Don’t take chances at your WLA RG certification

By Vidhi Sharma October 10, 2022 6 min read

Interview with the Chair of the Independent Assessment Panel - Anne Pattberg 

Every Lottery going through the association’s RG certification journey knows their submission will be assessed by the World Lottery Association (WLA) Independent Assessment Panel (IAP). When going through the process, many lotteries ask for support and for insights into how the IAP operates. To better understand the IAP’s role and how they go about evaluating a submission, Anne Pattberg, the Chair of the IAP panel, provides some insightful information for WLA Members, answering frequently asked questions about the IAP. 

DigitalRG: Let’s start with ‘who sits on the IAP’ with you? 

My two counterparts are Robert Ladouceur, Professor Emeritus at Laval University in Quebec renowned for his science-based approach to responsible gambling, and Henry Chan, former Executive Director of Hong Kong Jockey Club with over 35 years of industry experience. From my end, I’ve had extensive experience in sustainability and responsible gaming and have been the Sustainability Director at Camelot in the early 2010’s as well as the Chair of the WLA Responsible Gaming working group. 

DigitalRG: The journey for you first begins when the IAP receives the submissions. What happens to them next?

Anne: As soon as the WLA receives the submissions, either by the 1st of May or by the 1st of October, they are shared with the IAP. Then, with the other panel members, we decide how we will proceed with reviewing submissions. This is based on the number of submissions received, and sometimes there might be some particularities where one member will better understand the context in which the lottery operates. We, of course, avoid any conflicts of interest. For example, if one of us has worked with the lottery in the past. Each submission is reviewed by at least two panel members, and I as chair will review all submissions. submissions are always reviewed in full, not per section. 

DigitalRG: What happens if both assessors are not satisfied or do not agree on some aspects of the submission?

Anne: In the very rare cases the two reviewers cannot make a decision based on insufficient information, they will look for the advice of the third member of the IAP. They might also ask the lottery for clarifications or further information. 

DigitalRG: How much time does it take to review and evaluate all the submissions?

Anne: Normally, after 6-8 weeks, we come together, and through team discussions, we finalise our decisions on the submissions’ evaluation outcomes. The final call lies with me as the chair on any differing views; however, this is very rare as we are almost always aligned in our decisions. This timeframe will also depend on the number of submissions. As these have increased over recent years, this time frame has been extended. 

DigitalRG: What do you expect from a submission, and do you ever decline them?

Anne: We do not decline decisions per se, but we cannot assess submissions when there is a lack of context, consistency or information. This might inhibit proper communication about initiatives, and makes it very difficult to assess. We merely find this issue with the level 2 and 3 submissions, where the lottery has an RG programme, but they have not communicated about it clearly and concisely in their submission. 

One key element of any submission is to provide context for the IAP’s understanding.  For example, by ensuring that all evidence is given context and can be related directly to the practices discussed in the submission. Furthermore, it is also important to give context and background of the lottery so that the IAP has a more comprehensive understanding of the context in which you operate. 

However, ultimately the IAP should also be able to make an evaluation purely based on the submission. The evidence is used to support and should not be relied upon to provide vital information. When part of the submission is unclear, or we deem there is not enough information, we dig deeper and go to the evidence. 

DigitalRG: What is the most common case of a submission not being able to be assessed, and how can members avoid this?

Anne: For level 2 or 3, a common mistake is a lack of clear communication about what the lottery is  doing in their programme. In most cases it is not that the lottery is not doing enough.  For these levels, I would encourage focusing on communicating current actions and practices and gaps and opportunities. We don’t expect the lottery  to be perfect, but we expect them to understand where they need to improve. 

We have also noticed that there is sometimes a misalignment between the level of ambition and the actual level a lottery is submitting for. This happens mostly when lotteries want to move from Level 2 to Level 3. The transition from planning to the implementation can be challenging. To advance to Level 3, we need lotteries to show evidence and explanation of what has been implemented and a solid improvement plan.

For moving from Level 3 to Level 4, lotteries sometimes fail to demonstrate how they assess whether their Responsible Gaming programme is working. A common comment that we provide is that lotteries need to show their initiatives' effectiveness, what is and what is not working, and how they are building on these findings to improve their programmes. At Level 4, we are also looking to see how well RG has been integrated into the everyday commercial activities of your lottery. These should be at the core of everything you do, not just in a separate RG programme that is untied from their commercial or strategic planning..

And finally, the structure. Express each section clearly and limit yourself to the maximum 125 pages as stated in the requirements. 


3 tips to increase your chances of a successful certification.

  1. Create a clear structure and context that provides all the information the IAP needs to evaluate the submission. 
  2. Measure the effectiveness of your RG programme and its actions and build on areas that are showing gaps. 
  3. Always refer to previous comments from the IAP to ensure they have been addressed or taken into consideration in the submission.


Our core belief is that all National Lotteries should do their part in providing an equitable solution for society and the environment. This starts with understanding, planning, and acting on those beliefs. is a digital platform that saves you time. Our proven process takes lotteries from assessment to achieving any ESG, CSR, Responsible Gaming & sustainability certification easily and well. Sustainability is a journey. However, there is no need to reinvent the wheel to be the most effective. aims to make your sustainability journey as impactful and efficient as it can be. 


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