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eCOGRA COMPLIANCE COMMITTEE REPORT ON JACKPOT FACTORY SEARCH ENGINE ISSUE
eCogra Press Release
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On 28 July 2006 the Compliance Committee of eCommerce and Online Gaming Regulation
and Assurance, made up of Mr. W. Galston OBE (Chairman) , Mr. F. Catania and Mr.
M.Hirst OBE, all independent directors of the organization, considered all the facts
regarding an incident in which complaints were received concerning search engine
optimisation practices being conducted by the Jackpot Factory group. The Committee
received a report of an independent and on-site investigation which had been carried
out by external auditors. This covered the circumstances surrounding the issue,
its causes and effects and the remedial actions taken by the company. The Committee
findings are that:
1) The nature and tenor of the Jackpot Factory search engine optimisation project
was totally unacceptable because of the fictitious and misleading scenarios it portrayed.
This had resulted in widespread public disapproval of the campaign.
2) However, there was no evidence to show that any individual or group of individuals
were harmed or persuaded to indulge in potentially harmful behaviour by the campaign,
which represented an important mitigating factor.
3) Similarly, there is no evidence to suggest that Jackpot Factory management had
any deliberate intention to encourage vulnerable persons to participate in gambling
activities at group casinos
4) The investigating team report indicates that it is satisfied that the Jackpot
Factory claim to have outsourced the project initially is correct. However, the
report finds, and Jackpot Factory management conceded that the company's supervision
of the project was inadequate.
5) The report confirms that internal disciplinary action taken by the company against
those responsible was appropriate.
6) The Committee also considered the more positive aspects of the case and in particular
the actions of Jackpot Factory in the immediate aftermath of the issue coming to
public attention. On two occasions the company admitted fault in the matter and
offered public apologies. Management backed this up by re-directing company resources
and mounting a committed and energetic exercise to track down every element of the
campaign that could be found in order to remove it, at the same time urging the
public to report any elements discovered so that these could be addressed.
7) Jackpot Factory management cooperated fully with the independent investigation
team, presenting verbal and documentary evidence without reserve to assist in its
investigations.
8) Jackpot Factory management has since deployed control improvements in its systems
as suggested by the investigation team, which will guard against any repetition
of this unfortunate incident. Processes are now in place to ensure that any further
material that
may surface as a result of this campaign is dealt with on a timely
basis.
9) Evidence was produced showing that the damage to business and reputation suffered
by Jackpot Factory was substantial, as a consequence of public disapproval and the
suspension of the Play It Safe seal.
10) Before the incident, Jackpot Factory had a solid reputation for compliance with
all eCOGRA standards and requirements.
Having considered all of the above, the Compliance Committee has made the following ruling: The suspension of the "Play It Safe" seal is lifted, but Jackpot Factory
will be subjected to increased eCOGRA monitoring to ensure compliance with the new
content code of practice. This is to ensure that all remaining traces of the campaign
are removed wherever this is possible. The Compliance Committee is aware of the
existence of inactive search engine links, but is satisfied that these do not provide
access to any offensive material. The removal of this type of link is solely under
the control of the search engines. The Committee wishes to thank all those representing
players' interests for their comments during the initial complaints and throughout
the investigation. It also notes that the investigation team received the full cooperation
of the Jackpot Factory management and is satisfied that they have shown their determination
that this should not happen again. The goal of eCOGRA in incidents such as this
is to remove the immediate cause and potential for harm as quickly as possible,
and then through fair and factual investigation isolate the reasons and ensure that
systems are in place to guard against any repetition. These objectives have, in
the opinion of this Committee, been met. |
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