CORPORATE SOCIAL RESPONSIBILITY

Corporate social responsibility is about behaving responsibly towards employees, customers and society in general. The Group takes its responsibilities extremely seriously and is justifiably proud of its record in maintaining the highest ethical standards of corporate social responsibility in respect of all those who come into contact with our business.

RESPONSIBILITY TO OUR CUSTOMERS
The Group operates with six licences awarded under the G ambling Act 2005 (the ‘Act’). These licences encompass our UK-based pool betting, gaming and lottery businesses. One of the primary obligations under these licences is to treat customers fairly. To ensure that the obligations placed on the Group by the Act are adhered to, and in furtherance of our policy of maintaining the highest standards of compliance and integrity, the Group has a Director of Corporate Affairs who is responsible for ensuring compliance with the terms of the Act.

In addition, the Group employs a Security and Compliance anager whose primary role is to ensure that our customers are treated fairly, that our advertising is compliant with advertising standards and codes, that the young and vulnerable are prevented from accessing our products and that abuse and illegal behaviour are identified and stopped. All gaming products are subject
to age restrictions. Age verification software was introduced during 2005.

Our e-Gaming activities are outsourced to third-party providers and operate under the licences of those software providers.

The Group also actively promotes GamCare, the charity providing support to those suffering through a gambling problem, to its customers and £200,000 has been contributed to the Responsibility in Gambling Trust, GamCare’s major funder, and its predecessor body over recent years.

RESPONSIBILITY TO SOCIETY
The Group’s support for communities across the UK is virtually unparalleled; since the mid-1970s the Football Pools have contributed over £1.1 billion at today’s value to football, sport, the arts and charitable causes. Today the G roup generates over £1m per annum for charitable use through its management and operation of society lottery products.

The Group has for many years been the sole funder of the Foundation for Sport and the Arts (www.thefsa.net) which awards grants amounting to several million pounds each year. The Foundation’s goal is to increase active participation in sport and the arts, especially amongst young people and those with more ability than resources. Many communities, organisations and individuals in the UK have benefited from modest but critical training bursaries through to major capital projects.

In 2007, the Group changed the focus of its charitable donations specifically towards football charities and signed a deed with the four English and Scottish professional football leagues to direct donations of £5.9m towards football-related charities in the period up to June 2011.

Of the committed monies, £1.6m has been allocated to Premier League H ealth, a joint initiative between the Group and the Premier League, launched in February 2009. This initiative will see 17 of the clubs currently in the Premier League work with local health agencies such as Primary Care Trusts to engage with over 4,000 men. The project will aim to tackle issues as diverse as depression linked to unemployment, obesity and general poor physical health, as well as alcohol and drug addiction. It will target men aged 18 and above, with many clubs placing NH S health trainers within the stadiums themselves, taking referrals from local GPs. The project will also encourage men to play more sport and consider training to become football coaches themselves, or direct them towards other agencies that might be able to help.

We expect to make announcements regarding the balance of the committed monies over the next few months.

The Group also supports The Football Pools Trust, which addresses the needs of community football and augments the work undertaken through the deed with the football leagues. This Trust has awarded over £100,000 to a wide variety of smaller schemes during the year.

Specific donations amounting to nearly £3,000 were made in 2008 to a small number of charities. The Group also encourages employees to raise funds for local charities and supports those efforts where appropriate.

RESPONSIBILITY TOWARDS THE ENVRIONMENT
The Group recognises its responsibility to achieve good environmental practice and continues to strive for improvement in its environmental impact.

The nature of its business results in the principal impact arising from energy and paper consumption.

Wherever possible, waste consumable materials are recycled or disposed of in a manner most suitable to reduce any impact on the natural environment. The Group’s business practices also encourage environmental good practice and, through the increasing use of technology to facilitate information and data collection and dissemination, have led to reduced demand for paper resources.

All employees are encouraged to participate in the implementation of this policy and suppliers of consumable products are encouraged to be environmentally friendly, wherever practical.

REPSONSIBILITY TOWARDS EMPLOYEES

The Board is acutely aware of the vital contribution of employees to the future success of the business and recognises the importance of providing employees with information on matters of concern to them, enabling employees to improve their performance and make an active contribution to the achievement of the Group’s business objectives. This is accomplished through formal and informal briefings, meetings and the employee magazine. Employee representatives are consulted regularly on a wide range of matters affecting their current and future interests. The Group’s Investor in People accreditation reflects the progressive training and development programmes that are in place within the business.

The Group is committed to equality of opportunity and dignity at work for all, irrespective of race, colour, creed, ethnic or national origins, gender, marital status, sexuality, disability, class or age. It ensures that recruitment and promotion decisions are made solely on the basis of suitability for the job.

It is the policy of the Group to comply with the requirements of the Disability Act 1995 in offering equality of opportunity to disabled persons applying for employment, selection being made on the basis of the most suitable person for the job in respect of experience and qualifications. Training, career development and promotion are offered to all employees on the basis of their merit and ability. Every effort is made to continue to employ, in the same or alternative employment, and where necessary to retrain, employees who become disabled during their employment with the Group. The Group is an accredited Disability and Two Ticks employer.

The Group proactively addresses health and safety management and we have a programme of risk identification, management and improvement in place. The Board receives a report in respect of health and safety at each Board meeting, and is pleased to report that there was only one reportable minor incident during the 2008 financial year.

FTSE4GOOD
The Board was delighted to receive confirmation during the year that it had been independently assessed according to the FTSE4Good criteria, and had satisfied the requirements to become a constituent of the FTSE4Good Index Series. Created by the global index company FTSE Group, FTSE4Good is an equity index series that is designed to facilitate investment in companies that meet globally-recognised corporate responsibility standards. Companies in the FTSE4Good Index Series have met stringent social and environmental criteria and are positioned to capitalise on the benefits of responsible business practice.

http://www.ftse.com/ftse4good/index.jsp