that I would be proud to work for.

I think with the sector as it is now, it’s exciting to be part of that. There’s obviously the new voluntary code of good conduct that’s come in, but it’s a young industry and it’s growing very, very quickly. There’s a lot to do, and there will be a lot to do moving forwards as well, and that keeps it exciting. During my time at bet365 I learned a lot, and I’m grateful to them for that. I’m hoping I can bring some of that good practice and some of what I’ve learned into the prize competition sector and certainly into Elite Competitions.

From your first few weeks in the role, what are the biggest differences between compliance in the regulated gambling industry and compliance within prize competitions?

There are a few things. It’s early days, of course, but the wider gambling industry has a much broader scope of offerings than what you’ll find today in the prize competition sector.

The regulations there have been enforced for years, so they’re much more mature and established. Elite Competitions is far more focused in its product offering, but it’s a much less mature market. It’s still learning and finding its way. The regulations are new and there’s almost a catch-up exercise going on.

The regulatory starting point is different as well because prize competitions sit outside of the Gambling Act because of the free entry route. Regardless of that, the basic principles are always the same with compliance: having clear governance, having robust processes and, most importantly of all, protecting our customers.

The Voluntary Code introduced by the DCMS in May is an important milestone for the sector. Does it go far enough, or is this the beginning of a much longer journey towards higher standards?

I think it’s a great starting point. It sets the minimum expected standards for us, so it helps to protect our players and helps ensure fair competition amongst the industry as well. Whether more is required or not, I think a lot of that responsibility lies with ourselves and the wider industry.

Regardless of the voluntary code, we need to be seen to be doing the right things for the right reasons. I think that’s the most important thing. With regard to what happens next, we’ll be prepared for that.

Elite describes itself as the first prize competition business to appoint a senior compliance executive from a major regulated betting operator. Why do you think the sector has reached the point where this level of expertise is now necessary?

The industry has grown very, very quickly in a very short period of time and it’s still a new industry. Hopefully it’ll continue to grow, but at the stage it’s got to now and with that level of growth, there’s a lot more responsibility that comes with it. The customer base is growing and we need to be able to give them confidence that we’re operating responsibly and that we’re trustworthy.

We’ve already mentioned the new voluntary code of good practice, which is a positive. It’s a baseline for the industry. But it’s not just looking at what we must do. It’s looking at what we should do and what it is right to do moving forwards.

Having overseen bet365’s GLI-33 certification programme, what lessons from highly regulated gambling can realistically be applied to prize competitions without creating unnecessary burdens? Are there controls you’d like to see adopted on a ‘should do’ rather than ‘must do’ basis?

The GLI-33 certification programme required bet365 to perform an assessment of its entire business operations and ensure that they were robust and that they could provide the integrity and trust required by their customers. What came out from that was more reliable, more repeatable processes that facilitated continued growth. I think that applies to the prize competition sector now. It’s grown quickly and, if we want to continue to do so, that needs to be backed up by trust, integrity and effective processes.

We’re a fast-moving business, so we need to continue to become smarter and more efficient at what we do, make what we do well repeatable and set new standards for ourselves. That approach helps to protect our players and prepare us for what may or may not come in the future, but it helps us to grow as a business as well.

At bet365 you were working with something as prescriptive as GLI-33, where the standards and certification requirements are extremely detailed. You’ve now entered a sector where much of the framework remains voluntary. As a compliance professional, is that liberating, uncomfortable or more challenging?

It’s more challenging. With compliance in any environment where the rules and regulations are mature and black and white, that’s much easier to comply with as a baseline.

In the environment we’re in now, everything is still evolving, so it’s much more a case of shades of grey. There’s more responsibility on ourselves to make sure we’re doing the right thing and not just what’s written down in any external guidelines. We’ve got to go above and beyond that. Interpretation becomes more difficult and there’s much more responsibility on us.

Consumer trust is becoming increasingly important across all forms of online entertainment involving money. What does trust look like in the prize competition sector, and how do you build it beyond simply complying with the rules?

It’s about being transparent all the time – being honest, being fair and being accountable to our customers. For us, it’s about understanding our customer base, having that genuine connection with them and them believing in what we’re doing and wanting to come on that journey with us. That’s difficult to capture in regulations. That’s why it’s not just a tick-box exercise for us. It’s about how we operate as a business and the values that we have.

Prize competitions have grown rapidly over the past decade, but that growth has also attracted greater scrutiny. Do you expect more formal regulation in the future, and how should operators prepare for that possibility?

