Responsible Gaming, Self-Exclusion, Code of Conduct

Introductory

In this section, the rules and regulations regarding general policies on Responsible Gaming, Self-Exclusion and the application of the Code of Conduct (“CoC”) and the Standards of Responsible Gaming and Self-Exclusion (“SRGS”).

The Operator is responsible for for proper execution of CEGs’ general policies and CoC

CEG determines general policies that matter to End Users the most. The policies are transparent and therefore made public and these policies should be in line with international Standards of Good Industry Practice. The Operator as the one dealing with End Users directly, shall be responsible for the proper execution of the said policies.

CEG determines general policies that matter to End Users the most. The policies are transparent and therefore made public and these policies should be in line with international Standards of Good Industry Practice. The Operator as the one dealing with End Users directly, shall be responsible for the proper execution of the said policies.

The Operator shall commit to having adequate measures in place to comply with the Standards of Responsible Gaming (or also to be referred to as: the “RG-Principles”) and the option to voluntarily exclude or Self Exclude, which measures shall be available to the public and have therefore been included in CEG’s article 3 of the General Terms and Conditions pertaining the relationship between CEG and the Operator. The SRGS reads as follows:

1. The Operator shall when rendering B2B Services within a reasonable perspective aim to assist in the prevention of compulsory behavior with End Users.

2. The Operator shall collaborate with partners in the Gaming Industry in its efforts to minimize gaming addiction.

3. The Operator is required to monitor and research its Websites for elements unnecessarily causing problematic behaviour with End Users. In the event of any problems found, the Operator is required to make the necessary adjustments to negate any unnecessary risks for End Users.

4. The Operator is required to in its communications with End Users actively promote and advise on Responsible Gaming.

5. The Operator is obliged to maintain an online environment that provides the End User an informed choice.

6. The Operator is obliged to report to CEG any breach of the principles of Responsible Gaming.

7. The Operator is required to have in place and maintain proper measures to help prevent player addiction and allow Self-Exclusion to players who access the Websites.

8. The Operator must ensure that it has on its Websites, a dedicated page with information about addiction prevention and any measures provided by the Operator to help End Users monitor and control their online behavior while using the Websites such as however not limited to explanation of the Right to Self-Exclusion has been structured on the Websites as well as links to reputable gambling addiction support institutes.

9. Upon request of the End User, as well as if health issues of the End User deem such action necessary, the Operator must ensure that the End User shall for a limited or unlimited amount of time not be able to make use of any services offered on any of the Websites of the Operator.

10. The Operator shall at any time be entitled to withhold services from the End User by shall mean of Suspension of the Account or otherwise, whenever it finds indications of irregular behaviour by the End User such as, however not limited to compulsory behavior, chasing losses, erratic gambling patterns, and, or, abnormal long periods of sustained game play. If the Operator decides to exclude the End User, it shall notify the End User of its decision and shall communicate a time frame during which the said exclusion shall apply.

11. If measures for Self-Exclusion apply, the Operator or any of its Affiliates shall not approach the End User with any information aimed to generate interest by the receiver for products and services of the Operator.

12. The Operator is obliged to report in the RGR, the number of (1) End Users that have been excluded; (2) End Users that are being considered for exclusion, and (3) End Users that have applied for Self-Exclusion.

Code of Conduct (“CoC”)

The Operator shall commit to the Code of Conduct, that is available to the public and has therefore been included in article 2 of the General Terms and Conditions pertaining the relationship between CEG and the Operator. The CoC reads as follows:

1. The Operator is at all times obliged to have its statutory as well as its office address within the insular territory of Curaçao as meant in article 1 of the Ordinance. Furthermore, at least one of its board members should be a resident within the said territory.

2. The Operator shall abide by general standards of Corporate Governance as provided by the OECD Corporate Governance Committee. Such standards include, however, are not limited to independence of management, transparency, reporting and the establishment of proper social values in business practices.

3. Notwithstanding Subsection 2.2., the Operator shall abide by any specific standards of Corporate Governance as provided by OECD Member States in which the majority of the Key Individuals of the Operation has its residency.

4. The Operator shall refrain from doing business with any Third Party such as however not limited to financial institutions, software providers, affiliates, countries, that are not deemed Fit and Proper. The Operator is required to research and log such research and, if desired, provide proof to the B2B Services Provider, whether a Third Party is indeed Fit and Proper.

5. The Operator shall refrain from enabling as well as directly offering B2C Services to minors.

6. The Operator shall refrain from holding multiple Grants.

7. The Operator shall not hold any controlling interests in Third Parties that offer B2C Services without prior written approval of the Aggregator.

8. The Operator shall in no shall mean attempt to circumvent ramifications of Suspension by the Aggregator, such as, however not limited to the application of a Grant with an alternate Grantor, including alternate licensing under foreign legislation, and, or, the sale of a Website, Domain or Alias.

9. The Operator confirms that it has not been suspended by any Third Party prior to any agreement that refers to the General Terms and Conditions, including suspensions under foreign legislation.

10. The Operator shall not sell Websites without proper and timely notification of the Aggregator.

11. The Operator confirms that any breach of the Code of Conduct as formulated in Article 2 authorizes the Aggregator to, as cause for Material Breach, with immediate effect terminate any agreements between the Operator without the right for the Operator to claim for any damages in connection with the said termination.

12. The Operator confirms the right of the Aggregator to send out notifications of Breach of the Code of Conduct to any Third Party it deems necessary.

13. The Aggregator may at any time, as it sees fit, introduce or amend any provisions regarding a Code of Conduct to Third Parties.

14. The Operator is required, the Ordinance notwithstanding, to at all times comply with all Curaçao local as well as international rules and regulations.

Notwithstanding anything to the contrary as referenced in this section, the Operator is required to always keep its B2C Services to the End User responsible, transparent and fair.