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Managing Betting IntegrityHelp and support for British Licenced Operators
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This pack has been designed to help betting operators (and where applicable) their staff that are new to Britain’s licencing regime. It
aims to help you understand the measures in place to manage the risks related to betting integrity and match fixing. It is not
intended to replace or supersede official guidance.
It will signpost you to a range of advice and good practice developed by experts, based on their practical experiences.
Who can I talk to for advice and guidance? Who does what?
Britain has set up what is known as the Betting Integrity National Platform. This is basically a group of representatives from across
sport, betting operators, law enforcement and the Gambling Commission who work together in the fight against match fixing and
betting related corruption.
The Sports Betting Intelligence Unit (SBIU) are at the heart of this platform. Betting operators licenced in Britain are
obligated to report potential instances of betting integrity or match fixing to the SBIU. How this works in practice and who
to contact is explained throughout this pack.
The pack also has details of the national platform partners, what support is available and useful contact details.
Managing Betting Integrity: Help and advice for GB Licenced operators
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What is match fixing?
It is the corrupt manipulation of a sporting event by those participating, officiating, organising or coaching,
with the intention of producing a result or occurrence which benefits the corrupter and/or their associates.
The benefit may be a financial reward related to the deception of operators or other bettors through sports
betting.
Match-fixing corruption can also result in benefit to individuals or teams by gaining advantage in
tournaments, leagues and/or competitions. Such actions may not necessarily involve betting but would be
a breach of sports codes or regulations, if relevant clauses and/or conditions are in place.
Why is Prevention so important
Sport and sports betting rely upon high standards of integrity. Match-fixing and related betting corruption
undermines the ethos, reputation and commercial viability of sports and betting businesses.
It can have an impact on the social, political and economic benefits derived from sports and sports betting.
It tarnishes the reputation of all athletes and has impact upon Britain’s reputation as a safe environment
within which to host sporting events and conduct gambling related business.
The Sport and Sports Betting Integrity Action Plan outlines Britain’s approach to address risks to the integrity of sport and sports betting and to protect
our national and international reputation for being a safe place to enjoy both.
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This spectrum was developed to demonstrate the various
levels of betting integrity. It doesn't aim cover every single
element but an overview of the types of issues that may
arise.
At the bottom of the scale, an opportunistic breach of
rules, for example, could be a participant betting on the
outcome of an event in their sport that may be a breach of
that sport’s betting rules.
Deliberate underperformance could be something similar
to the example seen at the London 2012 Olympics when
badminton players were accused of wanting to lose, in an
attempt to manipulate the draw for the knockout stage.
Manipulation for sporting reasons could be two teams
agreeing a result of a match so that one avoids relegation
or achieves promotion. Neither necessarily always involve
betting – but such information could be used to unfairly
place a bet, as well as being a likely breach of sports
codes or rules.
Misuse of inside information relates to information that is not in the public domain being used for betting purposes. See the Gambling Commission’s policy paper for more
information. Opportunistic spot fixing may involve an athlete or team deliberately making something happen for betting purposes, such as losing a particular game in tennis or
being the first player to kick a ball off the pitch in rugby or football.
Organised crime match or spot fixing is participants being offered an incentive by persons, sometimes linked to organised crime groups, or are threatened by criminals, to
achieve a specific result relating to the outcome of a match or an event within a match. Match fixing may also be instigated by participants, without links to organised crime,
e.g. two teams agreeing the result of a match before it starts. However, although this is not instigated by a criminal gang, such action is potentially a criminal offence e.g. the
offence of cheat.
Opportunistic breach of rules
Deliberate underperformance
(e.g. to gain an easier draw in next
round)
Organised crime
(Match fixing / spot fixing)
Misuse of inside
information
Manipulation for sporting reasons (ranking points /
promotion / relegation)
Opportunistic manipulations
/spot fixing
The Match Fixing Spectrum
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The Sports Betting Intelligence Unit (SBIU) is a unit within the Gambling Commission. It is at the heart of Britain’s approach to managing reports about
sports betting integrity across the whole of the match fixing spectrum; from suspected match fixing though to breaches of sports betting rules.
The majority of reports into SBIU are received from betting operators concerning alerts about suspicious or irregular betting patterns or breaches of sport betting
rules. As mentioned previously, as an operator licensed in Britain, you are obliged to report any suspicious betting activity to SBIU. These obligations are further
explained in this pack.
SBIU also receive information from a range of other sources, including sport, law enforcement or through their confidential hotline. Anyone can contact SBIU if
they have genuine concerns about match fixing or other betting integrity related issues.
