The Online Gaming License Application Form has the wrong name and signature on the Declaration and Data Privacy page. The form must be in the name and digitally signed by one of the Managing Directors. Kindly change the name and digitally signed and resubmit the form.

The Online Gaming License Application Form has the wrong name and signature on the Declaration and Data Privacy page. The form must be in the name and digitally signed by one of the Managing Directors. Kindly change the name and digitally signed and resubmit the form.

We are missing the Declaration of Good Standing confirming compliance with tax and social contribution obligations (can be requested from the tax authorities). To be obtain at the tax authority. Kindly submit the requested document under the extra documentation section and name the file Declaration of Good Standing.

<p>We are missing the Declaration of Good Standing confirming compliance with tax and social contribution obligations (can be requested from the tax authorities). To be obtain at the tax authority. Kindly submit the requested document under the extra documentation section and name the file Declaration of Good Standing.</p><p><br></p><p>UPDATE:</p><p>Please note that the Declaration of Good Standing <b>(verzoek verklaring betalingsgedrag)</b> must requested directly from the <b><u>Tax Authorities</u></b>. No other document or self-made document is accepted. </p><p>The Declaration of Good Standing must be stamped with the stamp of 'ontvanger' and signed by the 'invorderaar'.</p><p>If the Declaration of Good Standing is not in English, a certified English translation must also be submitted.</p><p>Please upload the document in the Extra Documentation section. </p>

We are missing the registration email confirmation of the goAML registration of Vanir Ventures B.V. Kindly submit the confirmation under the extra documentation section and name the file goAML registration.

<p>We are missing the registration email confirmation of the goAML registration of Vanir Ventures B.V. Kindly submit the confirmation under the extra documentation section and name the file goAML registration.</p><p><br></p><p>UPDATE:</p><p>Please note that documents submitted in the checklist cannot be accepted. Once the application is put On Hold and the second four-week period begins, please upload the goAML registration confirmation to the Extra Documentation section in the portal. </p>

We are missing the 3rd party or shareholder loans agreement. Kindly submit the requested document under the extra documentation section and name the file 3rd party or shareholder loans agreement.

We are missing the 3rd party or shareholder loans agreement. Kindly submit the requested document under the extra documentation section and name the file 3rd party or shareholder loans agreement.

The Business and Corporate Information Form is missing response in question 7. Kindly select one option and resubmit the form.

The Business and Corporate Information Form is missing response in question 7. Kindly select one option and resubmit the form.

The Business and Corporate Information Form is missing response in question 12 and 12.1. Kindly complete question 12 and resubmit the form.

<p>The Business and Corporate Information Form is missing response in question 12 and 12.1.</p><p>In this section please include all key persons, including any key functions being held by the UBO as well as the compliance officer. Kindly complete question 12 and resubmit the form.</p>

We are missing information of the Compliance Officer of Vanir Ventures B.V. Kindly add the compliance officer to the qualifying person tab and submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer.

We are missing information of the Compliance Officer of Vanir Ventures B.V. Kindly add the compliance officer to the qualifying person tab and submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer.  Note, that the function of the CO is required to be independent from the appointed directors

The Business and Corporate Information Form is missing response in question 13. Kindly complete question 13 and resubmit the form.

The Business and Corporate Information Form is missing response in question 13. Kindly complete question 13 and resubmit the form.

The Business and Corporate Information Form has the wrong name and signature on the Declaration and Data Privacy page. The form must be in the name and digitally signed by one of the Managing Directors. Kindly change the name and digitally signed and resubmit the form.

The Business and Corporate Information Form has the wrong name and signature on the Declaration and Data Privacy page. The form must be in the name and digitally signed by one of the Managing Directors. Kindly change the name and digitally signed and resubmit the form.

The Personal History Disclosure Short Form of Analissa Heiland is missing response in question 7. Kindly fill question 7 and resubmit the form.

The Personal History Disclosure Short Form of Analissa Heiland is missing response in question 7. Kindly fill question 7 and resubmit the form.

The Personal History Disclosure Short Form of Christopher van Rosberg is missing response in question 7. Kindly fill question 7 and resubmit the form.

The Personal History Disclosure Short Form of Christopher van Rosberg is missing response in question 7. Kindly fill question 7 and resubmit the form.

