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“Leadership is the single biggest determinant of an inclusive culture,” Skinner comments. “Policies matter, but individuals experience inclusion primarily through their managers. Leaders set the tone through the decisions they make, the behaviours they reward and the conversations they encourage.”

Some companies, such as Evoke, actively monitor DEI at a leadership level to track whether initiatives are making an impact.

“Leadership is critical in setting expectations and maintaining accountability,” says Nicola Kociuba, learning and performance business partner at Evoke. “For example, our Nomination Committee monitors progress against diversity objectives and considers diversity in succession planning and appointments, while ensuring decisions remain based on merit, experience and capability.”

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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.

“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

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Anthony Lee’s senior campaigning role gave him access to confidential discussions about the election timing. Rather than keeping that information confidential, he placed bets and passed it to his wife. She then used the information to place her own bets.

UK operators already carry out enhanced checks on politically exposed persons (PEPs), but this case shows the limits of those safeguards, Bethan Lloyd, partner at law firm Wiggin, recently told iGB.

“PEP status does not prevent someone from gambling,” Lloyd explained. She said PEPs are entitled to bet, but not on events where inside information gives them an unfair advantage.