FDJ is fully committed to reducing the risks linked to the integrity of its activity, so as to be exemplary and to reinforce confidence in its gaming model. To that end, it rolls out and ensures compliance with its rules among its stakeholders.
Fighting fraud and money laundering
FDJ’s actions have three areas of focus:
The assessment of the risks of money laundering and terrorist financing takes place from the game design phase and from the implementation of new services. It is within this framework that the Group has implemented a system for monitoring internal procedures.
Training and empowering employees and distributors is also one of the keys to risk prevention. FDJ has conducted a training campaign to fight fraud and money laundering for employees and salespeople. In addition, FDJ deployed a network of antimony laundering liaison officers in the commercial sectors in 2019.
These liaison officers were trained to exercise their responsibilities and play their role in relaying information on the anti-money laundering system across the offline distribution network.
The monitoring of financial transactions (at points of sale and online) can serve to identify atypical situations. Enhanced investigations may result in a suspicious event being reported to Tracfin (the French agency tasked with preventing money laundering and the financing of terrorism).
Inspections of points of sale helped verify compliance with regard to security, behavioural, commercial, contractual and regulatory aspects. FDJ identifies and checks the identity of players whose wagers exceed €2,000 per ticket.
In addition, distributors, the sales force and the relevant employees will also be trained in combating fraud and money laundering.
FDJ ensures the security and confidentiality of all company data, including personal data, against potential security breaches.
Application of the EU’s General Data Protection Regulation (GDPR), which largely unifies the laws on data protection in Europe, has been mandatory since 25 May 2018. FDJ has implemented the new regulation, and aims both to both maintain compliance and anticipate legal and regulatory developments in the field of personal data protection with a view to optimising the transparency of the processing of personal data and factoring in players’ expectations.
The FDJ Group also protects the anonymity of prize winners by paying close attention to the conditions for storing and restricting access to data concerning them. It notably guarantees anonymity with respect to any external third party, in particular the media for reports on big prize winners.
The Group’s ethics charter, adopted in July 2017, forms the basis of the FDJ Group’s ethics and compliance policy. It affirms the Group’s collective commitment to promoting its values and helps guide individual behaviours in line with the fundamental principles of compliance with laws and regulations, the sharing of a culture of integrity, respect for employees, customers, partners and external stakeholders, and the engagement of a constructive dialogue with civil society.
Within this framework and in accordance with the law of 9 December 2016 on transparency, the fight against corruption and the modernisation of the economy (Sapin II), the FDJ Group advocates a principle of “zero tolerance” and has implemented a structured system, as well as awareness-raising, training and support initiatives for employees to the highest standards of business conduct.
Focus on anti-competitive practices: FDJ operates under exclusive rights (online lotteries, point-of-sale lotteries, point-of-sale sports betting) as well as in open competition (online sports betting) in the classic gaming sector. In recent years, the Group has diversified its activities and launched initiatives in new competitive and/or developing markets, namely eSport, online entertainment games and the provision of services to sports betting operators. The contrast within its activities entails greater risks with regard to competition law, especially the potential abuse of a dominant position, given the monopoly enjoyed in the vast majority of its activities.
Combating match fixing
The FDJ Group is strongly mobilised in the fight against match fixing around the world (often linked to fraudulent betting). Decree 2019-1060 of 17 October 2019 consolidates the tasks entrusted to the Company by the government, notably with regard to the installation of the tools necessary for the detection of atypisms in the taking of bets and prevention programs featuring sports players.
As a sports betting operator, it is committed to two main areas in the defence of the integrity of sport and sports betting: prevention and the monitoring of sporting competitions and betting within the National Platform for Combating Match Fixing, but also internationally with players in the sporting movement, international bodies and world lotteries.
A broad plan to promote the integrity of sporting competitions has been implemented on several fronts. The Group carries out internal awareness-raising and training initiatives to combat match fixing through regular communication with all employees and specific training for employees working directly or indirectly on sports betting.
Since 2014, the FDJ Group has been a signatory of business mediation organisation Responsible Supplier Relations Charter, from the Médiation inter-entreprises , the aim of which is to raise awareness about responsible purchasing challenges and the quality of customer-supplier relationships among economic operators. As part of a continuous improvement of purchasing practices, FDJ aims to obtain the “Supplier Relations & Responsible Purchasing” label awarded by Médiation inter-entreprises and the National Purchasing Council. This label is an extension of the principles laid down in the Charter. It aims to distinguish companies and public entities whose practices demonstrate sustainable and balanced relationships with their suppliers.
To lead by example, FDJ has undergone an Ecovadis CSR evaluation; its score of 70/100 places (as of December 2019) it among the 5% most responsible companies worldwide.
The FDJ Group also promotes purchases from companies that employ people with disabilities. In 2018, it spent €749 thousand to purchase services from ESAT (Establishments for the Services of Assistance through Work) and EA (Adapted Enterprises).
La Française des Jeux has established a mediation procedure, accessible to all of its suppliers in the event of a dispute, in connection with:
- ● The order of 11 March 2015, which encourages companies to use amicable methods of settling disputes, including mediation,
- ● Its responsible purchasing approach, illustrated by the signing of the Responsible Supplier Relations Charter in December 2014.
Pour rappel, la médiation est un mode de résolution amiable des différends liés à l’exécution d’un contrat, basé sur l’intervention d’un tiers, dès lors que deux ou plusieurs parties, dans le cadre de ce différent, ne sont pas arrivées seules à un accord.
Mediation is a means of amicable resolution of disputes related to the performance of a contract, based on the intervention of a third party, where two or more parties to the dispute have failed to reach an agreement on their own.
It is a structured but non-rigid process aimed at creating or recreating a bond, and restoring trust and business relationships between the parties involved in the dispute.
It is also a voluntary process that relies on the freedom and responsibility of individuals, in strict confidentiality.
If either party is not satisfied with the procedure, each party remains free to terminate it at any time and to resort to another means of resolution.
In this context, La Française des Jeux has appointed as Inter-company Mediator: Olivier de LAITRE, qualified mediator.
The mediator’s main tasks are as follows:
- ● Promote the search for an amicable solution to disputes;
- ● Inform the parties in writing of the initiation of a mediation procedure, informing them of the confidentiality of all exchanges;
- ● Undertake to study the case in the light of the respective positions of the parties and to assess the arguments of each of them in order to help them find an amicable, balanced and definitive solution to the dispute;
- ● Meet each party if necessary, either together or separately;
- ● Propose for the consideration of the parties those procedures or means that appear to him to offer the best chances of reaching a resolution;
- ● Record the outcome of the mediation, either by the supervision of a written or oral agreement between the parties, or by noting the failure of the mediation and notifying the two parties of the failure so as to terminate the procedure.
The Inter-company Mediator can be contacted directly by writing to: email@example.com