The Personal History Disclosure Short Form of Lorenza Godett is missing response in question 7. Kindly fill question 7 and resubmit the form.

The Personal History Disclosure Short Form of Lorenza Godett is missing response in question 7. Kindly fill question 7 and resubmit the form.

Submit signed financials in whatever form for years ending 2023 and 2024

Submit signed financials in whatever form for years ending 2023 and 2024

Resubmit a detailed 3 year financial projection as an annex to the business plan, providing a detailed break down of any investments, marketing expenses, wages, loans, commissions/benefits paid to any third party/provider, amongst other key figures

Resubmit a detailed 3 year financial projection as an annex to the business plan, providing a detailed break down of any investments, marketing expenses, wages, loans, commissions/benefits paid to any third party/provider, amongst other key figures

Clarify the commercial relationship between the applicant company and Njord Ventures B.V. Submit the necessary documentation substantiating the said explanation

Clarify the commercial relationship between the applicant company and Njord Ventures B.V. Submit the necessary documentation substantiating the said explanation

Please indicate the amount and currency of the loan in 11.2.1 and resubmit the form.

Please indicate the amount and currency of the amount in 11.2.1 and resubmit the form.

Please note that a certified copy of the birth certificate of Morten Groven has not been provided. Please upload a certified copy of the birth certificate in Morton Groven's base application QPA/2024/00509.

Please note that a certified copy of the birth certificate of Morten Groven has not been provided. <b>Please upload a <u>certified</u> copy of the birth certificate in Morton Groven's <u>base application QPA/2024/00509</u></b>.

Please note that a certified copy of the criminal record has not been provided for Analissa Heiland. Please upload a certified copy of the criminal record in English in Analissa Heiland's base application QPA/2025/03355.

Please note that a certified copy of the criminal record has not been provided for Analissa Heiland. <b>Please upload a <u>certified</u> copy of the criminal record in <u>English</u> in Analissa Heiland's <u>base application QPA/2025/03355</u>.</b>

Please note that a certified copy of the birth certificate of Analissa Heiland has not been provided. Please upload a certified copy of the birth certificate in English in Analissa Heiland's base application QPA/2025/03355. Kindly note that if the birth certificate is not in English, both a certified copy of the birth certificate and a certified English translation must be provided. All certifications must also be in English.

<p>Please note that a certified copy of the birth certificate of Analissa Heiland has not been provided. <b>Please upload a <u>certified</u> copy of the birth certificate in English in Analissa Heiland's <u>base application QPA/2025/03355</u>.</b> </p><p> Kindly note that if the birth certificate is not in English, both a certified copy of the birth certificate and a certified English translation must be provided. All certifications must be in English.</p>

Please note that a proof of address document (utility bill) is required for Analissa Heiland. Please upload a certified copy of the proof of address document (utility bill) in English and issued within the last 6 months in Analissa Heiland's base application QPA/2025/03355. Kindly note that bank statements are not accepted as proof of address.

<p>Please note that a proof of address document (utility bill) is required for Analissa Heiland.<b> Please upload a <u>certified</u> copy of the proof of address document (utility bill) in English and issued within the last 6 months in Analissa Heiland's <u>base application QPA/2025/03355</u>.</b> </p><p>Kindly note that bank statements are not accepted as proof of address.</p>

Resubmit an updated corporate structure duly signed by the director. Include all entities/subsidiaries forming part of the group

Resubmit an updated Group corporate structure duly signed by the director. Include all entities/subsidiaries forming part of the group

The Business and Corporate Information Form is missing response in question 12 and 12.1. In this section please include all key persons, including any key functions being held by the UBO as well as the compliance officer. Kindly complete question 12 and resubmit the form.

<p>The Business and Corporate Information Form is missing response in question 12 and 12.1. In this section please include all key persons, including any key functions being held by the UBO as well as the compliance officer. Kindly complete question 12 and resubmit the form.</p><p><b><u>UPDATE:</u></b></p><p>According to the business plan, the UBO also holds the roles of CEO and CFO. As such, he must be added to question 12.1. Kindly update the form and resubmit it.</p>

According to the business plan, in addition to being the UBO Morten Groven is also the CEO and CFO. Please update his roles in the portal to reflect this.

