Applicant & Employee Screening Policy

Les Ambassadeurs Club Limited (Les A) is committed to best corporate governance practices. The Les A Board is responsible for establishing policies and procedures to enable compliance within its operational business. Each Director of the Les A Board shall exercise independent judgment and act honestly and in the best interests of the Company. The Les A Board is also committed to exercising effective governance over the Company’s affairs and to balance the respective interests of the Company’s stakeholders (including its shareholders, employees and customers) and also of the broader community.

Les A is committed to:

Les A will ensure that its employees are aware of and comply with the licensing objectives and will deal with the Gambling Commission in an open and cooperative way. We are committed to socially responsible gambling and have adopted and support the Playing Safe initiative introduced by the National Casino Forum. The policies and procedures we have in place are in accordance with the three licensing objectives of the Gambling Act 2005:

Les A operates through its Club Rules, policies that have been approved by the Board of Directors, Procedure Manuals and an Employee Handbook.

Les A has internal procedures in place to ensure that its business is conducted in compliance with all relevant primary and secondary legislation and regulatory guidance. The Company will ensure that all procedures are communicated to all appropriate staff and personnel who are required to hold a Gambling Commission Personal Licence have the requisite competency for the licence held and the responsibilities associated with that position. Les A has well established staff practices and procedures in place, including procedures for staff to report grievances or suspected regulatory breaches through a Whistleblowing policy.

Regular reviews of the effectiveness of all policy and procedures are carried out in addition to audits periodically undertaken by the Internal Audit function of Les A. A suitably qualified third-party resource is engaged to review Les A policies and procedures on an annual basis which provides the Board and the Regulatory Compliance Committee with the necessary assurance regarding the operating effectiveness of the organisation’s controls.

We believe that a well-structured and organised corporate business with well-trained management and staff is essential to our success. We will deliver this success within the UK gambling legislative framework, working with our regulator through our management and compliance departments.

Kevin McGowen
Chief Executive Officer
Les Ambassadeurs Club

1. Introduction
2. Scope
3. Policy Elements
4. When will we conduct applicant or employee screening
5. Our Company’s responsibilities
6. What will happen if screening returns adverse results?
7. Procedure

Our employee screening policy refers to our guidelines for screening employees and applicants’ backgrounds, as part of both our hiring process and an ongoing assurance of the integrity of Les A employees.

Screening ensures that we can:

This employee background check policy applies to all applicants and employees, existing and newly employed who go through or have gone through our company’s recruitment process.

Background checks may include:

Applicants aren’t necessarily required to pass every type of background check we offer before our company hires them. Each position has its own requirements. For example, driving records may be relevant to drivers, but not to croupiers.

The basic background screening includes [Identity documentation, screening through third party service providers, open source media outlets and reference checks.]

We confirm compliance with legal and equal opportunity guidelines at all times.

Criminal records, criminal association, adverse media and problem gambling association checks are essential if applicants are interviewing for positions where they will:

PFL holders:

Key position personnel (PML):

In most cases, screening will be completed during the application or on boarding process and then again on an annual basis.

These screening checks will be completed by the Compliance and HR departments and reports will be securely held in line with the requirements imposed by both the Data Protection Act 2018 (DPA) and the General Data Protection Regulations (EU 2016/679) (GDPR).

Departmental Heads /Managers, Compliance and HR staff in association with the Data Protection Officer (DPO) (where applicable) must:

Adverse or concerning results do not automatically disqualify applicants from the application process or result in disciplinary action towards employees.

A risk assessment will be completed, on a case by case basis according to the following criteria:

HR and Departmental Heads /Managers should keep the company’s interests in mind when rating the seriousness of any issues arising from the screening process.

Ultimately, during recruitment, if Departmental Heads /Managers and/or HR decide a particular applicant would bring high or unreasonable risk to our company, the outcome may reasonably be, that the application will be rejected.

With respect to existing employees, the company staff handbook and company disciplinary polices may be considered and or implemented as a result of findings deemed, to potentially cause harm or a high risk.

HR and Departmental Heads /Managers may contact applicants or arrange private meetings with employees to discuss the results of their screening checks and in cases of minor issues and if the applicants or employees answer honestly when questioned, they may still be employed or that no further action is required.

Our aim is to have a transparent screening process that respects every individuals’ rights.

We ensure an informed work force through clear information being provided and to all who may be affected by the Employee Privacy Policy.

Departmental Heads /Managers and HR staff will follow this procedure for screening: