Anti-Slavery and Human Trafficking

September 2020

1. Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the anti-slavery and human trafficking statement of Camelot Global Lottery Solutions Limited (‘Camelot LS’) for the financial year ending 31 March 2020. It outlines the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains and sets out our commitments for the next year to combat slavery and human trafficking risk in our business and supply chain.

Camelot LS is the leading solutions and technology provider to lotteries around the world, helping its customers to reach new players and deliver responsible growth through increasing engagement with the lottery brand, leveraging digital technology and providing new ways to play. Via its subsidiary, Camelot Illinois LLC (‘CILL’), it is also the private manager of the Illinois State Lottery under a contract running until October 2027.

As a responsible business, Camelot LS has a zero-tolerance approach to all types of slavery and human trafficking within its business and supply chains.

2. Our Supply Chain

In 2019/20, Camelot LS worked with around 400 suppliers, around 150 of which were suppliers to CILL. The majority of CILL’s supplier spend relates to IT and marketing and the majority of the rest of Camelot LS’ supplier spend relates to specialist technology providers. Suppliers are managed by Relationship Managers with support from Finance, Legal, HR and other colleagues as required.

Our suppliers are generally chosen based on the following criteria; 

  • Quality, completeness and scalability of the service
  • Management systems, processes and flexibility
  • Relevant service experience and track record
  • Diversity, sustainability, environmental and social considerations
  • Risk transfer and management
  • Cost and value for money

2.1 Third party due diligence

Camelot LS undertakes appropriate due diligence in respect of its supply chains. We do so when engaging with new suppliers, reviewing existing suppliers through periodic review meetings, annual supplier surveys and audits to ensure that our standards are being implemented, and to ensure that relevant legislation and regulations are complied with.

To determine the current level of compliance and provide ongoing assurance, Camelot LS has defined an internal audit/assurance schedule to review key controls, this will help to minimize or prevent quality or performance issues, manage compliance and assess current risk posture. Camelot LS has categorized suppliers into High, Medium and Low risk levels;

  • High – Annual review
  • Medium – once every three years or at the contract renewal
  • Low – Contract renewal

3. Our Policy Documents  

3.1 Whistleblowing policy

We encourage Camelot LS staff to report any concerns where the interests of others may be at risk. This forms part of our Whistleblowing Policy, which encourages Camelot LS’ staff and suppliers to assist Camelot LS in tackling any fraud, corruption, unlawful conduct or other malpractice (specifically including failure to comply with The Modern Slavery Act 2015) which may occur within either our organisation or that of our suppliers.

Part of Camelot LS’ strategy is to provide a way for concerns about malpractice to be raised in confidence. We comply with The Public Interest Disclosure Act 1998 (PIDA) and the guidance it provides for dealing with whistleblowing issues in a safe and constructive way. 

We will continue to communicate with our employees and suppliers on an ongoing basis to raise awareness of the Modern Slavery Act and Camelot’s commitments.

3.2 Code of conduct

The purpose of our Code of Conduct is to affirm our strong dedication to the highest standards of business conduct. It applies to all Camelot LS staff and it details the actions and behaviour expected  (i.e. acceptable and unacceptable behaviors) when representing Camelot LS. This also links to our Whistleblowing policy.

3.3. Training and Awareness 

It is important that all relevant staff are appropriately trained and kept up-to-date regarding the risks of modern slavery in our business and supply chains and that, where necessary, staff are given additional training.  Camelot LS documents and communicates via an e-learning platform for mandatory training modules and policy documents to uphold integrity and ethical values.

4. Focus for 2020

Camelot LS will continue to enhance Compliance training and internal and external audit processes to manage the risk of modern slavery.

We therefore plan in the coming year (and annually thereafter, updated as necessary) to ensure that all appropriate staff complete compulsory online training on the Modern Slavery Act.  The training will cover best practice and ensure that employees understand the appropriate action needed to monitor and prevent any instances of modern slavery or human trafficking risk.

5. Ongoing Commitment

An update on progress in the action areas outlined in this statement will be included in our statement in respect of the year ending 31 March 2021.

This statement has been approved by our Board, which will review activities and update this statement as necessary on an annual basis.