Corporate responsibility

Customers

William Hill is committed to high standards of customer service and to conducting our gambling operations in a fair and open way.

Bar chart showing 3 year disputes referred to IBAS

In 2009, 394 disputes were referred to IBAS. Although the number has increased, the percentage of cases found in the customers' favour is unchanged year-on-year at just 5%.

Bar chart showing 3 year self-exclusions

Customer service

Customers are at the heart of what we do. We strive to deliver a high standard of customer service and to be fair and open in our dealings with customers.

We have dedicated customer service departments for each of our main operations, who handle enquiries on a large range of issues relating to our business. Service complaints are given serious consideration and consistent procedures are in place across all of our operations to ensure that complaints are dealt with effectively. The issues raised are closely reviewed and we are committed to continual improvement in this area.

We have a comprehensive set of rules that detail the terms and conditions under which all transactions placed with William Hill are accepted. A copy of the betting rules is available in our LBOs, online or from our Customer Relations department. Rules relating to our online gaming products are available online. We endeavour to resolve all betting disputes in a fair, consistent and equitable manner. However, if we are unable to resolve a dispute to the customer's satisfaction they are entitled to refer the matter to the Independent Betting Adjudication Service (IBAS).

Since 2007 we have operated our Competition Beating Service (CBS) programme, aimed at delivering the best possible service to customers around:

  • friendly service;
  • famous expertise;
  • creating a great in-shop experience; and
  • effective management of in-shop operations.

We use CBS to measure our performance, using a mystery shopper programme provided by Retail Eyes, an international company specialising in customer service, and questionnaires completed by shop teams to test their knowledge on subjects as varied as the Grand National and Gambling Commission compliance.

Customer complaints

We operate dedicated customer services for each of our channels: Retail, Telephone and Online.

Our Retail customer helpline, which also supports staff, receives around 250,000 calls and 2,500 letters and e-mails a year, operating 12 hours a day on Monday to Saturday and across opening hours on Sunday. The majority of calls are general enquiries, with only 10–20 serious complaints a month. Since 2007, all complaints have been recorded on our tracking system, enabling us to track any persistent issues. Serious complaints are followed up by Area Operations Managers, who are required to report the outcome to the customer within 21 days.

Disputes are handled by an expert panel. We endeavour to resolve all disputes in a fair, consistent and equitable manner. However, if these are unable to be resolved to the customer’s satisfaction, they can refer the matter to the IBAS. We have agreed to abide by any ruling made by IBAS.

Although gambling transactions in Great Britain are now legally enforceable contracts and are subject to relevant consumer contract legislation, the majority of disputes continue to
be adjudicated by IBAS, the acknowledged industry expert.

Protecting vulnerable persons

Gambling is an exciting form of entertainment that can be experienced in a range of environments with William Hill, from the racetrack and our licensed betting offices to telephone and the internet.

Our relationship with customers is underpinned by operating standards set by the Gambling Commission, which was established in 2007. Many of these standards were based on existing standards being applied by major operators such as William Hill. In 2009, we moved our remaining UK-based online activities to Gibraltar, where we are regulated by
the Gibraltar Regulatory Authority, whose standards are similar to those applied by the Gambling Commission.

We work closely with the Gambling Commission in the UK in furthering its three objectives as defined by the 2005 Gambling Act (see below). We encourage a socially responsible attitude both within our organisation and within the wider betting and gaming industry. We work closely with the Gambling Commission in the UK and regulators in Gibraltar and Malta to ensure that we continue to adhere to the highest industry standards in responsible gambling. We are also committed to listening to the views of relevant stakeholder groups and have an active dialogue with GamCare, the national centre for information, advice and practical help for anyone with a gambling problem.

Helping problem gamblers

The Gambling Commission estimates that approximately 0.6% of the UK’s adult population has a propensity to be problem gamblers(1). As a responsible organisation, we provide a range of services to support existing customers for whom gambling has become a problem rather than a pleasure.

Although there is no one set of behaviours that identify such customers, we encourage our employees to use their experience and to be aware of customers whose behaviours may indicate problem gambling. We have procedures in place to escalate any concerns and to consider whether or not it is appropriate to raise the issue with a customer. When a customer is approached, we provide them with contact details of a gambling support charity and with detailed information on the tools available to control their gambling. We also provide customers with information to enable them to make informed decisions about their level of gambling but respect the fact that, ultimately, those decisions rest with the customer.

In our shops, on our websites and through our customer services department, we provide information on the tools available to monitor or control someone’s gambling.

We provide a self-exclusion facility for customers designed to prevent them transacting with specific parts of the business for a period of their choice running for at least six months and up to five years. Customers who wish to resume business with us at the end of their chosen self-exclusion period are required to complete a further 24-hour ‘cooling off’ period before they will be permitted to use our gambling facilities.

We also provide a facility for telephone and online customers to limit the amounts they are able to deposit with us in any 24-hour period. Once set, a deposit limit can only be increased after a 24-hour ‘cooling off’ period.

We train all our customer-facing employees to have an awareness of our social responsibilities and the detailed procedural knowledge they need for their role. We continue to monitor best practice in the area of responsible gambling as it develops and review our policies and procedures on a regular basis in light of guidance from regulators, gambling charities and our own practical experience.

