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Gaming Policy

COMMONWEALTH GAMES FOUNDATION OF CANADA INC.

Operating Name: Commonwealth Sport Canada Foundation (CSCF)
CSCF NATIONAL CHARITABLE GAMING POLICY

Effective Date: December 1, 2025
Approved By: Board of Directors
Contact: gaming@commonwealthsport.ca

 

1. PURPOSE AND SCOPE

The Commonwealth Games Foundation of Canada Inc., operating as the Commonwealth Sport Canada Foundation (“CSCF”), conducts charitable gaming events — including electronic 50/50 raffles, prize draws, and other licensed charitable gaming initiatives — to support Canada’s athletes and community sport development across Canada.

This Policy establishes CSCF’s mandatory national standards for:

• Legal and regulatory compliance
• Fairness, transparency, and operational integrity
• Responsible gaming practices
• Financial stewardship and reporting
• Governance and risk management

This Policy applies to all CSCF directors, officers, staff, volunteers, contractors, gaming vendors, platform providers, and any third party involved in CSCF-licensed gaming operations.

 

2. LICENSING & REGULATORY COMPLIANCE

2.1 Provincial/Territorial Requirements

CSCF maintains the appropriate charitable gaming licence before conducting any gaming activity, including:

• Ontario — Alcohol and Gaming Commission of Ontario (AGCO), Lottery Licensing Policy Manual (LLPM)
• Alberta — Alberta Gaming, Liquor and Cannabis Commission (AGLC)
• British Columbia — Gaming Policy and Enforcement Branch (GPEB)

All gaming events must strictly comply with applicable provincial/territorial legislation, regulations, standards, technical bulletins, and licence conditions.

2.2 Technical Approvals

Before launch, CSCF must ensure:

• RNG (Random Number Generator) systems are certified by approved testing labs
• Electronic raffle systems meet regulator-mandated technical standards
• Payment gateways comply with PCI-DSS and anti-fraud requirements
• Geolocation and residency controls are implemented where required

CSCF shall maintain all records of regulatory certifications and technical compliance.

 

3. ELIGIBILITY TO PARTICIPATE

• Participants must be 18 years of age or older, or meet the provincial age of majority.
• Tickets may only be sold to individuals physically located within the province where that raffle is licensed.
• CSCF may verify eligibility using:
o Geofencing
o IP address verification
o Payment address validation
o ID checks
• CSCF employees, directors, contractors, or vendors with access to draw operations, financial reporting, or system administration are not eligible to purchase tickets.

Failure to meet eligibility requirements voids the ticket purchase and any associated prize.

 

4. CODE OF CONDUCT & FAIR PLAY

4.1 Fair Play Principles

CSCF is committed to maintaining the highest standards of integrity. The following are strictly prohibited:

• Tampering with tickets, accounts, or RNG technology
• Unauthorized access to gaming systems
• Fraudulent transactions, chargebacks, or stolen-payment methods
• Collusion or attempts to influence draw outcomes
• Harassment, discrimination, or abusive behaviour toward staff or participants

4.2 Vendor and Partner Obligations

All vendors, platforms, and contractors must:

• Operate in accordance with regulator-approved technical standards
• Maintain comprehensive audit logs
• Enforce secure user authentication
• Report incidents, breaches, or anomalies immediately
• Consent to audit and oversight by CSCF and regulators

Non-compliance may result in termination and regulatory reporting.

 

5. GAME MECHANICS, DRAWS & PRIZE DISTRIBUTION

5.1 Authorized Game Types

CSCF’s core gaming activity is the 50/50 electronic raffle, where:

• 50% of gross ticket revenue is awarded to the prize winner
• 50% is retained by CSCF for its charitable mandate

Any additional game types require regulatory approval.

