Wagering and Competition Manipulation Policy

Summary 

The manipulation of sporting competitions and related activities undermines the integrity of sport. Manipulating sporting competitions can be a crime and punishable by law.  

World Golf Competition Pty Ltd recognises that while betting may be a legitimate pursuit in certain circumstances, Golf must safeguard against illegal or fraudulent betting and competition manipulation.  

World Golf Competition Pty Ltd has zero tolerance for illegal or fraudulent betting and competition manipulation. World Golf Competition Pty Ltd has an obligation to address the threat of illegal or fraudulent betting and competition manipulation.  

This Policy prescribes prohibited conduct which constitutes a breach, as well as offences which must be reported to World Golf Competition Pty Ltd.  

Through this Policy, World Golf Competition Pty Ltd aims to ensure that its core values, good reputation and positive behaviours and attitudes are maintained.  

 

Definitions  

In this Policy the following words have the corresponding meaning:  

  • Benefit means any advantage and is not limited to property.  
  • Inside Information means any information connected to the conduct, management or organisation of a sporting event that is not generally available and if it were generally available, the information, would, or would be likely to, influence a person’s decision to bet on the sporting event or in making any other betting decision.  
  • Policy means this Wagering and Competition Manipulation Policy.  
  • Prohibited Conduct means conduct proscribed by clause 3 of this Policy.  
  • Wagering Service Provider means any company or other undertaking that promotes, brokers, arranges or conducts any form of wagering activity in relation to Golf in general.  

 

Jurisdiction  

This Policy applies to:  

  1. Relevant Persons; and 
  2. Relevant Organisations,  

in the manner set out in this Policy.  

 Prohibited Conduct  

A Relevant Person commits a breach of this Policy when they, either alone or in conjunction with another or others, engage in any of the following conduct:  

  1. Participating (whether by act or omission) in improperly altering the result or the course of an Event in order to remove all or part of the unpredictable nature of the Event to obtain a Benefit for themselves or others, whether successful or not in obtaining the Benefit, by: 
    1. the direct, pre-meditated or planned interference with the natural course of an Event or element of an Event*;  
    2. providing modified or false information related to a players’s identity or personal information;  
    3. intentionally modifying playing surfaces, equipment or players’s physiology to improperly influence the natural course of the Event**; or  
    4. providing or receiving any Benefit that might reasonably be expected to bring the Relevant Person, World Golf Competition Pty Ltd or Golf into disrepute;  

* Examples may include, but not limited to, intentionally conceding shots, pre-arranging the outcome of a competition, deliberate underperformance (sometimes known as ‘tanking’) in any manner (through selections or not playing to a person’s merits), influencing player selections and strategy, or intentional unfair or incorrect officiating  

** For the avoidance of doubt, this does not include any matters dealt with under other relevant policies relating to anti-doping, eligibility, gender identity or selection criteria. 

2. Solely for those Relevant Persons who are Participants who participate in, or provide support to those who participate in World Golf Competition Pty Ltd Events or who are Employees, Contractors or Volunteers of World Golf Competition Pty Ltd, bet, or enter into any other form of financial speculation on any Event, or on any incident or occurrence in an Event connected with World Golf Competition Pty Ltd, whether or not they are participating in the Event. For the avoidance of doubt:  

    1. any bets placed by a betting syndicate or group, such as a ‘punter’s club’, of which the Relevant Person is a member;  
    2. an interest in any bet, including having someone else place a bet on their behalf; or  
    3. allowing another person to place a bet using a Relevant Person’s account, shall be treated as if the bet was placed by the Relevant Person as an individual;  

 

3. Facilitating or assisting with the making of a bet on any Event or part of any Event including communicating in any way, such as by using a mobile phone, computer or other electronic device, information that may give another person an unfair advantage if they were to engage in betting related to that information, other than as required as part of their official duties; 

4. Disclosing Inside Information, other than as required as part of their official duties;  

5. Accepting a Benefit to incite, cause or contribute to any breach of this Policy;  

6. Facilitating, assisting, aiding, abetting, encouraging, inducing, covering-up or being complicit in any Prohibited Conduct;  

