Governance Policies

These governance polices shall be adopted by the Scottish Croquet Association (SCA) Executive Committee and key Volunteers. Unless otherwise stated, “volunteers” refers to all SCA Officers, SCA Executive Committee members, SCA members with delegated SCA responsibilities (such as sub-committee members), and all other volunteers.

Code of Conduct

In addition to SCA policies and procedures, the following standards and requirements apply to all volunteers as part of their duties while acting for the SCA. The SCA believes that these are reasonable standards to expect and that they are a reflection of good and professional governance practices. These standards are set out in this Code of Conduct for the avoidance of doubt and, where concerns arise, as a benchmark against which SCA volunteers’ conduct and misconduct can be measured. Failure to abide by these standards may result in disciplinary action.

  1. Volunteers are required to maintain satisfactory standards of performance in their duties, including a high level of quality, accuracy, and diligence.
  2. Volunteers are required to take all necessary steps required to safeguard the SCA’s public image and preserve positive relationships with its members, the public, and outside agencies.
  3. Where applicable, volunteers are required to ensure that they understand the health and safety procedures pertaining to the clubs and premises they are operating in.

Conflict of Interest Policy

All volunteers will strive to avoid any conflict of interest between the interests of the SCA on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.

The purposes of this policy are to protect the integrity of the SCA's decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of volunteers, staff and committee members.

Examples of conflicts of interest include:

  • An Executive member who is also an SCA member who must decide whether fees from SCA members should be increased.
  • An Executive member who is also on the committee of another club that is competing for the same funding or resource.
  • An Executive member who has shares in a business that may be awarded a contract to do work or provide services for the organisation.
  1. During the SCA induction process, each Executive member will make a full, written disclosure of interests, such as relationships, and posts held, that could potentially result in a conflict of interest. This written disclosure will be kept on file by the SCA Secretary and will be updated as appropriate.
  2. In the course of meetings or activities, committee members will disclose any interests in a transaction or decision where there may be a conflict between the organisations best interests and the committee member’s best interests or a conflict between the best interests of two organisations that the committee members is involved with.
  3. After disclosure, individuals must understand that they may be asked to leave the room for the discussion and may not be able to take part in the decision depending on the judgement of the other committee members present at the time.
  4. Any such disclosure and the subsequent actions taken will be noted in the minutes.
  5. This policy is meant to supplement good judgement, and volunteers should respect its spirit as well as its wording.

Whistleblowing

The SCA is committed to the highest standards of openness, probity and accountability and we expect all volunteers to maintain high standards in accordance with our Code of Conduct. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring or to address them when they do occur. This policy applies to all individuals volunteering at all levels of the organisation, and all members of the SCA.

  1. Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers in the Governing Body. This may include:
    • Miscarriages of justice;
    • Bribery;
    • Failure to comply with any legal obligation or regulatory requirements;
    • Dangers to Health & Safety or damage to the environment;
    • Criminal activity;
    • Financial malpractice or impropriety or fraud;
    • Negligence;
    • Breach of our internal policies and procedures [including our Code of Conduct];
    • Conduct or improper behaviour likely to damage our reputation;
    • The deliberate concealment of any of the above matters.
  2. It is not necessary to have proof before making a disclosure. A reasonable belief that one of these qualifying offences has been, or will be, committed is sufficient. However, anyone raising a claim must:
    • Make the disclosure in good faith;
    • Reasonably believe that the information is substantially true;
    • Not act for personal gain; and
    • Act reasonably.
  3. In many cases you will be able to raise any concerns with an SCA Officer, either verbally or in writing if you prefer. They may be able to agree a way of resolving your concern, although in some cases they may refer the matter to the Whistleblowing Officer. If the matter is more serious or you feel that the SCA Officer concerned has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact the SCA Whistleblowing Officer.
  4. The SCA Whistleblowing Officer will by default be the SCA Chairman, unless otherwise agreed by the SCA Executive Committee.
  5. The SCA Officer first approached will arrange a meeting with you as soon as possible to discuss your concern raised. You may bring another representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.
  6. We will treat all disclosures in a confidential and sensitive manner and we hope that individuals will feel able to voice whistleblowing concerns openly under this policy. However, if you would prefer to raise your concern confidentially we will make every effort to keep your identity secret so long as it does not hinder or frustrate any investigation.
  7. The SCA aims to encourage openness and will support volunteers or members who raise genuine concerns under this policy, even if they turn out to be mistaken. Volunteers or members should not suffer any detrimental treatment as a result of raising a concern, for example threats or other unfavourable treatment. If you believe you have suffered any such treatment, you should inform the Whistleblowing Officer immediately, or raise it formally using our Grievance and Disciplinary Procedure.
  8. If it is concluded that a whistleblower has made false allegations maliciously or with a view to personal gain, the whistleblower will be subject to disciplinary action.
  9. You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action.

