As a company operating in a regulated industry, operating with integrity is part of our DNA.
William Hill is licensed in 12 countries, including the UK, Italy, Spain, the US, Gibraltar, Malta, and Sweden. Compliance with the regulations that covering our licensing obligations is a core part of our day-to-day activities and is built into our business.
For instance, there are three licensing objectives set out by the UK Gambling Commission that underpin our operating policies and procedures:
- Ensuring that gambling is conducted in a fair and open way;
- Protecting children and other vulnerable persons from being harmed or exploited by gambling; and
- Preventing gambling from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime.
In addition, we have signed up to the UK Betting and Gaming Council’s Code of Conduct, which can be found here.
Treating customers fairly and openly
We make available a comprehensive set of rules in our betting shops and online that detail the terms and conditions under which all transactions placed with William Hill are accepted. We have specialist customer service teams for shop, telephone and online customers to respond to their needs. The Online UK team have reviewed their terms and conditions for plain English standards and will be publishing these in 2020.
We want customers to feel they are treated fairly and openly, and endeavour to resolve all betting disputes in a clear and equitable manner. When a customer disagrees with our decision, they can refer to the Independent Betting Adjudication Service.
We regularly measure the quality of our service performance through Customer Satisfaction (CSAT) and Net Promoter Scores (NPS) surveys. CSAT has increased 20% between 2018-2019. The CSAT improvements have come from listening to our customers and using the feedback to reduce friction points and improve communications.
The overall NPS moved from 18 in 2018 to 16 in 2019, due to a constant decline in gaming while sportsbook overall NPS remained flat across both years. In Retail, NPS has been measured since 2011 and shows a consistently high rating, which was 58% in 2019.
Socially responsible marketing
We adhere to the Industry Code for Socially Responsible Advertising, overseen by the Industry Group for Responsible Gambling. This was updated in 2019, to implement the voluntary ‘whistle-to whistle’ ban on TV advertising around live sports before the 9pm watershed. Under the Association of British Bookmakers’ Responsible Gambling Code, we do not advertise gaming machines in our betting shop windows and 20% of shop window advertising is dedicated to safer gambling messages.
Gambling is an adults-only activity and we are fully committed to preventing under-18s from gambling. We devote significant resources to minimising any risk of accepting bets from minors, as well as adopting clear policies around age-gating on social media.
In our betting shops, we use a ‘Think 21’ approach, requiring colleagues to seek proof of age from any customer who appears to be under 21, and we ask individuals to leave if they are unable to provide that proof. Every shop undergoes independent age verification tests and we ensure we maintain a consistently high pass rate.
In Online UK, new age verification procedures were introduced in May 2019 meaning all customers are checked on registration, which resulted in a doubling of the number of checks conducted annually. We have clear processes to ensure our advertising content complies with the Advertising Standards Authority UK Code of Broadcast Advertising and does not appeal to children, and have strengthened controls regarding affiliates in this area. Our content is labelled 18+ and includes ‘BeGambleAware’ messaging and age gates are applied on social platforms.
William Hill takes crime prevention extremely seriously and devotes considerable people and financial resources to this area. As retail outlets can be a target of crime. We have adopted rigorous processes and safe working practices. We have invested in networked, monitored CCTV in all shops, and have deployed safe havens across the estate and the use of StaffSafe, a monitoring and intervention system to protect colleagues in shops.
Over the last decade, we have materially reduced the level of crime and focused on protecting the safety of our colleagues, customers and communities. Compared with 2009, robberies are down 85%, burglaries are down 75% and cash-in-transit incidents are down 77%. Societal violence in the workplace continues to be an area of high priority and we hold around 100 risk-based, anti-social behaviour workshops for Retail colleagues each year, usually in collaboration with the local police and local authority support.
We are an active member of the Gambling Anti-Money Laundering Group, which has adopted best practice guidelines on anti-money laundering. Our Online business is subject to the 4th EU Anti Money Laundering Directive and in the UK we also adhere to the Proceeds of Crime Act 2002.
We have dedicated risk management teams employing more than 70 people full time in monitoring and investigating suspicious activities in Online and in Retail.
We use ‘Know Your Customer’ and ‘Enhanced Due Diligence’ checks on customers in compliance with the relevant licensing regulations and laws. In addition to these, we conduct source of funds/ wealth checks on customers. We are also adopting further affordability checks based on publicly available income data.
Sports betting integrity
We also support efforts to uphold the integrity of sports and sports events, and are active members of the International Betting Integrity Association in Europe and the new Sports Wagering Integrity Monitoring Association in the US, which provide a platform for sharing data on suspicious betting patterns and reporting on them publicly.
We also have a number of memoranda of understanding with sports governing bodies where we work closely in sharing information and best practice on sports integrity issues relating to betting. In the UK, we are actively involved in the Sports Betting Integrity Forum, established by the Government and the Gambling Commission, which has developed the Sports Betting Integrity Action Plan.
The Board considers that it is not necessary for the Group to operate a specific human rights policy at present. Our policies already operate within a framework to comply with relevant laws, to behave in an ethical manner and to respect the human rights of our employees and other stakeholders in the business. Most of the Group’s business is focused in the UK and in jurisdictions where human rights are generally observed. The Corporate Responsibility Committee, on behalf of the Board, is satisfied that William Hill’s policies operate in a way that is consistent with the UN’s Global Compact, covering areas of human rights, labour, the environment and anti-corruption. The Group also operates its own bribery and corruption policy.
The Group’s statement on the Modern Slavery Act 2015 was reviewed and updated in February 2020. The statement is available here.
Health and safety
The health and safety of our colleagues and customers and those who come into contact with our business is of paramount importance to us.
Our Chief Executive Officer has overall responsibility for health and safety, and we have systems in place to set our policies, to implement them and to monitor and audit how we perform, drawing on external expertise in key areas.
In the UK, since 2012 we have had a Primary Authority relationship with Westminster City Council, which means they are given full transparency on our health and safety management systems, including the health and safety objectives as overseen by the Board’s Corporate Responsibility Committee, and we benefit from their informed advice on related issues.
We have periods of time when colleagues are lone-working in our betting shops. In making the decision to allow this, we conducted risk assessments of each shop and also took account of the Health & Safety Executive’s lone-working detailed guidance. When we made changes to our approach to lone-working in 2014, we undertook an extensive four-month trial in 400 shops and made a range of security changes prior to implementation. The impact of the changes were thoroughly assessed after implementation, looking at a number of areas, including colleague welfare and security.
The changes were made without significantly impacting our colleagues, customer service or compliance obligations.
Our primary objective is to maximise shareholder value in all aspects of the Group’s business activity. We manage our taxes in the same manner as we manage our business – in a manner expected by our shareholders and consistent with our core values.
You can view our UK tax strategy here.
We are committed to conducting our operations with honesty and integrity, and with respect for human rights and the interests of our employees and shareholders.
The Modern Slavery Act 2015 requires large UK businesses to publish a statement describing the activities they are undertaking to prevent slavery and human trafficking in their own business operations and supply chain.
Our commitment to human rights and our people
William Hill actively maintains a zero tolerance approach to slavery and trafficking in all its forms, in any part of its business or supply chain, continuing to apply the UN Guiding Principles on Business and Human Rights and core labour standards set out by the International Labour Organisation.
Our Code of Business Conduct has been approved by the William Hill PLC Board and sets out the basic principles that we expect all to comply with across the Group. This is supplemented by more detailed policies and procedures in a number of areas, which are communicated to employees and other stakeholders as appropriate. Our policies operate within a framework to comply with all relevant laws.
Download our current statement here