What is an External Lottery Manager?
ELMs are commercial companies that manage lotteries and provide services to society and local authority lotteries.
An ELM is defined in section 257 of the Act as someone that makes arrangements for a lottery on behalf of a society but is not a member, officer or employee of the society or local authority. A society or local authority and an ELM must be separate entities and be able to demonstrate that they are independent of each other.
Lotteries within Great Britain are the preserve of good causes and as such the Act did not intend ELMs to be primarily a vehicle to create profit for commercial organisations; rather, the intention was to enable societies and local authorities to raise funds for their own non-commercial purposes.
An ELM must be licensed by the Gambling Commission.
An ELM must hold a lottery manager operating licence issued by the Commission before they can promote a society or local authority lottery.
All ELMs licensed by the Commission to run lotteries on behalf of societies and local authorities are required to comply with specific conditions and codes of practice relevant to them. The specific licence conditions are set out at the time a licence is issued and are printed on the licence
It is the responsibility of both the society and the ELM to ensure that the other party holds the relevant operating licence before they enter into any arrangements regarding the promotion of lotteries.
Some of the licence conditions and codes of practice applicable to ELMs .Specific details are contained in the Licence conditions and codes of practice (LCCP).
The Act allows a society or local authority lottery to employ an ELM to manage all or part of its lottery on its behalf. The intention of these provisions is relatively limited in scope: they are designed to do nothing more than to allow a society to ‘outsource’ the running of a lottery to a third party.
Even though the society has outsourced a service to an ELM, both the society and ELM are responsible for that service.
Social Responsibility
Lotteries are a form of gambling and as such ELMs are required to ensure that children and other vulnerable people are not harmed or exploited by the lotteries they manage. Societies have the same requirements placed on them.
Further information about social responsibility requirements is available in the LCCP.