5.2 Draw Procedures

All draws must:

• Use a certified RNG or regulator-approved draw method
• Run only during licensed operating hours
• Generate a complete audit trail
• Be monitored or witnessed where required
• Ensure zero manual interference

5.3 Prize Claims

Winners must provide:

• Valid government-issued ID
• Proof of residency within the licensed province
• Any additional documentation required by the regulator

Prizes are:

• Non-transferable unless specifically permitted
• Payable only to the verified winner
• Claimable within six (6) months, unless provincial rules require otherwise

5.4 Unclaimed Prizes

Unclaimed prize funds will be handled in accordance with:

• Provincial law
• Licence conditions
• CSCF charitable allocation requirements

 

6. FINANCIAL CONTROLS, BANKING & REPORTING

6.1 Raffle Trust Accounts

All raffle revenue shall be deposited in a designated charitable gaming trust account with:

• Chequing privileges
• Dual-authorized disbursements
• Segregation from all non-gaming funds
• Monthly reconciliation and audit trails

6.2 Record Maintenance

For a minimum of seven (7) years, CSCF must retain:

• Ticket sales reports
• Draw verification files
• RNG logs and certifications
• Banking records
• Payment processor statements
• Winner validation documents

6.3 Mandatory Reporting

CSCF shall file all required reports to provincial regulators, including:

• Event financial statements
• Bank reconciliation reports
• Prize payout confirmations
• Incident or discrepancy reports

6.4 External Audits

The Board may engage licensed auditors to conduct:

• Annual gaming audits
• Event-specific audits
• Compliance reviews
• Risk assessments

 

7. PRIVACY, DATA PROTECTION & CYBERSECURITY

CSCF must comply with:

• PIPEDA
• All applicable provincial privacy statutes
• CSCF’s Privacy Policy

CSCF and its vendors must ensure:

• Encryption of all personal and financial data
• Secure storage of participant information
• Multi-factor authentication for system administrators
• Real-time fraud monitoring
• Incident response and breach reporting protocols

Personal information shall be used strictly for:

• Ticket issuance
• Payment processing
• Contacting winners
• Regulatory reporting
• Fraud and compliance checks

No data may be sold, traded, or used for non-gaming purposes.

 

8. RESPONSIBLE GAMING

CSCF promotes safe participation and provides access to provincial responsible gaming resources, including:

• ConnexOntario
• Alberta Health Services – Addiction Helpline
• BC Responsible & Problem Gambling Program

 

Organization

Website Link

ConnexOntario

Alberta Health Services – Addiction Helpline

Gambling Support BC (Responsible & Problem Gambling Program)

 

CSCF may restrict or suspend participation for individuals demonstrating harmful or compulsive gaming behaviours.

 

9. DISPUTE RESOLUTION

CSCF strives to maintain oversight and timely dispute resolution. In order to do so:

• Disputes must be submitted in writing within 14 days of the draw.
• CSCF will conduct a documented investigation.
• Final decisions rest with the CSCF Gaming Compliance Officer, subject to regulator oversight.
• If required, the matter may be escalated to the applicable provincial gaming authority.

 

10. LIABILITY, INDEMNIFICATION & FORCE MAJEURE

CSCF, its directors, officers, agents, and approved vendors are not responsible for:

• Technical failures beyond CSCF’s control
• Internet outages or payment processing delays
• Loss of data due to third-party failures
• Acts of God, emergencies, or government restrictions

CSCF’s maximum liability is strictly limited to the face value of the prize awarded.

 

11. AMENDMENTS & POLICY UPDATES

CSCF reserves the right to modify this Policy at any time to remain aligned with new legislation, evolving regulatory requirements, technology advancements, and operational improvements. Any substantive amendments will be posted on CSCF’s website and communicated to participants to ensure continued transparency and compliance.

 

12. PLATFORM OPERATIONS & TECHNOLOGY GOVERNANCE

CSCF will operate its gaming platform using an authorized random number generator (RNG) or certified draw provider. All data migration activities will be conducted securely and, where required, under regulatory oversight. Any changes to the platform must be properly documented, tested, certified, and communicated to participants to maintain system integrity and trust.

 

13. GOVERNANCE, OVERSIGHT & RISK MANAGEMENT

13.1 Gaming Compliance Committee

CSCF will maintain a dedicated Gaming Compliance Committee composed of CSCF executive leadership, legal counsel, finance representatives, and, when appropriate, an independent auditor.

13.2 Responsibilities

This Committee oversees all gaming operations, reviews audit findings, ensures regulatory compliance, manages incident reports, approves annual gaming strategies, and provides ongoing reporting to the CSCF Board of Directors.

 

13.3 Annual Review

An annual review will be conducted to evaluate overall compliance performance, the accuracy of financial reporting, vendor performance, stakeholder confidence and public trust, and opportunities for improving CSCF’s policies and governance frameworks.