1. PURPOSE

This policy establishes the processes and systems used by Hittin It Big Competitions (“the Company”) to monitor and regularly review compliance with the Voluntary Code of Good Practice for Prize Draw Operators (“the Code”), published by the Department for Culture, Media and Sport (DCMS).

The Company is committed to operating to the highest standards of fairness, transparency, and player protection, and to taking swift action where any inadequacies or improvements are identified, in line with clause 3.1 of the Code.

2. SCOPE

This policy applies to all aspects of the Company’s operations covered by the Code, organised under its three sections:

• Player Protections — age verification, complaints handling, payment limits, spend controls, account suspension and self-exclusion, harm monitoring and intervention, signposting, draw duration, instant wins, and marketing standards.
• Transparency — draw mechanics, fair allocation of prizes, odds disclosure where possible, free entry route, prize fulfilment, and any charitable contributions.
• Accountability — internal monitoring, third-party oversight, sector engagement, and public disclosure of compliance measures.

Data protection obligations under the UK GDPR and Data Protection Act 2018 are handled separately under the Company’s Privacy Policy and remain outside the scope of this Code-specific policy.

3. RESPONSIBILITIES

Compliance Officer

The Director acts as the designated Compliance Officer with overall responsibility for:

• Maintaining and updating this compliance monitoring policy
• Conducting regular compliance reviews
• Reporting compliance status to relevant stakeholders
• Implementing corrective actions when issues are identified
• Staying informed of regulatory changes and industry best practices
• Engaging with DCMS and any delegated industry body on Code-related matters (clauses 3.3 and 3.5)

Team Members and Contractors

All team members and contractors involved in the Company’s operations are responsible for:

• Operating in accordance with the Code and Company policies
• Reporting potential compliance issues to the Compliance Officer without delay
• Supporting compliance reviews and audits where requested

Third Parties

In line with clause 3.2, the Company takes reasonable steps to ensure relevant Code requirements are also followed by third parties supporting its prize draw operations (for example, affiliate marketers or draw-management partners). Compliance expectations are managed through contractual arrangements, and the Company reserves the right to terminate relationships with third parties who fail to comply.

4. MONITORING ACTIVITIES

4.1 Continuous Monitoring

The following activities are monitored on an ongoing basis:

• Customer complaints and resolution times
• Draw execution logs and audit-trail integrity
• Age verification outcomes
• Self-exclusion, account-pause, and spend-limit requests
• Website content accuracy and promotional compliance
• Indicators of potential player harm (clauses 1.6 and 1.7)

4.2 Periodic Reviews

5. ANNUAL COMPLIANCE CHECKLIST

Each annual audit assesses compliance against the three sections of the Code:

1. Section 1 — Player Protections (clauses 1.1–1.11): Review age verification, complaints handling, payment limits, spend controls, suspension and self-exclusion tools, harm monitoring and intervention processes, support signposting, draw duration policies, instant-win compliance, and marketing standards.
2. Section 2 — Transparency (clauses 2.1–2.6): Verify draw mechanics and audit trails, confirm equal chance of winning across paid and free entry routes, confirm odds disclosure where applicable, review free entry route prominence, verify prize fulfilment record, and review any charitable contribution disclosures.
3. Section 3 — Accountability (clauses 3.1–3.5): Review internal monitoring outcomes, third-party compliance arrangements, sector engagement, and the accuracy and accessibility of publicly published compliance measures.

6. ISSUE IDENTIFICATION & REMEDIATION

6.1 Identifying Issues

Compliance issues may be identified through:

• Scheduled reviews and audits
• Customer complaints or feedback
• Reports from team members or contractors
• Industry alerts or regulatory updates from DCMS
• Third-party audits or assessments

6.2 Issue Classification

6.3 Remediation Process

1. Document: Record the issue, root cause analysis, and potential impact
2. Contain: Take immediate steps to prevent further harm if applicable
3. Correct: Implement fix or process change
4. Verify: Confirm the issue has been resolved
5. Prevent: Update procedures to prevent recurrence
6. Report: Document actions taken and lessons learned

7. RECORD KEEPING

The following compliance records are maintained:

• Compliance review reports and audit findings
• Issue logs with remediation actions and timelines
• Draw audit trails (including pool-based draw audit records introduced in May 2026)
• Complaints register with outcomes
• Policy version history

Audit and operational records relating to compliance are retained for a minimum of three years. Records containing personal data are held only for as long as necessary for their stated purpose under the Company’s Privacy Policy and applicable data protection law.

8. CONTINUOUS IMPROVEMENT

The Company is committed to continuous improvement of its compliance framework. This includes:

• Regular review of industry best practices and peer approaches
• Engagement with other operators and sector initiatives in line with clause 3.3
• Proactive updates based on DCMS guidance and any delegated industry body
• Acting on customer feedback to improve processes
• Annual review of this policy for effectiveness