According to the business plan, in addition to being the UBO Morten Groven is also the CEO and CFO. Please update his roles in the portal to reflect this.

Please note that a certified copy of the birth certificate of Morten Groven has not been provided. Please upload a certified copy of the birth certificate in Morton Groven's base application QPA/2024/00509.

<p>Please note that a certified copy of the birth certificate of Morten Groven has not been provided. Please upload a certified copy of the birth certificate in Morton Groven's base application QPA/2024/00509.</p><p><b><u>UPDATE:</u></b></p><p>Please note that the birth certificate uploaded in the base application QPA/2024/00509 cannot be accepted as it is not certified as a true copy. Please submit a certified copy of the birth certificate in the base application QPA/2024/00509.</p>

Please note that in the Personal History Disclosure Form in the base application (QPA/2025/03733) the response to question 39 is missing. Please complete question 39 and resubmit the form in the base application (QPA/2025/03733).

Please note that in the Personal History Disclosure Form in the base application (QPA/2025/03733) the response to question 39 is missing. Please complete question 39 and resubmit the form in the base application (QPA/2025/03733).

In question 8 on the Personal History Disclosure Form submitted in the base application (QPA/2025/03733) it is indicated that Pearl Reiph changed her last name in 2005 (former last name of Joseph). Please submit proof of the name change in 2005 in the Birth Certificate section of the base application (QPA/2025/03733). Kindly note that all documents submitted must be certified as a true copy. If the document is not in English, an English translation (certified by the translator) must also be submitted.

<p>In question 8 on the Personal History Disclosure Form submitted in the base application (QPA/2025/03733) it is indicated that Pearl Reiph changed her last name in 2005 (former last name of Joseph). Please submit proof of the name change in 2005 in the Birth Certificate section of the base application (QPA/2025/03733). </p><p>Kindly note that all documents submitted must be certified as a true copy. If the document is not in English, an English translation (certified by the translator) must also be submitted.</p>

Please note that the criminal record must be certified as a true copy. Kindly submit a certified copy of the criminal record in the base application QPA/2025/03733.

Please note that the criminal record must be certified as a true copy. Kindly submit a certified copy of the criminal record in the base application QPA/2025/03733.

Please note that the bank reference letter must be certified as a true copy. Kindly submit a certified copy of the bank reference letter in the base application QPA/2025/03733.

Please note that the bank reference letter must be certified as a true copy. Kindly submit a certified copy of the bank reference letter in the base application QPA/2025/03733.

Please note that the proof of address document must be certified as a true copy. Kindly submit a certified copy of the proof of address document in the base application QPA/2025/03733.

Please note that the proof of address document must be certified as a true copy. Kindly submit a certified copy of the proof of address document in the base application QPA/2025/03733.

Please upload a certified copy of the birth certificate in the Vanir Ventures B.V. application in the applicable section under Analissa Heiland.

Please upload a certified copy of the birth certificate in the Vanir Ventures B.V. application in the applicable section under Analissa Heiland.

Please complete questions 7 and 7.1 and resubmit the form.

Please complete questions 7 and 7.1 and resubmit the form.

Please note that the birth certificate must be certified as a true copy. Since the document is not in English, an English translation (certified by the translator) must also be submitted. Please submit these documents in the base application QPA/2025/03733.

Please note that the birth certificate must be certified as a true copy. Since the document is not in English, an English translation (certified by the translator) must also be submitted. Please submit these documents in the base application QPA/2025/03733.

Please submit a letter of engagement signed by both the managing director and the compliance officer. Please upload the letter in the letter of engagement section for Pearl Reiph in the Vanir Ventures B.V. application.

Please submit a letter of engagement signed by both the managing director and the compliance officer. Please upload the letter in the letter of engagement section for Pearl Reiph in the Vanir Ventures B.V. application.

Please upload the CV in the letter of engagement section of the base application QPA/2025/03733.

Please upload the CV in the letter of engagement section of the base application QPA/2025/03733.

Please provide a signed copy of the 2024 financial statement for Njord Ventures B.V. Kindly upload this in the source of funds section.

Please provide a signed copy of the 2024 financial statement for Njord Ventures B.V. Kindly upload this in the source of funds section.

Please provide a certified true copy and additional sow.

Please provide a certified true copy and additional sow.

Please upload updated documents that are requested in the base application.