Anti-Corruption (Sports Betting) Policy

Introduction

  1. All SCA Volunteers have a moral obligation to maintain the highest standards of integrity by carrying out their work in a way that will not compromise the reputation of the organisation.
  2. This policy sets out the SCA’s standards and procedures relating to Anti-Corruption (Sports Betting) and applies to all individuals representing the SCA, which includes SCA Executive members and all employees, contractors, consultants, and/or related personnel of the SCA acting in any capacity or activity sanctioned by the SCA as determined by one of the SCA’s Officers in writing (referred to collectively as “Volunteers”).
  3. The framework for this policy is based on the Scottish Governing Bodies and Sporting Organisations Sporting Integrity – Guidance Note.
  4. The purpose of this policy is to provide an overview and general advice to all the above people on the issues associated with the integrity of sports betting.
  5. This policy is intended to protect the reputation of sport, the SCA, and each individual acting for it. Please note that responsibility for complying with this policy lies with all those to whom it applies.

Sporting Integrity

  1. A core function of the SCA is to maintain, and be seen to be maintaining, the integrity of sport.
  2. The SCA must take action to protect itself from the threats posed to its integrity by corrupt betting and associated activity both from within and outside the organisation. As sports betting activity has increased across all sports and disciplines, it is essential that such activity does not take place in a manner which has the potential to compromise sporting conduct and endeavour.
  3. There will be stricter rules for volunteers in positions of trust and/or at particular risk and this will depend on the role of the volunteer.
  4. If you are “Directly Involved” with a sport you cannot:
    1. bet on events organised by the SCA and affiliated SCA clubs;
    2. ask someone to bet on your behalf on the sport in the events in 4.2.4.1;
    3. share any “Inside Information” with anyone including but not limited to your spouse, cohabitee or dependent children which could enable them to gain an advantage through corrupt betting activity (see section 4.4 on “Inside Information” for further information); and
    4. become involved in any other activity associated with corrupt betting which could reasonably be deemed as suspicious and detrimental to the image and reputation of the SCA and the sport.
  5. “Directly Involved” means working with a sport as a representative of the SCA.
  6. The following offences are also prohibited:
    • fixing a match or attempting to fix a match;
    • benefiting from failing to perform;
    • soliciting, inducing, encouraging, offering a bribe (or attempting to) any other party to do any of the above offences;
    • receiving, seeking a bribe (or attempting to) in order to fix a match or attempt to fix a match;
    • posing a threat to the integrity of the sport;
    • destruction of evidence in relation to a potential breach; and
    • failing to report suspicions or approaches.

Criminal Offence of Cheating

  1. Section 42 of The Gambling Act 2005 has created a new offence of “cheating at gambling” which would include cheating in sports influenced by betting involvement.
  2. Breach of the Gambling Act 2005 new rules may result in the imposition of severe penalties for individuals (fines and jail).
  3. Depending on the nature of the activity, the SCA’s Investigation Panel (see section 6.5-6.13) may refer the matter to the Gambling Commission for consideration of an investigation of the criminal offence of cheating at gambling.

“Inside Information”

  1. The sharing of “Inside Information” by anyone captured by this policy is specifically prohibited by the SCA.
    1. “Inside Information” means any information, which is not Publicly Known that would materially affect people's expectations relating to the participation in, or the likely or actual outcome of a sporting competition or event. Such information includes, but is not limited to, factual information regarding the competitors, the conditions, tactical considerations, injuries, or any other aspect of the sporting competition or event.
    2. “Publicly Known” means any information that is already published as a matter of public record, able to be readily acquired by an interested member of the public, or disclosed according to the rules and regulations governing the relevant sporting competition or event.
  2. With regard to your responsibilities under 4.2.4.3, it is your responsibility to determine whether information which you have access to falls under the definition of “Inside information”. You are advised to err on the side of caution. You should also seek advice from the SCA’s Betting Integrity Officer.

