RESPONSIBLE GAMBLING POLICY

3-102-949565 SOCIEDAD DE RESPONSABILIDAD LIMITADA | Last updated: 2026-07-16

The English version prevails.

Gambling should be a form of entertainment, not a way to earn money. This Policy explains the Company commitment to responsible gambling, underage protection, gaming management tools, cooling-off/time-out, self-exclusion, ordinary account closure, responsible-gambling account closure, operator-imposed exclusions and sources of support.

1. Commitment and Access to Information

1.1 The Website will provide a direct link to a Responsible Gambling page from the home page, registration pages and gaming pages. Responsible gambling information should be accessible by one click from any Responsible Gambling link or logo.

1.2 The Responsible Gambling page will provide the Company responsible gambling policy, practical advice, a credible problem gambling self-assessment tool or process, links and contact details for at least one problem gambling support organisation, and access to gaming management tools.

1.3 Commercial advertising or promotional material will not be displayed on the Responsible Gambling page.

1.4 Responsible gambling information and underage warnings will also be available from free-play presentations where those are offered.

2. Responsible Gaming Manager, Monitoring and Decision-Making Framework

2.1 The Company designates a named Responsible Gaming Manager responsible for developing responsible gambling policies, staff training, customer-intervention standards, monitoring, record keeping and escalation procedures.

2.2 The Responsible Gaming Manager must be adequately trained and have sufficient authority to develop, implement, monitor and improve responsible gambling controls.

2.3 Staff and agents whose roles involve responsible gambling interaction receive training at induction and annual refreshers, and completion records are retained.

2.4 The Company monitors indicators of potential gambling harm and may intervene where customer behaviour or gameplay is symptomatic of risk. Monitoring is not a medical diagnosis and does not replace professional support.

2.5 Indicators and patterns that may trigger review include, without limitation:

- sudden or sustained increases in deposits, losses, session length or frequency of play;

- chasing losses, repeated failed deposits, repeated withdrawal cancellations or rapid redeposit after withdrawals;

- repeated requests to increase limits, remove limits or reopen following a break;

- customer statements indicating loss of control, financial distress, borrowing, employment stress, family conflict or gambling to recover debts;

- gambling while apparently intoxicated, distressed or behaving aggressively;

- activity inconsistent with the customer profile, source of funds or previous behaviour;

- use of multiple Accounts, third-party funding, AML red flags or other conduct that also requires AML/KYC escalation.

2.6 When a risk indicator is identified, the Company may ask the customer to complete a responsible gambling questionnaire or affordability/risk interaction. Questions may cover gambling purpose, budget, affordability, source of funds where relevant, signs of loss of control, desired limits, breaks, and whether the customer wants support or self-exclusion.

2.7 Customer responses, monitoring data and support interactions are reviewed under a documented decision-making framework. Possible outcomes include: no immediate action with continued monitoring; responsible gambling advice and signposting; setting or reducing limits; cooling-off/time-out; ordinary account closure; responsible-gambling closure; self-exclusion; operator-imposed exclusion; AML/KYC escalation; or report/escalation where legally required.
Any request or internal proposal to approve a withdrawal-limit exception for a high-value customer must be reviewed against available responsible gambling indicators. No exception shall override any responsible gambling restriction, self-exclusion, cooling-off period, operator-imposed limit or protective measure applicable to the customer.

2.8 Higher-risk decisions, refusal to reopen an account after an RG concern, operator-imposed exclusion, and conflicts between AML and responsible-gambling indicators must be reviewed by the Responsible Gaming Manager or suitably trained senior staff. The rationale, evidence and outcome must be recorded.

3. Underage Gambling Policy

3.1 The Company does not allow anyone under the age of 18 to open an Account, deposit, play or claim winnings. Preventing underage access is an ongoing process.

3.2 Every person registering an Account must provide date of birth and positively affirm that they are at least 18 years old. The registration process uses controls designed to detect under registrants who are under 18 and provided  false information.

3.3 Identity documents may be required to verify age and identity before winnings are released. Age verification begins at Account opening and must be completed within the verification period required by the Terms and AML/KYC Policy.

3.4 If a player is shown to be under 18, the Account will be closed, no further bets or deposits will be accepted, winnings will not be paid, and the balance will be returned in accordance with applicable law and Tobique requirements. Underage attempts or activities may be reported to the Tobique Gaming Commission.

3.5 Marketing campaigns, Website presentation and content must not be directed at or specifically attractive to under-18s. The Website will display obvious 18+ warnings on home page, registration pages, Responsible Gambling page, lobby/entry pages and logout/session-end pages.

3.6 To help prevent minors from accessing gambling websites, parents or guardians may consider reputable filtering tools such as Net Nanny, CyberPatrol, CyberSitter, SafeKids or similar services.

4. Practical Guidelines for Players

- Gambling should be treated as entertainment, not a source of income.

- Set deposit, loss or time limits before you start.

- Do not gamble if you are under the influence of alcohol, narcotics or medication.

- Do not gamble if you are depressed, distressed or trying to recover losses.

- Use a cooling-off period, time-out, self-exclusion or customer support if you need a break.

5. Gaming Management Tools

5.1 The Company provides tools to help customers monitor, manage and control gambling behaviour. Procedures for using these tools are available on the Website and are designed to be user-friendly and unambiguous.

