Prize Draw Code of Conduct – Compliance Tracker
This page sets out how we comply with the Department for Culture, Media and Sport Prize Draw Code of Conduct. Each clause shows our current status and what we’ve implemented. As per DCMS Code of Conduct Website
Status legend:
Compliant
In progress
Planned / future implementation
1. Player protections
1.1 Age restrictions and age verification
18+ players only, no targeting under-18s.
Compliant
In progress
Planned
Code requirement
1.1 Operators should only make prize draws available for players aged 18 or over. Operators should implement
a reasonable age verification process. Advertisements for prize draws should not be targeted at anyone below the age of 18.
What we do
- Require all players to confirm they are 18+ before creating an account or entering a competition.
- Use date-of-birth fields and verification checks to prevent under-18 participation.
- Target our marketing only at adult audiences and exclude under-18s wherever targeting tools are available.
1.2 Complaints and dispute resolution
Clear route for players to raise issues.
Compliant
In progress
Planned
Code requirement
1.2 Operators should have an appropriate, transparent and robust complaints process for players and, where
required to resolve a complaint, an appropriate dispute resolution process for players.
What we do
Example text – edit to match your process:
- Provide a published complaints policy and contact route via email and website forms.
- Log all complaints and respond within a defined timeframe.
- Escalate unresolved complaints to senior staff and, where appropriate, external dispute resolution.
1.3 Credit card limits
Monthly limit and no cards for instant wins.
Compliant
In progress
Planned
Code requirement
1.3 Operators should not accept credit card payments in excess of £250 per month per player. Operators should
not accept any credit card payments whatsoever for any instant win prize draws. This includes any payments
made to operators by credit card through a money service business.
What we do
Edit to reflect your implementation:
- Configure payment providers to enforce a £250/month maximum via credit card per player account.
- Disable credit card payment options for instant win products.
- Review payment methods regularly to ensure ongoing compliance.
1.4 Monthly spend limits
Operator-set and player-set limits, including £0.
Compliant
In progress
Planned
Code requirement
1.4 Subject to the credit card limit in clause 1.3, operators should set suitable and proportionate maximum
monthly totals spend limits for all players, or provide the facility for players to set individual monthly
total spend limits... Operators should allow customers to set their individual spend limit at £0.
What we do
- Provide a “My limits” section where players can set or lower their monthly spend limit, including to £0.
- Prevent purchases once a player’s limit is reached for the month.
- Record and monitor limit changes to help identify risky behaviour.
1.5 Account suspension and closure
6-month suspension and permanent closure options.
Compliant
In progress
Planned
Code requirement
1.5 Operators should provide players with options to suspend their account temporarily or to close their
account permanently. Any request for a temporary suspension of an account should be actioned... for a minimum
period of 6 months. During suspension, no play or marketing should be permitted. A shorter “pause” option is encouraged.
What we do
- Offer self-exclusion for at least 6 months, during which no entries or marketing are allowed.
- Allow players to permanently close their account on request.
- Provide shorter “cool-off” pauses where technology allows.
1.6 Monitoring for harm
Systems to detect harm or potential harm.
Compliant
In progress
Planned
Code requirement
1.6 From the point when an account is opened, operators should make reasonable efforts to have in place
effective systems and processes to monitor players’ activity to identify harm or potential harm...
What we do
- Monitor player behaviour such as frequency of entries, limit-reaching and changes to payment methods.
- Flag patterns that may indicate financial or psychological harm.
- Train staff to recognise and act on signs of distress or risky behaviour.
1.7 Tailored intervention
Act when indicators of harm appear.
Compliant
In progress
Planned
Code requirement
1.7 Where operators are reasonably able to identify any indicators of harm for any player, they should
take a tailored and proportionate approach to intervention... including preventing further participation where necessary.
What we do
- Contact affected players with safer-play messaging and support options.
- Implement tighter limits, pauses or exclusions where warranted.
- Document all interventions to ensure consistent and fair treatment.
1.8 Signposting to support
Direct players to specialist help.
Compliant
In progress
Planned
Code requirement
1.8 Operators should signpost players to available support... including services such as Citizens Advice,
National Debtline, Samaritans, Mind, or other suitable support services.
What we do
- Publish links to independent support services on our website and safer-play pages.
- Include support information in emails relating to limits, exclusions or concerning behaviour.
- Encourage players to seek help early where they feel at risk.
1.9 Time between opening and closing a draw
Draw durations that support responsible play.
Compliant
In progress
Planned
Code requirement
1.9 Operators should ensure that an appropriate time period elapses between a prize draw opening and
concluding with a view to encouraging responsible play.
What we do
- Set opening and closing dates that avoid rapid “churn” of multiple entries.
- Clearly display countdown timers and close times on all competitions.
1.10 Instant win prize draws
Equivalence of free and paid routes, minority of total comps.
Compliant
In progress
Planned
Code requirement
1.10 Operators who offer instant win prize draws are expected to ensure compliance with, and equivalence
between, the paid and free-entry routes... Instant win prize draws should not form the majority of an operator’s total competitions.
What we do
- Apply the same odds and structure to both paid and free entry routes.
- Limit the proportion of instant win draws compared to scheduled competitions.
- Explain clearly on each instant win page how the free entry route works.