(1) Gambling Commission Prevalence Study, 2007

Problem gambling research, education and treatment

Following publication in October 2008 of a Gambling Commission report on the review of research, public education and treatment (RET) of problem gambling, the Minister for Sport agreed to institute plans for a statutory levy on operators licensed in Great Britain, which would come into effect in the 2009/2010 financial year if the industry did not reach agreement on the target levels of funding for the next three years and to the proposed improved voluntary arrangements. We strongly supported a voluntary system and played a significant role in industry efforts to establish a workable framework for funding. With a number of other operators, we guaranteed a total gambling industry contribution for RET of £15m over three years. The Minister accepted that funding should continue on a voluntary basis.

The RET framework is underpinned by an industry funding body (the GREaT Foundation), with funds being passed to a distributor who allocates industry funding in accordance with priorities set by the Responsible Gambling Strategy Board.

Recently William Hill received a Gold award from the GREaT Foundation for our significant contribution to the 2009/10 funding campaign.

Under-age gambling

We can only accept customers over the age of 18 in our shops, at the racetrack, on our websites and via the telephone. To help enforce this age restriction, we have adopted a ‘Think 21’ approach in our shops and at the racetrack, which requires our staff to seek proof of age from any customer who appears to them to be under 21. For Online and Telephone customers, we use an external agency to verify the ages of customers who open new accounts using deposit methods that may be available to under 18s.

We take particular care not to target advertising at people under the age of 18. All our advertising in Great Britain is carefully considered in light of the Gambling Commission’s licensing objectives, the specific requirements of the Gambling Commission’s licence conditions and codes of practice, and the Committee of Advertising Practice and Broadcast Committee of Advertising Practice codes. In addition, we adhere to an industry code of practice designed to promote socially responsible advertising and the ‘Gamble Aware’ information website. The advertising agencies we use are fully briefed on our responsible gambling requirements.

Data protection

With well-established Telephone and Online business, we handle substantial amounts of personal customer data and have put in place comprehensive security policies, procedures and standards to reduce the risk that information could be lost or stolen. These cover the handling of both electronic and paper-based customer information and we carry out security awareness training with employees. Our equipment for sensitive systems is built to internationally accepted security standards. At the time of publication, we are over 90% through a programme of compliance with the Payment Card Industry Data Security Standards, by which we carefully restrict access to sensitive systems and data and encrypt card data to protect it in storage. In 2010, we will also complete roll-out of a proactive monitoring system that alerts us to suspicious activities.

Avoiding crime and disorder

Ensuring that crime is kept out of gambling is a key regulatory priority in both the UK and Gibraltar and one which William Hill takes very seriously. Whilst the principal tool to keep crime out of gambling is the regulatory licensing process by ensuring only legitimate operators are licensed, we are proactive in both the UK and Gibraltar in ensuring that our business is not subject to external attack by criminals, including those who seek to cheat at gambling.

As well as having extensive reporting obligations to both the Gambling Commission and the Gibraltar Regulatory Authority, our own risk management systems are designed to identify unusual betting activity. Where appropriate, suspicious betting transactions are reported to the regulator and the relevant sports governing body for further investigation.

Contrary to popular media-led perception, there are relatively few suspicious betting transactions identified by William Hill, or the betting industry in general, in any given year and it has been our experience that the majority of these are not progressed further, in terms of investigations or voiding action, by the relevant authorities.

Whilst betting does not fall within the regulated sector for the purposes of money laundering, we also remain focused on active compliance with the Proceeds of Crime legislation. We have internal controls and specialist staff, including a Money Laundering Reporting Officer, to deal with disclosures to the relevant authorities and to service requests for assistance from law enforcement and regulators. All staff are trained on their obligations to report money laundering and how to handle cash and cash equivalents safely. Online gaming products fall within the requirement of the 3rd EU Money Laundering Directive, and we have systems and procedures in place to ensure compliance with those requirements.

Logo: The Gambling Commission
Logo: The Gambling Commission

The Gambling Commission’s objectives

  • to prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime;
  • to ensure that gambling is conducted in a fair and open way; and
  • to protect children and other vulnerable persons from being harmed or exploited by gambling.


Image: No Under 18's
Image: No Under 18's

Review of our under-age gambling procedures

  • In May 2009, the Gambling Commission undertook a mystery shopper exercise to test the effectiveness of the industry’s measures for preventing under-age gambling. The result of this exercise was disappointing: across the industry, 98% of the 100 shops tested and all 25 of the William Hill shops tested, failed to challenge the individual on their age.
  • We take this failure very seriously and undertook a wholesale review of our policies and procedures to assess what had gone wrong and how we could improve. All our staff who were involved in the Commission’s mystery shopper exercise were interviewed to identify how they failed to challenge the mystery shopper. As a result of the review, we took the following steps to improve our systems.
  • A letter was sent to all Retail employees stressing the importance of Think 21, the key practical points and explaining that failure to follow the Company’s Think 21 procedure is an act of gross misconduct.
  • A briefing on Think 21 was cascaded throughout Retail, delivered personally by senior management through Area Managers to District Managers and then on to every member of Retail staff.
  • All job offer letters to new employees now include a statement on the importance attached to Think 21 and compliance with regulations.
  • All Retail training material on Social Responsibility was revised and reissued.
  • Consultation with the Staff Council was undertaken to enable staff views on how to implement Think 21 to be taken into consideration.
  • In December 2009, the Gambling Commission undertook a further mystery shopper exercise, at which point our success rate rose to 68%. This is good progress and comparable with the levels usually achieved by the drinks industry on its ‘Think 21’ programmes. However, we are not complacent and have instituted our own third-party testing systems to monitor our effectiveness on an ongoing basis.
©2010 William Hill PLC