The SBIU work with stakeholders to collect, collate and develop the available intelligence relating to reports. This could include betting account data, information
from sport and open source research. They can share intelligence, where appropriate, with sports governing bodies, which in some cases can be used to
support a sport investigation. In some cases they will liaise with law enforcement and the Crown Prosecution Service if a criminal investigation is appropriate. All
intelligence is logged on SBIU systems, so even if an investigation is not appropriate, information is retained in case it may be relevant to future cases. (When
considering dissemination and retention of information SBIU adhere strictly to Data Protection Legislation)
To find out more about the help and support offered by the SBIU, or to report an alert, get in touch:
• By phone on +44 121 230 6655
• By email using [email protected]
Website: SBIU at the Gambling Commission
Betting Integrity and Match Fixing in GB: Who does what?
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The Sports Betting Integrity Forum (SBIF)
The Forum brings together representatives from sports governing bodies, betting operators, sport and betting trade associations, player associations, law
enforcement and gambling regulation. It supports and coordinates partners' individual and collective efforts to deliver Britain's strategy for protecting the integrity of
sport and sports betting.
The SBIF Website offers a range of good practice tools, including examples of Education Programmes, Betting Rules and case studies. Forum members are also
happy to share their advice and expertise, either via the good practice information on the SBIF website or through direct contact to offer bespoke advice.
If you would like get in touch you can do so via the Contact Us Page on the SBIF website.
The Sports Betting Group (SBG) brings together representatives from across sport to provide
leadership and to share good practice to address the risks from sports betting corruption. Central to the
SBG’s work is the SBG Code of Practice. The SBG website provides sports governing bodies and wider
stakeholders in the sports betting field with a central resource containing information and good practice
including betting rules, reporting contacts and educational material. The SBG may be able to provide
assistance to operators looking for contacts or information on specific sports. More detail on this is
explained throughout this pack.
You can contact the SBG by phone on 0207 976 3900 or by email [email protected]
Betting Integrity and Match Fixing in GB: Who does what and who can I ask?
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Betting Integrity: Your obligations under licence conditions and codes of practice
Licence conditions and codes of practice (LCCP)
The LCCP sets out the Gambling Commission’s general licence conditions and associated code of practice provisions under the Gambling Act 2005. Anyone
holding a licence with the Gambling Commission must comply fully with the requirements of the LCCP.
The LCCP covers:
• the suite of general conditions attached to operating licences
• the principal code of practice
• the suite of general conditions attached to personal licences.
General licence conditions and associated code of practice provisions (LCCP) under the Gambling Act 2005 apply to all gambling sectors.
Licence Condition 15.1 and ordinary code provisions 4.2.8 and 7.1.3 relate to betting integrity. The following slides sign posts you
to where you can find additional advice and support on these areas.
The Gambling Commission was set up under the Gambling Act 2005 to regulate commercial gambling in Great Britain in
partnership with licensing authorities. It also regulates the National Lottery under the National Lottery etc. Act 1993.
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Reporting Suspicion of Offences LCCP 15.1
This licence condition means that you must have processes in place to identify suspicious, unusual or irregular betting patterns that could indicate misuse of inside
information, the manipulation of an event or activity within an event or match fixing. These conditions apply to any business that has a British operating licence, be it
through a small independent shop or large multi national company. These mechanisms should provide you and all relevant staff in your organisation with an auditable
decision making process to determine when and how suspicious activity should be reported to SBIU.
SBIU, in conjunction with the Association of British Bookmakers and the Remote Gambling
Association have produced additional guidance for operators that provides some clarification on
what 15.1 means in practice; the Framework for Identifying Unusual or Suspicious Betting Patterns.
The Framework provides a suite of indicators that can be referenced to assist in the identification of
potential unusual/suspicious activity.
If you would like a copy of the Framework please get in touch with SBIU
Suspicious activity should be reported to SBIU by phone or by email
Telephone: 0121 230 6568
0121 230 6609
Email: [email protected]
If you are unsure whether to report specific activity under licence condition 15.1, you can contact the SBIU
who would be happy to discuss the more detail.
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Many sports have rules in place that prohibit participants from placing bets on their sport.
15.1.2 states that, once identified, operators should also notify the relevant Sports Governing Body
(SGBs) about information that could lead to the voiding of a bet or a potential breach of sports rules*.
Licence Condition 15.1.2 Sharing Information with Sports Governing Bodies
*LCCP refers to those SGBs that are included on Schedule 6 of the Gambling Act. The Schedule list bodies which are able to exchange information with the Gambling
Commission under powers conferred by section 30 of the Gambling Act. To note, in line with correspondence issued by the Commission in February 2016, in order to
help protect the integrity of UK sport, in time sensitive cases we request that operators consider alerting the relevant SGB at the time the suspicious activity is
identified. Time sensitive cases are those where the suspicious activity is identified immediately prior to or during an event, where the event involves UK sports.