5.2 Gaming management tools may include one or more of the following: deposit limits per time period, loss limits per time period, time played reminders, time-outs, cooling-off periods, table or tournament limits, and self-exclusion.

5.3 Customers may set controls during registration, at first deposit where available, or at any time after registration.

5.4 Requests to reduce a limit will be implemented as soon as reasonably practicable. Requests to increase a limit will be implemented only after a 24-hour cooling-off period.

5.5 The Company may impose its own gaming management limits where it suspects a problem gambling risk, and will inform the customer of any such limit where appropriate.

6. Cooling-Off and Time-Out

6.1 A cooling-off period or time-out is a temporary break from gambling requested by the customer or applied by the Company as a protective measure. During the cooling-off/time-out period, the customer may not place bets or make deposits.

6.2 The customer is not prevented from withdrawing cleared funds during a cooling-off/time-out period, subject to AML/KYC checks and payment rules.

6.3 A cooling-off/time-out cannot normally be shortened once implemented. When it expires, the Account may be restored automatically or after customer confirmation, depending on the tool selected and the risk assessment.

6.4 A cooling-off/time-out is different from self-exclusion. If the customer indicates loss of control, gambling harm, addiction, serious distress or inability to stop, the Company may treat the matter as a self-exclusion or responsible-gambling closure rather than an ordinary time-out.

7. Account Closure: Non-RG and RG Closure

7.1 Ordinary non-RG account closure is a customer request to close the Account for reasons not connected to gambling harm. The Company will close the Account and return available cleared funds in accordance with the Terms and Payments Policy, subject to AML/KYC checks, unresolved bets, fees, chargebacks and legal restrictions.

7.2 A customer who closed an Account for non-RG reasons may request reopening. Reopening is at the Company discretion and may require KYC refresh, fraud review, payment review and confirmation that no responsible-gambling concern is present.

7.3 Responsible-gambling closure applies where a customer requests closure, cancellation, suspension or similar action because of gambling harm, loss of control, inability to stop, financial distress, addiction, or similar statements or behaviours. RG closure is handled under the same protective principles as self-exclusion unless the Responsible Gaming Manager records a reasoned alternative decision.

7.4 For RG closure, the Company will stop accepting new bets and deposits as soon as reasonably practicable after processing the request, suppress marketing, signpost support, and document the decision. Reopening is not automatic and requires a documented return-to-play assessment, customer confirmation and any applicable cooling-off period.

8. Self-Exclusion

8.1 Customers may request self-exclusion for any period of time or permanently. The request can be made by contacting Customer Support from the registered email address or through any self-exclusion tool made available on the Website.

8.2 Self-exclusion requests are recorded and implemented as soon as practicable. After implementation, no new bets or deposits will be accepted from the customer until the exclusion expires or is removed in accordance with the documented process.

8.3 During the exclusion period, the customer is not prevented from withdrawing any or all cleared Account balance, subject to AML/KYC checks. If permanent self-exclusion is selected, the Company will remit the customer’s cleared balance in accordance with payment and AML/KYC requirements.

8.4 Self-exclusion applies consistently across all brands and products under the control of the Company.

8.5 For self-exclusion of six months or more, a customer who wishes to resume gambling after expiry must confirm through a documented process that they wish to return before the Account or facility is reinstated. A cooling-off period may be applied.

8.6 The Company takes reasonable steps to prevent its own marketing material being sent to customers subject to customer-imposed exclusion, operator-imposed exclusion or RG closure.

8.7 Breaches of self-exclusion will be reviewed case by case. Reimbursement of deposits is at the Company discretion and will take account of the customer history. Breaches will not be incentivised by automatic reimbursement of deposits or payment of winnings.

8.8 Details of self-excluded customers and operator discretionary exclusions are reported to the Tobique Gaming Commission as part of quarterly reporting where required.

9. Operator-Imposed Exclusion

9.1 The Company may impose exclusion where there is suspicion of cheating or collusion, improper behaviour, indicators of problem gambling, or apparent influence of alcohol or narcotics. The assessment, decision and balance handling will be recorded.

9.2 The Company must impose exclusion where there is clear evidence of cheating or collusion, threatening behaviour, proof that the participant is an uncontrollable problem gambler, known intoxication by alcohol or narcotics, or proof that the participant is under 18. Where the participant is under 18, the balance must be returned in accordance with applicable law.

10. External Support and Blocking Tools

10.1 Players who decide to self-exclude or close an Account for responsible-gambling reasons should consider seeking support from a recognised gambling addiction or counselling organisation and should also consider self-exclusion across other gambling operators where they hold accounts.

10.2 Blocking tools that may help prevent access to gambling websites include GamBlock and Betfilter. Support organisations may include Gambling Therapy, GamCare, GambleAware and other local services available in the player jurisdiction.

Regulatory source notes

This document is drafted against the Tobique Gaming Commission framework and the latest available Tobique restricted-jurisdiction assessment. References are included as drafting notes and should be checked against any later TGC update before publication.

TGC General Code ss.17-19: responsible gambling information, signposting, monitoring, gaming management tools and self-exclusion.

TGC General Code ss.20-21: underage gaming information and age verification.

TGC General Code s.30.3.3: quarterly reporting of self-exclusions.

Client comment addressed by defining cooling-off/time-out, ordinary non-RG account closure, responsible-gambling account closure, self-exclusion, risk patterns, questionnaire use and decision-making framework.