Responsible Gaming Hub

Responsible Gaming Policy

Lottorbit · Version 1.0

1. Introduction and Commitment

1.1. Lottorbit is in the process to be licensed and regulated by the Tobique Gaming Commission ("Commission"). Lottorbit ("we", "us", "the Company") is committed to providing gaming services that are safe, fair, and conducted responsibly. This Responsible Gaming Policy ("Policy") sets out the measures we take to help players stay in control of their play, and reflects the requirements of the Tobique Gaming Act 2023 ("Gaming Act") and the General Code of Practice for Remote Gaming License Holders ("the Code") issued by the Commission.

1.2. This Policy forms part of, and should be read together with our Terms and Conditions. It applies consistently across all brands and products operated by the Company.

1.3. Gambling should always be an entertaining activity. If it stops being enjoyable, or starts to affect finances, relationships, work, or wellbeing, we encourage all players to use the tools described in this Policy and to seek independent support.

2. Accessing This Policy

2.1. A direct link to our Responsible Gaming page shall be provided on our homepage, our account registration page and gaming pages. This link is accessible in one click from wherever it appears.

2.2. Our Responsible Gaming page does not carry commercial advertising or promotional material.

3. Information and Support

3.1. Our Responsible Gaming page includes: a statement of our commitment to responsible gaming; details of this Policy; guidance on responsible play; a self-assessment tool and a direct link and contact details for at least one independent organisation dedicated to treating and/or supporting problem gamblers.

3.2. All players are encouraged to contact one of these organisations if they are concerned about their own gambling activity. Reaching out does not affect a player's ability to continue using our other services in the meantime, except where a limit or exclusion has been applied.

3.3. Gambling should be paid for out of disposable income. Players should not gamble beyond what they can afford to lose, and not to chase losses.

4. Responsible Gaming Manager

4.1. We have designated a named Responsible Gaming Manager ("RGM") responsible for formulating our responsible gaming policies and procedures, including staff training on their implementation.

4.2. Our RGM is appropriately trained in responsible gaming policies and procedures, and has sufficient authority to develop, communicate, implement, and maintain responsible gaming practices throughout the Company and, where relevant, with any partner organisations.

4.3. All customer-facing staff and agents are trained to recognise signs of problem gaming and to respond appropriately to contact relating to it. This training is refreshed at least annually, and staff completion is recorded.

5. Monitoring for Signs of Problem Gambling

5.1. We monitor customer behaviour and play patterns for indicators that may be symptomatic of problem gambling, and take the measures described in Clause 7 (Self-Exclusion) where such indicators are identified.

5.2. We work with the Commission, our Direct Licensee where appropriate, to establish and refine techniques for identifying and discouraging problem gambling.

5.3. We take all reasonable steps to prevent a person under the minimum permitted age of 18 from participating in our gaming activities. Further details of which are set out in our Terms and Conditions policy.

6. Gaming Management Tools

6.1. We provide tools to help all players monitor, manage, and control their gaming behaviour. These tools, and how to use them, are described clearly and are readily accessible on our website.

6.2. Players may set a gaming management control as part of registration, at the point of first deposit, or at any time afterwards. Our process for doing so is user-friendly and to promote a safe gambling environment.

6.3. We offer the following gaming management options:

• Deposit limits — an overall maximum deposit limit over a specified period of time.
• Loss limits — an overall cumulated maximum loss limit over a specified period.
• Session limits — This creates a reminder of the length of time a player has been logged in to our gaming facilities.

6.4. Should a player request one of these, we will implement the relevant limit(s) as soon as reasonably practicable. Should a player wish to increase a limit, the increase will only take effect after a 24-hour cooling-off period.

6.5. Where we suspect a problem gaming instance, we may set our own gaming management limits on an account. If we do so, we shall inform the player accordingly.

6.6 We may from time to time contact players via email with a reminder of the responsible gaming tools that are available to them.

7. Self-Exclusion

7.1. A player may request to be excluded from our gaming facilities for a defined period or permanently, at any time. Requests are recorded and implemented as soon as practicable, and our exclusion procedures are described clearly on our Responsible Gaming page.

7.2. A self-exclusion request is implemented consistently across all brands and products under our control.

7.3. Once a self-exclusion request has been processed: no new bets or deposits will be accepted from a player account until the exclusion has expired or been removed; players will not be prevented from withdrawing any or all of their account balance during the exclusion period.

7.4. Following an exclusion of six months or more, we will invite players to confirm, via a documented process, that they wish to resume gaming before their account is reinstated.

7.5. We may exclude a player at our discretion where we have reason to believe:

• Cheating or colluding with other participants;
• Improper behaviour (visible signs of problem gaming, in which case we will direct all players to our gaming management tools;
• A player appears to be under the influence of alcohol or narcotics.

7.6. We shall take reasonable steps to prevent our marketing material from being sent to players who are subject to self-exclusion or an exclusion we have imposed.

7.7. If a self-excluded customer is able to breach our exclusion system and is subsequently detected, reimbursement of deposits made during the breach is at our discretion, having regard to the customer's history. Breaches of self-exclusion will not be incentivised by the automatic reimbursement of deposits or the payment of winnings.

7.8. We report details of self-excluded customers, including any exclusions we have imposed at our discretion, to the Commission as part of our quarterly reporting.

8. Underage Gambling

8.1. Persons under the age of 18 are not permitted to hold an Account or participate in our gaming activities. Should we become aware that an underage individual has participated in gaming, we will suspend the relevant Account, report the matter to the Commission, and apply the treatment of deposits and winnings set out in our Terms and Conditions.

8.2. Our marketing is not directed at, or designed to appeal to, persons under 18.

9. Review of This Policy

9.1. We review this Policy at least annually, and more frequently where required by changes to the Gaming Act, the Code, or our own procedures.