Whistleblowing, Governance and Exec Management oversight - what can gambling companies learn from Post Office Inquiry?

In the UK, there are a fair few independent inquiries currently ongoing. For those not in the know, two of the biggest include the Post Office scandal and the UK government’s handling of the Covid-19 pandemic. Both these inquires have been hotly discussed and closely followed by the media, which recognises that these issues mean a lot to the public.    

“What’s this got to do with us?”, I hear you ask.   

An underlying focus emerging from the various public inquiries is that of the performance of governance systems and the importance of effective senior management oversight.   

From the publicly available info, it appears that various people in positions of authority, responsibility and power may not have necessarily acted entirely comprehensively, openly or in accordance with their employers’ policies. Allegedly.   

As we know in any regulated industry, a policy is only as good as the content it includes, the publication it benefits from, the adoption rate it enjoys, the training deployed to support the adoption, and the ongoing review and assessment of its performance - both from the quality of content and the quality of implementation perspectives. We could go on here (but we won’t).   

However, this all counts for nothing if policies are ultimately ignored by those in positions of authority and responsibility, instead making decisions which counter the stated approach and instructing more junior members of staff to diverge from the written word to get round a difficult situation. 

What’s more, if the people doing this are very senior, those being instructed to vary from what should be done are placed in an unenviable dilemma.   

What does this mean for us? 

This is where the subject of whistleblowing comes in, a topical subject given the introduction of the Commission’s anonymous whistleblowing hotline which was quietly launched in late December 2023.  

The service invites consumers to report concerns around sports integrity, underage gambling and money laundering amongst other things - “Tell us something in confidence”.  

Whilst the landing page does make it clear that this service should not be used for raising complaints about operators, should the Commission receive a tip off about money being laundered through a gambling business, it’s probably safe to assume there’ll be a regulatory review type knock at the door sometime soon.  

What should we do?  

In terms of the GC’s new hotline, there’s not much you can do, except continue to ensure you are managing regulatory and AML risk appropriately for your business (and probably get Betsmart Consulting in to give you a thorough, independent health check).  

However, in terms of internal business improvement, you should be making sure you have a clear, robust whistleblowing policy in place, which is usually included in a Code of Conduct policy containing statements on ethical and fair business operations and details the protection of people who ‘blow the whistle’. A much forgotten and often de-prioritised concept, whistleblowing is important none the less and the importance exists both from the organisational and employee perspectives.   

For the employer’s benefit, a good whistleblowing process can help the early identification of questionable activity, avoidance of situations progressing to the “no going back now” stage and ultimately reducing the chances of having to deal with implementation failings down the line.  Even if potentially questionable behaviour does occur, supporting a whistleblowing environment gives the organisation the opportunity to identify and deal with it before it gets too big, or too noisy, or too bad.  

From the employee’s viewpoint, knowing that a good whistleblowing environment is supported and utilised, should promote confidence and willingness to engage, thus helping the business identify and deal with potential problems early whilst giving the employee confidence that they can raise concerns. 

If you have any questions about this topic or would like support to adopt practices mentioned above, get in touch with us today. 

Written by Andrew Mason – Betsmart Consultant