Key Events Policy

March 2023

Introduction

This policy outlines how the Labour Party will ensure it meets its Gambling Commission licence conditions by reporting any key events to the Commission that could have a significant impact on the nature or structure of our lottery or raffle activities.

Scope of policy

A key event is an event that could have a significant impact on the nature or structure of a licensee’s business. Within this Policy, the Labour Party outlines times when we must notify the Commission, in such form or manner as the Commission may from time to time specify, of the occurrence of any of the following key events as soon as reasonably practicable and in any event within five working days of the Party becoming aware of the event’s occurrence

Policy

As part of our commitment to meet our Gambling Commission licence conditions we will notify the Gambling Commission of any key events that could have a significant impact on the nature or structure of the lottery or raffles.

This notification will be made as soon as reasonably practicable and in any event within five working days of us becoming aware of the event’s occurrence. Notification will be made via the Gambling Commissions e-services facility.

A full account of the key event will be recorded by Angela Cartwright, Commercial Director for the Labour Party.

Procedures

The key events that may affect us and will be reported to the Gambling Commission are as follows:

Operator status

In the case of a petition being presented for its winding up or being placed in administration or receivership or its trustees proposing to creditors a composition in satisfaction of its debts or a scheme of arrangement of its affairs

Relevant persons and positions

Key events in the case of relevant persons and positions include:

  • The taking of any loan from any person not authorised by the Financial Conduct Authority: A copy of the loan agreement must be supplied.
  • The entering into an arrangement whereby a third party provides services to, or grants any licence concession or permission to, the Party other than for full value: full details of the arrangements must be supplied.
  • The appointment of a person to, or a person ceasing to occupy, a ‘key position’: a ‘key position’ in relation to the Party is:
    • in the case of an operator which is not a small-scale operator, a ‘specified management office’ as set out in (current) LCCP licence condition 1.2
  • a position the holder of which is responsible for the licensee’s anti-money laundering procedures, including suspicious activity reporting
  • any other position for the time being designated by the Commission as a ‘key position’. (Notification is required whether or not the person concerned is required to hold a personal management licence and whether or not the event notified requires the licensee to apply for a variation to amend a detail of their licence.)
  • Any change to the structure or organisation of the Party’s business that affects a ‘key position’ or the responsibilities of its holder.

Financial events

Key financial events include:

  • Any material change in the Party’s banking arrangements, in particular the termination of such arrangements or a particular facility and whether by the Party or the provider of the arrangements.
  • Any breach of a covenant given to a bank or other lender.
  • Any default by the Party in making repayment of the whole or any part of a loan on its due date.
  • Any court judgments (in whatever jurisdiction) against the Party, remaining unpaid 14 days after the date of judgement.
  • Where the Party is required to have its accounts independently audited, any qualification to an auditors’ report; and any unplanned change of auditor including a change prompted by a dispute or resulting from auditors being unable or unwilling to sign an unqualified audit report.
  • Any change in the Party’s arrangements for the protection of customer funds in accordance with the general licence condition 4 relating to the protection of customer funds (where applicable).
  • Where the Party holds customer funds in a separate bank account, any deficit on reconciliation of such bank account.

Legal or regulatory proceedings or reports

Key events concerning regulatory proceedings or reports include:

  • The grant, withdrawal or refusal of any application for a licence or other permission made by the Party, to a gambling regulator in another jurisdiction. In the case of a withdrawal or refusal of the application, the Party will also notify the reasons for such withdrawal or refusal. (This condition does not apply to applications for licences or other permissions to carry on activities that would fall outside the scope of a Gambling Commission operating licence if carried out in Britain or with customers in Great Britain.)
  • Any investigation by a professional, statutory, regulatory or government body (in whatever jurisdiction) into the Party’s activities, or the activities in relation to the licensed entity of a personal licence holder or a person occupying a qualifying position employed by them, where such an investigation could result in the imposition of a sanction or penalty which, if imposed, could reasonably be expected to raise doubts about the Labour Party’s continued suitability to hold a Gambling Commission licence.
  • Any criminal investigation by a law enforcement agency in any jurisdiction in relation to which:
  • The Party is involved (including, but not limited to investigations of crimes allegedly committed against the Party or involving the gambling facilities provided under the licence), AND
    • The circumstances are such that the Commission might reasonably be expected to question whether the Party’s measures to keep crime out of gambling had failed o Notification of the event must occur as soon as practicable after the Party becomes aware of any such investigation in which the Party is involved and measures may have failed.
  • The receipt of any report from a professional, statutory or other regulatory or government body (in whatever jurisdiction) of the outcome of a compliance assessment in relation to the gambling activity of the Party in which at least one person who holds a key position in or in respect of the Party holds a key position: a copy of the report should be provided where available to the Party.
  • The referral to the Party’s Governance and Legal Unit, of any material concerns raised by a third party (such as an auditor) about the provision of facilities for gambling which are expressed (in whatever terms) as requiring attention as a high priority: a summary of the nature of the concerns must be provided.
  • The imposition by the Party of a disciplinary sanction, including dismissal, against the holder of a personal licence or a person occupying a qualifying position for gross misconduct; or the resignation of a personal licence holder or person occupying a qualifying position following commencement of disciplinary proceedings in respect of gross misconduct against that person.
  • The commencement (in whatever jurisdiction) of any material litigation against the Party, relating to its Lottery activities. The Party will also notify the outcome of such litigation.
  • The making of a disclosure pursuant to section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (a suspicious activity report): the Party will inform the Commission of the unique reference number issued by the United Kingdom Financial Intelligence Unit of the National Crime Agency in respect of each disclosure and for the purposes of this key event the five working day period referred to above runs from the Party’s receipt of the unique reference number. We will also indicate whether the client relationship has been discounted at the time of the submission.

Gambling facilities

Key events concerning gambling facilities include:

  • Any breach in the Party’s information security that adversely affects the confidentiality of customer data or prevents customers from accessing their accounts for longer than 24 hours.
  • Any change in the identity of the ADR entity or entities for the handling of customer disputes, as required by the social responsibility code provision on complaints and disputes.
  • The reference of a dispute to an ADR entity other than one in respect of which contact details were given in accordance with the social responsibility code provision on complaints and disputes; the reason for selection of that ADR entity should be given.
  • In the case of remote gambling, the commencement or cessation of trading on website domains (including mobile sites or mobile device applications) or broadcast media through which the Party provides gambling facilities.

Other reportable events

Other reportable key events include:

  • The Labour Party will also notify the Commission in such form or manner as the Commission may from time to time specify, or ensure that the Commission is so notified, as soon as reasonably practicable of the occurrence of any of the following events:
  • the conclusion of a dispute referred to an ADR entity and in such case providing the Commission with a copy of the decision or note of the outcome.
  • any outcome adverse to The Labour Party of any proceedings taken against us (in whatever jurisdiction) by a customer in relation to a gambling transaction; but excluding proceedings allocated to the County Court small claims track or equivalent in jurisdictions outside England and Wales.
  • The calling of a UK Parliamentary General Election. The Labour Party may seek to amend the frequency or size of any draws held under the terms of its licence to support fundraising for any general election campaign. Should that be the case, the lottery terms and conditions shall be updated accordingly and the Party shall notify the Commission of the same.
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