Please upload updated documents that are requested in the base application.

How Njord Ventures B.V. (the third party entity) can afford the facility/ dividends.

How Njord Ventures B.V. (the third party entity) can afford the facility/ dividends.

How Njord Ventures B.V. (the third party entity) can afford the facility/ dividends.

How Njord Ventures B.V. (the third party entity) can afford the facility/ dividends.

Please upload the Responsible Gaming Policy, in the designated policy section.

Please upload the Responsible Gaming Policy, in the designated policy section.

Please upload the Information Security Policy, in the designated policy section.

Please upload the Information Security Policy, in the designated policy section.

Please upload the Player Complaints Policy, in the designated policy section.

Please upload the Player Complaints Policy, in the designated policy section.

The policy must be signed by the Compliance officer and managing director of the applicant.

The policy must be signed by the Compliance officer and managing director of the applicant.

The policy must make reference to Curaçao laws, specifically the following: LOK, NORUT, NOIS, CGA Guidelines, Sanctions Ordinance, Criminal Code.

The policy must make reference to Curaçao laws, specifically the following: LOK, NORUT, NOIS, CGA Guidelines, Sanctions Ordinance, Criminal Code.

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

The operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.

The operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.

On the basis of the CRA, the AML & KYC Policy must include a Customer Acceptance Policy, on which the proper level of CDD can then be applied. When drawing up its CAP the casino has to comply with its obligations with regard to Politically Exposed Persons (PEP) and Sanctions Screening. The CAP should address the type of players that pose higher than average risk and also indicate the circumstances under which a player is denied.

On the basis of the CRA, the AML & KYC Policy must include a Customer Acceptance Policy, on which the proper level of CDD can then be applied. When drawing up its CAP the casino has to comply with its obligations with regard to Politically Exposed Persons (PEP) and Sanctions Screening. The CAP should address the type of players that pose higher than average risk and also indicate the circumstances under which a player is denied.

The policy must describe the process in place to recognise and report unusual transactions to the Curacao FIU when the threshold of XCG 5,000 is reached. It is important to note the prohibition to disclose a report filed to the FIU. The record keeping requirements for CDD information and transactions also need to be described.

The policy must describe the process in place to recognise and report unusual transactions to the Curacao FIU when the threshold of XCG 5,000 is reached. It is important to note the prohibition to disclose a report filed to the FIU. The record keeping requirements for CDD information and transactions also need to be described.

The policy must describe the risks and potential consequences of violating the policy, including disciplinary actions, legal implications, or busines risks. All staff must confirm awareness and compliance with the AML policy.

The policy must describe the risks and potential consequences of violating the policy, including disciplinary actions, legal implications, or busines risks. All staff must confirm awareness and compliance with the AML policy.

The policy must outline the annual audit plan of the AML program and internal controls.

The policy must outline the annual audit plan of the AML program and internal controls.

The document must provide contact information for any questions regarding the policy which must include the name and email address of the designated contact person.

The document must provide contact information for any questions regarding the policy which must include the name and email address of the designated contact person.

The policy must state that players who do not register themselves will not be allowed to play.

The policy must state that players who do not register themselves will not be allowed to play.

The policy must specify that screening for PEP status should be carried out within 30 days from when a player reaches the deposit threshold even if PEP screening would have already been carried out.

The policy must specify that screening for PEP status should be carried out within 30 days from when a player reaches the deposit threshold even if PEP screening would have already been carried out.

The policy must explain the procedure that needs to be followed when a PEP is identified, including the procedure for obtaining senior management approval, establishing the player's source of wealth and, where applicable, their source of funds and conducting enhanced on-going monitoring of the customer’s activity.

The policy must explain the procedure that needs to be followed when a PEP is identified, including the procedure for obtaining senior management approval, establishing the player's source of wealth and, where applicable, their source of funds and conducting enhanced on-going monitoring of the customer’s activity.

The RG policy must state the operator's record-keeping policy.

The RG policy must state the operator's record-keeping policy.

The RG policy must be include a structured process on flagging potential vulnerable gamblers.

The RG policy must be include a structured process on flagging potential vulnerable gamblers.