The most important thing for us is not to rely upon that. We need to look at best practice, not just from the gambling industry but from elsewhere, and implement what’s relevant to us to improve, protect our customers and maintain that trust and integrity. Our goal is to lead the way and to be proactive, not reactive. We don’t want to wait to see what might happen.

We want to do the right thing and the best thing that we can for ourselves, our customers and the wider industry, so that we’re essentially ready for whatever happens next.

Responsible gambling is deeply embedded within licensed betting. While prize competitions sit outside gambling regulation, are there still responsible play principles that businesses should adopt?

Absolutely. I think that’s one of the reasons it’s valuable that I’ve come from that sector. It’s about doing the right things for the right reasons, not because we must do something at this particular moment in time or because we’re legally obliged to do so. We’ve got to maintain our standards and values and protect our customers regardless of that.

What we’ll be doing moving forwards is looking at those responsible play principles that are in place in the wider gambling industry and learning from them. If they’re applicable to us, if they can help us, help our customers or guide us in where we need to go, then that’s something we need to explore.

As Elite continues to scale, how do you ensure compliance evolves alongside growth rather than becoming something that catches up afterwards?

It’s not a tick-box exercise and it’s not a reactive exercise. We’ve got to go beyond that. It’s more of a mentality for the business in general. What we’ll continue to do moving forward is implement robust frameworks, processes and working practices, and have a culture of continually reviewing and improving what we do and how we do things.

Elite Competitions has the right people with the right energy to do that, and it’s a responsibility on me to drive that moving forwards. If we continually have that improvement cycle and become more efficient and better at what we do, it facilitates that growth.

You’re also coming into a company that hasn’t previously had that framework imposed upon it. Does introducing it create friction internally?

I don’t think there’s friction per se. It might be a learning exercise. Elite Competitions has specifically employed me as Head of Compliance for all of the right reasons, so that’s the correct starting point and the intentions are clear. But there’ll be a learning exercise. It’s a staged process. Initially, it’s a case of getting the baseline foundations in place. We have to be compliant with everything we’re required to be compliant with.

The second stage is to review our operations and look at how we can do things better and improve. It’s for the benefit of us and it’s for the benefit of our customers as well.

Transparency has become a key differentiator for operators. Beyond live-streamed draws and independent verification, where can the industry still improve its communication with customers?

A lot of it is around customers trusting that our competitions are fair and that the prize winners are genuine. I think the industry has grown so quickly that there can be a misconception that the prize, particularly compared with the cost of entry, is almost too good to be true. We need to make sure that people understand that every ticket has an equal chance of winning and be clear and honest in our communications.

It’s about being professional in everything that we do and then constantly reviewing that, moving forwards, setting new baselines for ourselves and getting better and better.

If the voluntary code ultimately develops into formal regulation, would that radically change the prize competition sector or simply represent the next stage in its evolution?

I think it’s a little bit of both. The voluntary code is a stepping point. It’s put a new baseline in place and sets a standard that everybody needs to keep to. It’s a good thing and the right thing to do in terms of protecting our players, trust and transparency.

I do think it will continue to evolve. We need to make sure that our customers trust us as a business first and foremost, and choose to play and follow Elite Competitions for the right reasons. It may well be that there are further regulations in the future. It may not. It’s very difficult to say.

But it’s up to us to make sure that we’re protecting our customer base in the right way, so whatever comes our way we’re ready for it. By taking this proactive approach and ensuring everything is running in a fair, trustworthy and valued manner, we’ll be well placed to respond to any further regulation that may come our way.

Should prize competitions ultimately be aiming for the same level of compliance as a highly regulated operator such as bet365, or does the sector’s different risk profile require a different standard?

It is different from the wider gambling industry. There’s the free prize entry route, so it doesn’t fit within gambling regulation. It sits underneath UK consumer protection law and people can enter for free. If somebody uses that free entry route, they have the same chance of winning as somebody who doesn’t use the free entry route. I think that’s important.

I think the level of entry and the scope of the offering is, in general, different to the wider gambling sector. Prize competitions are also entirely random, with no choice or level of skill required, which can create a clearer outcome for the player with less perceived player input or control. We need to continue to make sure that’s the case.  Certainly, what we’re already striving to do is make sure that we protect customers who may be at risk.

We don’t want customers who are spending excessive amounts of money, because that’s not good for us, it’s not good for them, and I don’t believe that’s good for the industry either moving forwards. So it is different. It isn’t the same. It is much more focused in scope and there’s a different product offering.

But again, if we do the right things, then the need for further regulation is not necessarily as great. We’ll be ready for it. We want to do the right things and act with trust and integrity, so we’ll be prepared for whatever happens next.