Code of Conduct for Cerberus Members
Part A: General principles
- Members should fulfil their contractual obligations with Operator Subscribers at all times, including by complying with brand and copy guidelines and other guidance provided to them by gambling operators from time to time.
- Members should only advertise gambling to customers in Cerberus Approved Markets, on behalf of operators (Licensees) that hold an operating licence issued by the Gambling Commissions or relevant bodies responsible for regulating gambling and supervising gaming law in Cerberus Approved Markets (Gambling Commissions).
- Members should conduct themselves as if they are bound (to the extent relevant) by the Gambling Commissions’ licensing conditions, codes of practice, such as the UK Gambling Commission’s Licence Conditions and Codes of Practice (LCCP) and also have regard the licensing objectives set out in any active Gaming Law in any Cerberus Approved Markets when advertising on behalf of Licensees.
- Members should ensure that all advertising of gambling is undertaken in a socially responsible manner, using LCCP Ordinary code 5.1.6(1)) found in the UK Gambling Commission’s LCCP as standard.
- Advertising in Cerberus Approved Markets should comply with local non-broadcast advertising, sales and direct marketing and any broadcast advertising codes, using as standard the UK’s Code of Non-broadcast Advertising, Sales and Direct Marketing (CAP Code) and the UK’s Code of Broadcast Advertising (BCAP Code) (LCCP Ordinary code 5.1.6(1)).
- Members should also follow an local gambling industry codes or Licensee required measures pertaining to socially responsible advertising, using as standard the UK’s Gambling Industry Code for Socially Responsible Advertising (LCCP Ordinary code 5.1.6(1)) and any relevant guidance issued by the Committee of Advertising Practice (CAP) and Broadcast Committee of Advertising Practice (BCAP) including the CAP and BCAP Guidance on the rules for gambling advertising, which contains a specific section on ‘misleadingness: free bets’ (LCCP Ordinary code 5.1.6(2)).
- Members should comply with data protection and privacy laws in all Cerberus Approved Markets in which they knowingly or unknowingly operate.
Part B: Specific principles
- Members should ensure that they do not place digital advertisements on websites providing unauthorised access to copyrighted content (using as standard the UK’s LCCP Licence condition 16.1.1).
- Gambling advertising should not appear on any primary web page/screen or micro site that provides advice or information on responsible gambling (using as standard the UK’s LCCP Ordinary code provision 5.1.8(1)).
- Members should take reasonable steps to prevent marketing communications being sent to consumers who they are aware or should be aware have self-excluded from the facilities offered by the relevant gambling operator or under any Multi-Operator Self-Exclusion Schemes (using as standard the UK’s LCCP Social responsibility code provision 3.5.3(2)).
- Members should ensure that they have appropriate technical and organisational measures in place to ensure that personal data is not processed unlawfully or without authority and is protected from accidental loss, destruction or damage, unauthorised use, disclosure or alteration (using as standard the UK’s Data Protection Act 1998).
- Members should ensure that any proposed transfer of personal data to a country outside the European Economic Area must be made only if that country ensures adequate protection for the rights and freedoms of consumers in relation to the processing of personal information or if contractual arrangements provide that protection (using as standard the UK’s Data Protection Act 1998).
- Members engaging in the capture of customer information for any purpose shall register with the local independent regulatory office dealing with local data protection law and/or the General Data Protection Regulation (EU), such as the Information Commissioner’s Office in the UK, to the extent required under data protection laws.
Part C: Cerberus Membership Principles & Commitments
- Members should act decently, fairly and reasonably at all times.
- Members should use reasonable endeavours and the tools provided to the through their Cerberus Membership to ensure that the information contained within gambling advertisements and marketing communications is accurate and does not include any material errors.
- Members should not engage in advertising practices designed (or likely) to mislead or dupe consumers into accessing gambling facilities or promotions without knowing that they will be doing so.
- Members should ensure that gambling advertisements and marketing communications are not directed at those aged below the legal gambling age in any Cerberus Approved Markets in which they knowingly or unknowingly operate.
- Members should clearly identify themselves as an advertiser on all gambling advertisements and marketing communications that they have instigated.
- All forms of content marketing should be easily identifiable as such.
- Members should seek to ensure that all gambling advertisements and marketing communications include reference to at least one local prevention and treatment charity, such as BeGambleAware.org in the UK, in print and broadcast media where it is feasible and practical to do so and that all gambling advertisements carry clearly a message indicating the minimum legal gambling age and above in any of the Cerberus Approved Markets that members operate in, an example being the ’18+’ symbol in the UK.
- When buying or renting personal data, members should satisfy themselves that the data has been properly sourced, permissioned and cleaned.
- Members are encouraged to have their staff participate in local events and activities arranged by the Cerberus Affiliate Foundation.
- Members are required to contribute to information gathering requests to any Cerberus-authorised organisation involved in research into the prevention and treatment of gambling-related harm, the development of harm prevention approaches and/or the identification and funding of treatment for those harmed by gambling.
- Members should keep themselves informed of relevant developments in any advertising and gambling legislation, regulations, appropriate guidance, license codes in any Cerberus Approved Markets in which they knowingly or unknowingly operate.
- Members are required to commit that all staff responsible for marketing communications can access and undertake training, testing and learning development activities made available to them through their membership and put into effect policies and procedures designed to ensure that their employees, sub-affiliates and agents co-operate with/adhere to this Code when advertising gambling to customers in Cerberus Approved Markets and ensure that all employees, sub-affiliates and agents are expected and required to adhere to those policies and procedures.
- Members are required to notify of and share with Cerberus Network staff any advertising and marketing communications activity that would be in breach of this Code in any Cerberus Approved Markets, whether conducted by their own business, a fellow member or any non-member.
- To ensure the development of the Cerberus Affiliate Foundation fund, Members are required to conduct any new commercial partnerships and affiliate relationships they undertake with Cerberus Operator Subscribers via Cerberus’ sub-affiliate tracking codes
- Members are required to carry the Cerberus Standard Mark on all of their websites, social media profiles and email communication.
- Members are required to complete necessary training requirements of all management staff within 6 months of membership approval in order to qualify for the Cerberus Gold Standard Mark.
- Members are required to complete necessary training requirements for all operational staff within 6 months of membership approval in order to qualify for the Cerberus Platinum Standard Mark.