The RG policy must contain a structured process for responding to indicators of problem gambling. The key monitoring factors include: - Deposit and wagering frequency - Repeated failed transactions due to insufficient funds - Reversing withdrawals - A pattern of inexplicable extended play sessions - Unreasonable increased communication with customer support, including requests for bonuses - Frequent changes to RG tools - Players maxing out a credit card - Attempts to open multiple accounts to bypass deposit or loss limits

The RG policy must contain a structured process for responding to indicators of problem gambling. The key monitoring factors include: - Deposit and wagering frequency - Repeated failed transactions due to insufficient funds - Reversing withdrawals - A pattern of inexplicable extended play sessions - Unreasonable increased communication with customer support, including requests for bonuses - Frequent changes to RG tools - Players maxing out a credit card - Attempts to open multiple accounts to bypass deposit or loss limits

The RG policy must establish player profiles to assess risk levels.

The RG policy must establish player profiles to assess risk levels.

The RG policy must adopt RBA to determine level of monitoring and intervention.

The RG policy must adopt RBA to determine level of monitoring and intervention.

The RG policy must state that the operators records all RG interactions in the PAM system.

The RG policy must state that the operators records all RG interactions in the PAM system.

The RG policy must define the procedure to be followed for players identified as vulnerable persons.

The RG policy must define the procedure to be followed for players identified as vulnerable persons.

The operator must offer players the option to activate a cooling-off period.

The operator must offer players the option to activate a cooling-off period.

The options for cooling-off may include Duration, brand, vertical and marketing, of which the duration and marketing opt-out are mandatory. Furthermore, the duration must be for a minimum of at least 24 hours.

The options for cooling-off may include Duration, brand, vertical and marketing, of which the duration and marketing opt-out are mandatory. Furthermore, the duration must be for a minimum of at least 24 hours.

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year.

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year.

Players must be able to set limits on the total amount they deposit.

Players must be able to set limits on the total amount they deposit.

Training should cover, at least: - Recognizing signs of gambling distress - Conducting sensitive and structured conversations with at-risk players - Directing players to appropriate support resources and RG tools

Training should cover, at least: - Recognizing signs of gambling distress - Conducting sensitive and structured conversations with at-risk players - Directing players to appropriate support resources and RG tools

The RG policy must state that the operator must not engage in irresponsible advertising, including: - No targeting of Vulnerable Groups - No portrayal of Gambling as an Investment - No misrepresentation of Skill vs Chance - No Emotional Manipulation - Marketing materials must not feature minors or depict them engaging with gambling content - No explicit content - No encouragement of Unrelated Harmful Behaviours - Bonuses and promotions must be communicated transparently - Operators must not use bonuses to encourage excessive gambling - Operator is responsible for materials provided to affiliates, representatives, sponsorships, ambassadors, social media influencers - Operator must make any contracted third-party aware of their RG policy - All advertising must include a clearly visible RG message or slogan

The RG policy must state that the operator must not engage in irresponsible advertising, including: <br>- No targeting of Vulnerable Groups <br>- No portrayal of Gambling as an Investment <br>- No misrepresentation of Skill vs Chance <br>- No Emotional Manipulation <br>- Marketing materials must not feature minors or depict them engaging with gambling content <br>- No explicit content <br>- No encouragement of Unrelated Harmful Behaviours <br>- Bonuses and promotions must be communicated transparently <br>- Operators must not use bonuses to encourage excessive gambling <br>- Operator is responsible for materials provided to affiliates, representatives, sponsorships, ambassadors, social media influencers <br>- Operator must make any contracted third-party aware of their RG policy <br>- All advertising must include a clearly visible RG message or slogan

The operator is advised to remind adults that they should take precautions when sharing devices with minors, such as safeguarding usernames, passwords and payment details.

The operator is advised to remind adults that they should take precautions when sharing devices with minors, such as safeguarding usernames, passwords and payment details.

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours.

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours.

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact.

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact.

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market.

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market.

Complaints related to responsible gaming should be prioritized due to potential impacts on player well-being. Complaints should be categorized as related to responsible gaming in any case when it regards targeting of Vulnerable Players, the availability and/or timely implementation of self-exclusion and/or cooling-off and the mandated consequences therein as outlined in the Responsible Gaming policy.