1.11 Marketing and advertising standards
CAP/BCAP compliance and social responsibility.
Compliant
In progress
Planned
Code requirement
1.11 Operators should ensure that all marketing and advertising of their prize draws is undertaken in
accordance with the CAP and BCAP codes and in a socially responsible manner, particularly protecting children
and vulnerable persons. Advertising should not present prize draws as a solution to financial problems.
What we do
- Review marketing content against CAP/BCAP guidance.
- Avoid any suggestion that competitions are a way out of debt or a replacement for work.
- Use age-appropriate targeting tools on social platforms.
2. Transparency
2.1 Clear rules and mechanisms
Explain how each prize draw works.
Compliant
In progress
Planned
Code requirement
2.1 For every variant of prize draw product offered by an operator, players should be provided with a clear
summary of how that prize draw will be conducted alongside the relevant rules and game mechanisms...
including a statement that the prizes are to be awarded in accordance with the laws of chance.
What we do
- Include key information and rules on every competition page.
- State that winners are selected at random in line with the laws of chance.
2.2 Fair award of prizes and random draws
Independent or verifiably random selection.
Compliant
In progress
Planned
Code requirement
2.2 Promoters should ensure prizes are awarded fairly... by an independent person or verifiable computer process
or certified physical drawing machine. Entries via free and paid routes must have equal chance of winning.
What we do
- Use a verifiable random number generator / drawing system for all draws.
- Treat all valid entries equally regardless of how they were submitted.
- Publish the draw method on our website.
2.3 Information about chances of winning
Ticket caps and comparable draw data.
Compliant
In progress
Planned
Code requirement
2.3 Where possible, prior to entering a draw, operators should provide players with clear and easily accessible
information regarding the likelihood of winning a prize and how prizes will be allocated...
What we do
- Show maximum tickets available and ticket numbers sold where applicable.
- Provide context using similar past draws where possible.
2.4 Free entry routes
Clear, prominent and genuine free entry options.
Compliant
In progress
Planned
Code requirement
2.4 Operators should clearly and prominently provide players with details of any “free entry” option(s) for
the prize draw before the point of purchase... Free entry routes should be effective and offer a genuine choice.
What we do
- Provide a clear “Free Postal Entry” section on relevant competition pages, before checkout.
- Ensure postal entries are treated equally and have sufficient time to be received before the draw.
2.5 Awarding prizes and no “low sales” changes
No downgrading, cancelling, or shifting dates for low sales.
Compliant
In progress
Planned
Code requirement
2.5 Operators should promptly provide the winning player with the advertised prize or a reasonable cash
alternative. They should not lower prize value, change draw date, or cancel a draw due to low ticket sales.
What we do
- Honour the advertised prize or a clearly defined cash alternative regardless of ticket sales.
- Keep draw dates fixed once published, except where external factors make this impossible.
2.6 Charitable contributions
Clear parameters and reporting of charity amounts.
Compliant
In progress
Planned
Code requirement
2.6 Operators who provide a charitable contribution as part of a prize draw are expected to outline clearly
the parameters... publish information on how much is given and meet the Code of Fundraising Practice.
What we do
- State clearly the percentage or fixed amount donated to charity for relevant competitions.
- Publish periodic updates on total funds raised and recipient charities.
3. Accountability
3.1 Monitoring compliance with the Code
Regular reviews and improvements.
Compliant
In progress
Planned
Code requirement
3.1 Operators should have processes and systems to monitor and regularly review compliance with this Code,
and take swift action where inadequacies are identified.
What we do
- Carry out regular internal reviews of processes against the Code.
- Update procedures and staff training where gaps are found.
3.2 Third-party compliance
Affiliates and partners must follow the Code.
Compliant
In progress
Planned
Code requirement
3.2 Operators should take reasonable steps to ensure that all relevant Code requirements are also followed
by third-parties such as affiliate marketers or draw-management partners...
What we do
- Include Code-compliance clauses in contracts with affiliates and partners.
- Review third-party activity and terminate relationships where serious non-compliance is found.
3.3 Sector collaboration
Sharing best practice with other operators.
Compliant
In progress
Planned
Code requirement
3.3 Operators should engage with other operators and work across the sector to share best practice in relation
to player protections, transparency and accountability.
What we do
Example: participate in industry groups, share learnings from our own safer-play measures, and adopt agreed-upon best practices where they improve protections for players.
3.4 Publishing our measures
Transparency on this page and related policies.
Compliant
In progress
Planned
Code requirement
3.4 Operators should publish all of the measures they have in place with regards to player protections,
transparency and accountability, ensuring their adherence with this Code is transparently displayed on their websites.
What we do
- Maintain this Code of Conduct page as a live record of our measures and status.
- Link to this page from key policy and safer-play areas of the site.
3.5 Working with DCMS
Keeping the Code fit for purpose.
Compliant
In progress
Planned
Code requirement
3.5 Operators are encouraged to work with the Department for Culture, Media and Sport on ensuring this
Code remains fit for purpose and sharing any learnings or challenges.
What we do
Planned: engage with DCMS and relevant bodies to provide feedback on practical implementation of the Code and support future improvements.
Note: The status badges above are for transparency only. We regularly review and update this page as our systems, policies and controls evolve in line with the Prize Draw Code of Conduct.