
Voluntary Code Advisory (Prize Draws)
The Voluntary Code of Good Practice for Prize Draw Operators, published by the Department for Culture, Media and Sport (DCMS), sets out enhanced expectations for player protection, transparency, and operator accountability across the UK prize draw sector.
Although non-statutory, the Code is increasingly referenced by stakeholders, including the media, as the benchmark for responsible operation.
Our Voluntary Code Advisory & Audit Service provides independent, proportionate support to help operators assess, implement, and evidence alignment with the Code in a credible and defensible manner.
Framework
The service is delivered using eGaming Integrity’s Voluntary Code Audit and Compliance Framework, aligned directly to the structure and intent of the DCMS Code.
The framework is built around the Code’s three core pillars; player protections, transparency and accountability.
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Controls to prevent harm, protect under-18s, and manage behavioural risk
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Clarity of free entry routes, draw mechanics, odds or probability proxies, and prize fulfilment
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Governance, internal oversight, affiliate controls, monitoring, and reporting
Each review is scoped proportionately, reflecting the size, complexity, and risk profile of the operator.
Methodology
A risk-based audit methodology is applied, consistent with established internal audit and assurance principles.
The review typically includes:
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Pre-assessment document review and structured evidence requests
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Interviews with personnel responsible for compliance, operations, marketing, and customer support
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Testing of key controls covering player protections, free entry processing, draw execution, marketing governance, and complaints handling
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Assessment of control design, implementation, and operational effectiveness
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Clear documentation of findings, risks, and remediation actions
Where advisory support is provided (for example, readiness or remediation), this is clearly separated from any independent assessment.
Delivering Credible Assurance
The service is designed to move beyond high-level statements of compliance and provide objective, evidence-based assurance.
It delivers value because it:
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Is aligned directly to the DCMS Voluntary Code and its underlying intent
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Applies a structured, risk-based audit methodology
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Produces clear, prioritised findings and practical remediation
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Generates defensible outputs suitable for boards, partners, and stakeholders
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Maintains independence, objectivity, and proportionality
The result is a clear, credible assessment of how effectively an operator meets the expectations of the Voluntary Code, and what actions are required to strengthen alignment.