Complaints related to responsible gaming should be prioritized due to potential impacts on player well-being. Complaints should be categorized as related to responsible gaming in any case when it regards targeting of Vulnerable Players, the availability and/or timely implementation of self-exclusion and/or cooling-off and the mandated consequences therein as outlined in the Responsible Gaming policy.

Operators must use best efforts to resolve these cases within five business days.

Operators must use best efforts to resolve these cases within five business days.

Within two days of receiving a complaint, the operator will: - Confirm receipt of the complaint in writing. - Provide an explanation of how the complaint will be processed. - Provide notice of the average timeline for resolution of such complaints.

Within two days of receiving a complaint, the operator will: <br>- Confirm receipt of the complaint in writing. <br>- Provide an explanation of how the complaint will be processed. <br>- Provide notice of the average timeline for resolution of such complaints.

If more time is needed by the operator to make a reasonable and informed decision, players must be informed of the delay, which cannot exceed two weeks. If a delay is due to a lack of or a slow response from the player, the resolution period may be extended by no more than a further two weeks.

If more time is needed by the operator to make a reasonable and informed decision, players must be informed of the delay, which cannot exceed two weeks. If a delay is due to a lack of or a slow response from the player, the resolution period may be extended by no more than a further two weeks.

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.

Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.

Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.

In light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.

In light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.

ID verification procedure

The RG policy must outline the procedure carried out by the operator to verify the player's age.

Account closure procedure upon the operator becoming aware that the player is a minor post-registration.

The RG policy must outline the procedure for post-registration account closure upon the operator becoming aware that the player is a minor.

Record-keeping

The RG policy must state the operator's record-keeping policy.

Procedure on how the player can contact the operator regarding RG concerns via email or chat

The RG policy must describe the procedure for how the player can contact the operator regarding RG concerns via email or chat.

Must be available in English and target market language

The RG page/policy must be available in English and the site's target market language.

RG policy should include a structured process on flagging potential vulnerable gamblers

The RG policy must include a structured process on flagging potential vulnerable gamblers.

Must have a structured process for responding to indicators of problem gambling

The RG policy must contain a structured process for responding to indicators of problem gambling. The key monitoring factors include: - Deposit and wagering frequency - Repeated failed transactions due to insufficient funds - Reversing withdrawals - A pattern of inexplicable extended play sessions - Unreasonable increased communication with customer support, including requests for bonuses - Frequent changes to RG tools - Players maxing out a credit card - Attempts to open multiple accounts to bypass deposit or loss limits

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Adopt RBA to determine level of monitoring and intervention

The RG policy must adopt RBA to determine level of monitoring and intervention

Record all RG interactions in PAM system

The RG policy must state that the operators records all RG interactions in the PAM system

Procedure to follow for players identified as vulnerable persons

The RG policy must define the procedure to be followed for players identified as vulnerable persons

Operator must offer players option to activate a cooling-off period

The operator must offer players the option to activate a cooling-off period

Options for cooling-off must include duration and marketing opt-out at minimum

The options for cooling-off may include Duration, brand, vertical and marketing, of which the duration and marketing opt-out are mandatory. Furthermore, the duration must be for a minimum of at least 24 hours

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year

Players must be able to set limits on the total amount they deposit

Players must be able to set limits on the total amount they deposit

Operators must train customer service and Responsible Gaming staff to handle player interaction profesionally and effectively

Training should cover, at least: - Recognizing signs of gambling distress - Conducting sensitive and structured conversations with at-risk players - Directing players to appropriate support resources and RG tools

Operators must not engage in irresponsible advertising

The RG policy must state that the operator must not engage in irresponsible advertising, including: - No targeting of Vulnerable Groups - No portrayal of Gambling as an Investment - No misrepresentation of Skill vs Chance - No Emotional Manipulation - Marketing materials must not feature minors or depict them engaging with gambling content - No explicit content - No encouragement of Unrelated Harmful Behaviours - Bonuses and promotions must be communicated transparently - Operators must not use bonuses to encourage excessive gambling - Operator is responsible for materials provided to affiliates, representatives, sponsorships, ambassadors, social media influencers - Operator must make any contracted third-party aware of their RG policy - All advertising must include a clearly visible RG message or slogan

The operator is advised to remind adults that they should take precautions when sharing devices with minors

The operator is advised to remind adults that they should take precautions when sharing devices with minors, such as safeguarding usernames, passwords and payment details.

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market