7. Attempting to engage in any conduct which would be Prohibited Conduct if successful; or  

8. Failing to promptly report to World Golf Competition Pty Ltd’s General Manager any of the matters listed above.  

Obligations  

Reporting  

  1. A Relevant Person must, where permitted by law, promptly notify World Golf Competition Pty Ltd’s General Manager if he or she:  
    1. is interviewed as a suspect, charged, or arrested by a law enforcement body in respect of conduct that falls with the definition of Prohibited Conduct.  
    2. has been approached by another person to engage in Prohibited Conduct;  
    3. knows or reasonably suspects that another person has engaged in Prohibited Conduct, or has been approached to engage in Prohibited Conduct; or  2.
    4. has received or is aware or reasonably suspects that another person has received, actual or implied threats of any nature in relation to any past or proposed Prohibited Conduct. 
  2. A Relevant Person has a continuing obligation to report any new knowledge or suspicion regarding any Prohibited Conduct under this Policy, even if the Relevant Person’s prior knowledge or suspicion has already been reported. 
  3. Notification by a Relevant Person under this clause may be made verbally or in writing by the Relevant Person and may be made anonymously if there is a genuine concern of reprisal. A Relevant Person who makes a report anonymously is responsible for keeping a record that will allow them to confirm that they have met their obligations under this clause . 
  4. World Golf Competition Pty Ltd and Relevant Persons should be aware of the relevant legal requirements of the country in which the event is being held to report criminal activity in relation to the manipulation of sporting competitions (match-fixing) and Inside Information.  

 

Information sharing  

  1. World Golf Competition Pty Ltd may share information (including Personal Information as defined in the Privacy Act 1988 (Cth)) at any time relating to Relevant Persons or Relevant Organisations with Wagering Service Providers, law enforcement agencies, government agencies or other sporting organisations (including Golf Entities, the PGA and the R&A) to prevent, identify and investigate alleged Prohibited Conduct. 
  2. World Golf Competition Pty Ltd must share the following information with Sport Integrity Australia:  
    1. Any notification received from a Relevant Person  
    2. Any information received from Wagering Service Providers  3.

3. In sharing information, World Golf Competition Pty Ltd will remain bound by the legal obligations contained in the Australian Privacy Act 1988 (Cth) and the privacy policies of  Golf Australia, The PGA and/or the R&A. 

 

Monitoring by Wagering Service Providers  

  • Relevant Persons must disclose information to World Golf Competition Pty Ltd regarding all of their commercial agreements, interests, and connections with Wagering Service Providers. For the avoidance of doubt, this does not include the disclosure of accounts that Relevant Persons may hold with Wagering Service Providers.  
  • World Golf Competition Pty Ltd will work with Wagering Service Providers to ensure the ongoing integrity of Activities under the auspices of Golf Australia, the PGA and/or the R&A.  
  • World Golf Competition Pty Ltd may request Wagering Service Providers to monitor and conduct regular audits of their databases and records to monitor the incidents of suspicious betting transactions (including single or multiple betting transactions or market fluctuations) that may indicate or tend to indicate that Relevant Persons have engaged in Prohibited Conduct under this Policy.  
  • To enable the Wagering Service Providers to conduct such audits, World Golf Competition Pty Ltd may, from time to time and subject to any terms and conditions imposed by World Golf Competition Pty Ltd (including in relation to confidentiality and privacy), provide to Wagering Service Providers details of Relevant Persons who are precluded by this Policy from engaging in Prohibited Conduct.  
  • Wagering Service Providers may provide World Golf Competition Pty Ltd with regular written reports on incidents of suspicious betting transactions (including single or multiple betting transactions or market fluctuations) that may indicate or tend to indicate that Relevant Persons have engaged in Prohibited Conduct.  
  • All requests for information or provision of information by World Golf Competition Pty Ltd or a Wagering Service Provider shall be kept strictly confidential and shall not be divulged to any third party or otherwise made use of, except where required by law or by this Policy, is permitted by World Golf Competition Pty Ltd or Wagering Service Provider, or where information is already in the public domain other than because of a breach of this Policy.  

 

Complaints and Disputes Policy  

The Complaints and Disputes Policy applies to any alleged Prohibited Conduct, including reports of breaches of this Policy.  

 

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