SBIU also holds details of some SGBs, so please get in touch if you can’t
find the details you are looking for. Or you can contact the SBIU direct to
report potential breaches of a sport’s rules.
Contact details for the integrity teams of many SGBs can be found on
the Sports Betting Group’s website . If the sport you need is not listed,
contact the Sports Betting Group as they may be able to help you find
the relevant rules.
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SBIU are currently running a pilot that aims to standardise the format of information returns.
At the moment that the data provided by operators is presented in a number of different formats i.e. Excel, Word,
Screen Shots, PDF etc.
This means that before any analysis can take place, the data has to be re-keyed or copied and pasted into a
standardised Excel spreadsheet. This presents two issues; firstly, the process is time consuming and resource
intensive and secondly, it is open to errors being made when data is transposed.
We are encouraging operators to use a standard Excel spreadsheet format that will allow the team to focus on
analysis and assessment rather than administrative tasks.
If you would like more information please email Lorraine Pearman, the Commission’s Betting Integrity Programme
Lead on [email protected]
Licence Condition 15.3 - Requests for information
SBIU can request information from betting operators related to incidents of suspected betting integrity under LCCP
15.3. SBIU will make sure that information requests are specific and only relevant to the case for which they are
gathering intelligence.
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LCCP Ordinary Code Provision 4.2.8.1 sets out responsibilities for
operators to familiarise themselves with the rules applied by Sports
Governing Bodies.
Many sports governing bodies prohibit any betting on their sport by
participants or persons covered by their codes of conduct, betting
rules or terms of employment.
You can find links to the relevant betting rules for each sport under
the control of the Sports Betting Group members on the SBG
website
If the sport you need is not listed, contact the Sports Betting Group
as they may be able to help you find the relevant rules.
LCCP Ordinary Code Provision 4.2.8
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LCCP Ordinary Code Provision 4.2.8.2 sets out responsibilities for
operators to ensure that a condition of accepting bets, customers
must not be in breach of professional rules relevant to a sports
governing body. Some suggested wording as to what could be
included within customer terms and conditions are below*;
• By accepting our terms and Privacy Policy you acknowledge that
the following conditions comprise part of our bet acceptance
terms:
• bet placement is not prohibited by any term of your
employment contract or any Sport's Governing Body rule
which applies to you; and
• You are not aware of any circumstances which would
make the placing of the bet a breach of a betting rule
being applied by a sport's governing body.
• If any bet placed by you is found to be false and in contravention
of this term, we will have the right to withhold any and all
winnings, and your stake will be forfeited win or lose. We are
entitled to share the information we hold on you which includes
personal data and betting history with the Gambling Commission,
sporting governing bodies and other bodies, including the police,
in order to investigate sports integrity issues and to comply with
our regulatory responsibilities
*for demonstration purposes only, Operators should ensure legal teams are consulted on
the wording of actual T&Cs
LCCP Ordinary Code Provision 4.2.8
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LCCP Ordinary Code Provision 7.1.3
It is recognised that many employees of betting operators of enjoy having a
bet and there is no intention to prohibit such activity.
However, there is potential for a conflict of interest if a licensee’s employees
have access to information that might indicate suspicious betting activity and
use it to place bets for personal gain.
The betting integrity system relies on operators reporting information about
suspicious betting patterns to the SBIU and the relevant Sports Governing .
Without this, you may be at risk of accepting bets based on advantageous
commercial intelligence in the possession of other operators and the betting
integrity system is at risk of being undermined.
This element of the code requires you to have employment terms and
conditions are in place that require employees to act primarily in the interests
of their employers. i.e. that information related to suspicious betting activity
should be reported to SBIU, via whatever process is in place in your
organisation and is not used to place their own bets.
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Many larger operators put in place memorandums of understanding sporting and regulatory bodies to help facilitate the sharing of information. An MoU can work
alongside operators Terms and Conditions of account use and in certain circumstances facilitate the sharing of customer data with these organisations. An MoU can also
assist in securing a single point of contact within a sport with whom you can agree how information can be shared securely.
Paddy Power Betfair explain how they use MoUs and provide a generic template that can be adapted for specific agreements on the
SBIF website
The SBIF are currently developing a template that could be used by sport governing bodies to set up an MOU. The template,
will be made available on the SBIF website in early 2018.
Additional Advice
Working Together
To see examples of how betting operators have worked with sports, the Commission and others check out the SBIF website, in particular the case studies in the best
practice section
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Contact the Sports Betting Integrity Forum for help
or advice about any element of this pack through
the Contact Us page of the website.
A list of current members of the Forum can be
found by clicking here.
If you would like to contact one of the members
direct, we can put you in touch via the Contact Us
page
