Raffle House response to Lotteries Council demand for parity with prize draws

The Lotteries Council is asking the government to ‘level the playing field’ between charity lotteries and prize draws, but these are two different products. It’s also worth noting that any company currently operating in the regulated gambling space could adapt its model to fall outside the Gambling Act 2005’s definition of gambling by offering a free entry option, as we do.

Comments from James Mieville, Executive Director of Raffle House, in response to the report:

“We fully comply with legislation related to operating under the free draw model and all of our competitions offer a free entry option that is displayed as prominently as the paid entry option, in line with the Gambling Act 2005. We believe this eliminates any potential for players to be misled into thinking we are a regulated gambling product or a lottery, as the report produced for the Lotteries Council suggests may be the case.

“We believe our customers are fully aware of what type of business we are running and do not feel there is any confusion among consumers about the difference between our prize draws and lotteries.

“While some may believe that prize draws pose unfair competition to lotteries, entertainment companies generally face increasing competition from a variety of business models and there’s room for many different types of companies offering the chance to win prizes.

“The report produced by nfpResearch for the Lotteries Council is incorrect in stating that Raffle House entered the market after Omaze. It has been active in the UK market since 2017.

“The nfpResearch report claims that prize draws primarily benefit larger charities. This is completely untrue of Raffle House’s draws. We now have 18 charity partners, almost all of which are small charities. We believe we are, in fact, helping small charities greatly by stepping in to fill a funding gap that has become more acute in recent years due to the cost-of-living crisis and the closure of many grant programmes.

“As a business, we’ve always gravitated towards supporting smaller organisations. Among our reasons is a desire to offer corporate partnerships to charities without the enormous marketing and fundraising resources that are often needed to find donors. We believe the charities we support would suffer if the regulations that govern prize draws were changed, and indeed the report acknowledges this risk.

“The report also states that ‘evidence does not currently support the thesis that prize draws are yet supplanting charity lotteries in the scale of the sector’s fundraising’. In fact, evidence suggests charity lotteries are thriving – earlier this year Gambling Commission CEO Andrew Rhodes said large-scale society lottery sales had passed the £1 billion mark for the first time.

“If charity lotteries are doing better than ever and there’s no evidence that prize draws are impacting lotteries’ fundraising, doesn’t it follow that we and other prize draw operators are simply providing additional funds for charities that desperately need them? Isn’t that something to be celebrated rather than shut down, particularly in light of the fact there’s no obligation for prize draw companies such as ours to make any contribution to charities; we do so out of choice. It’s highly likely that all of the policy suggestions set out in the report would lead to less money going to the charities currently supported by prize draws.”