Betting Integrity Officer - Roles and Responsibilities

  1. The SCA Betting Integrity Officer will by default be the SCA Chairman, unless otherwise agreed by the SCA Executive Committee.
  2. All SCA volunteers are responsible for betting integrity issues but the Betting Integrity Officer has specific additional responsibilities including:
    • establishing and maintaining a sound Sports Betting Policy that supports the achievement of the SCA’s policies, aims and objectives; and
    • advising the Investigations Panel (see section 4.6 below).

Response Plan

  1. It is vital that, if there is any suspicious betting activity in the SCA, action is taken.
  2. All Volunteers should be aware that they must not try to deal with or investigate any allegations of corrupt betting and associated activity by themselves but should immediately report the matter to the SCA Betting Integrity Officer.
  3. All volunteers must report any approach or activity which contravenes, or which may contravene, the SCA’s rules on sports betting. Specifically,
    • if any volunteer is approached about fixing any part of a match or asks for “Inside Information” then he/she must report this and cannot just ignore it;
    • if any volunteer has any concerns about any other volunteer’s activity then he/she must report this; and
    • any threats must always be reported.
  4. In the event that a volunteer is concerned that the SCA Betting Integrity Officer is involved in suspicious betting activity outlined in section 4.6.3 above, this should be reported to one of SCA Officers.
  5. All Volunteers must co-operate with any investigation and/or request for information including the provision of documentation, e.g. telephone/betting records, to the Investigations Panel (see section 4.6.6 to 4.6.12 below)
  6. The Betting Integrity Officer will co-ordinate the investigation and set up an Investigations Panel consisting of not less than three SCA Executive members including the Betting Integrity Officer.
  7. The Investigations Panel will investigate the allegation. A member of the Investigations Panel will be allocated the responsibility for leading the investigation process.
  8. The Investigations Panel should establish the facts quickly and any threat of further corrupt betting and associated activity should be removed immediately.
  9. The Investigations Panel is required to:
    • act promptly in investigating the allegation and taking any action required (subject to SCA Executive approval where appropriate);
    • fully document the investigation process;
    • secure evidence in a manner which does not alert suspects at the outset of the investigation; and
    • ensure that the evidence is secured in a legally admissible form (e.g. evidence must be carefully preserved; it should not be handled and no marks made on original documents; a record should be kept of anyone handling evidence).
  10. Depending on the nature of the activity, the Investigations Panel may refer the matter to the Gambling Commission for consideration of an investigation of the criminal offence of cheating (section 42 of the Gambling Act 2005). Additionally, the Investigations Panel may wish to liaise with betting operators, European/International federations, the Police and the Sports Betting Group.
  11. Depending on the nature of the fraud, the Investigations Panel may wish to contact external experts for advice.
  12. The Investigations Panel must obtain the consent of the SCA Officers before contacting any of the third parties referred to in 4.6.10 and 4.6.11 above.
  13. The Investigations Panel will prepare a report of its findings and recommendations to the SCA Officers for final approval. The report will include details of:
    • recommendations on how to deal with volunteers under suspicion (which may include expulsion from the SCA);
    • recommendations on how to deal with third parties under suspicion;
    • recommendations for mitigating the threat of future corrupt betting and associated activity by taking appropriate action to improve controls;
    • recommendations for disseminating the lessons learned from the experience in cases where there may be implications for the organisation as a whole; and
    • recommendations on what information can be released externally if requested.
  14. If a volunteer feels that his/her concerns have not been dealt with appropriately internally, you should also be aware that you are empowered to take any concerns to the relevant authorities and other associated external bodies including the Gambling Commission, so long as you act in good faith.

Compliance

  1. This policy will be reviewed annually unless circumstances dictate more frequent reviews.
  2. Employees who breach this policy and procedure may be subject to disciplinary action.
  3. Compliance with this policy will be monitored by the SCA.