Definitions “Problem gambling” Exists when gambling activity results in a range of adverse consequences where: the safety and/or well-being of gambling customers and/or their families and friends are placed at risk; and negative impacts extend to the broader community. Some potential harmful effects of problem gambling on individuals and the community are: Personal: stress, depression and anxiety, poor health, suicide Work and study: job loss, absenteeism, poor performance Financial: financial hardships, debts, asset losses, bankruptcy Legal: theft, fraud, scams Interpersonal: domestic violence, relationship breakdown, family neglect Community services: pressure on charities and public spending Requirements Underage gambling It is stated in the Terms and Conditions and the ‘Minor Protection & Parental Control’ section of the site that individuals must be over 18 years of age to register an account with 888bet. Upon submission of the account application form, potential customers are required to check a box, confirming that they accept the Terms of Conditions of the site and that they accept that their age and identity will be verified. Checks are undertaken to verify a customer’s identity when their total bet volume exceeds the currency equivalent of $1,000. Customers are required to provide documents to verify their identity, age, and address. Until a customer successfully passes verification, they will remain unable to process a withdrawal.  However, we do recognise that there is a potential for underage individuals to create accounts using someone else’s identity and as such have implemented a procedure for the management of this type of case. Vulnerable individuals It is stated in the Terms and Conditions that all account applicants must be of ‘legal capacity’ to place a bet or register with 888bet. ‘Legal capacity’ is defined as ‘the capability and power under law of a person to occupy a particular status or relationship with another or to engage in a particular undertaking or transaction’. Although our Terms and Conditions state that individuals must be of legal capacity to hold an account, we recognise the vulnerable persons, including those suffering from mental health conditions may register an account with 888bet. If, during the course of communications with customers, it transpires that they may be suffering from a mental health condition, the vulnerable persons process is immediately implemented. Responsible gambling tools A link to the customer facing Responsible Gambling Policy is provided in the footer of the website. Within this policy there are two key sections which are related to responsible gambling tools: Self-Assessment and Staying in Control. Self-Assessment A link is provided in this section which takes customers to a self-assessment form. The form asks a series of questions about gambling activity and provides a score which helps customers to understand where they sit in terms of problem gambling risk. Staying in Control The Staying in Control section outlines the tools which are available to customers to help them effectively regulate their level of gambling, these include: Limits: Deposit, Stake, and Session Limits Time-Out (also called ‘Take A Break’) Self-Exclusion (or Account Deactivation) Set Limits Deposit Limit Customers may want to set a daily (calculated on a 24-hour basis), weekly (calculated on a 7-day basis) and monthly (calculated on a 30-day basis) deposit limit to manage the amount they want to deposit and spend using their betting account. Once a limit has been met, customers will not be able to deposit any amount until after the set period has expired. Customers have the option to decrease or increase their deposit limits. Any decrease to these limits will come into effect immediately; any increase will only become effective if, after 24 hours, the customer confirms via his/her account that he/she still wishes to have the higher limit(s). Stake Limit Customers may want to restrict the total amount they bet on a Sports or Casino game. With a stake limit in place, they will not be allowed to make a larger bet that would exceed the self-set limit. This facility allows customers to have Sports betting and/or Casino stakes up to their selected amount per 1, 2, 3, 4, 5, or 6 days, week, or month. Session Limit Customers may also select a session limit, which would limit the amount of time they can spend wagering on Sports and Casino within a single login session. Once the self-set limit has been reached, a customer will not be able to continue playing and will need to log in again if he/she wishes to make a new wager. Customers can set the above limits via “Account Settings/Limits” in their account. Time-Out / Take A Break Customers can use the time-out facility if they need to fully concentrate on other things (i.e., studies, work, family, etc.). The minimum time-out period is 12 hours, and the maximum is 6 months. During that time, customers will be able to log into their account and withdraw any outstanding winnings; what they will not be able to do is play. It shall be noted that no marketing emails or promotions will be sent to a customer whose account has been set on a time-out. Such an account will automatically become active once the selected period has ended. However, customers have the option to request the reopening of their account earlier should they wish to do so. It will take 7 days for the request to become effective. Customers can select the “Take A Break” facility under “Account Settings/Limits” in their account. Self-Exclusion/Account Deactivation Anyone having, or being at risk of, developing a gambling addiction is strongly encouraged to self-exclude. Customers can choose to self-exclude for the following periods: 6 months, 1 year, 2 years, 3 years, 5 years or permanently. No marketing material will be sent during self-exclusion periods. Account access will not be possible, so customers will have to contact our customer support team if they have any outstanding bets or balance on their account. Upon completion of the self-exclusion period the customer will be given the option to extend. Should he/she wish to reopen the account instead, he/she will need to contact our customer support team. During self-exclusion, customers are not allowed to create a new account to continue betting. Any attempt to do so will be in breach of our Terms and Conditions and may result in the permanent ban of the original account. Customers can self-exclude/deactivate their account by selecting “Deactivate Account” under “Account Settings” in their account. FAQs There is also a section about responsible gambling within the Frequently Asked Questions (“FAQs”) section of the site. As well as reiterating the information stored in the customer facing Responsible Gambling Policy, there is also a section entitled ‘How do I gamble responsibly’ which provides tips to help customers self-regulate their activity: Follow these tips for gambling responsibly to be able to fully enjoy your gambling experience. Gamble for fun only - gambling is not a way of making money Never gamble with money you cannot afford to lose Set a deposit limit – decide how much money you can afford to lose in a day/week/month before you start gambling Stop gambling if you have lost your set daily/weekly/monthly limit – do not chase your losses Decide how much time per day/week/month you shall spend gambling. Do not forget your other hobbies – they deserve some of your time, too Do not gamble if you feel stressed, emotionally upset, or simply cannot concentrate – take a break instead Do not gamble if you are under the influence of alcohol or drugs Seek help immediately if you realize you have a gambling problem Sign posting A link to our customer facing Responsible Gambling Policy is provided in the footer of our website. The same information can also be found in our Responsible Gambling FAQ section. Within this customer facing policy there is a section entitled Further Help, which directs customers to appropriate local self-help charities. Behaviour monitoring 888bet has established a range of financial and behaviour triggers which are used to help identify potential problem gambling. The type of triggers we use to monitor gambling activity include: Bet frequency Stake increase When reviewing accounts which have been flagged under the trigger-based system, 888bet considers different factors to determine what further actions need to be taken. These factors include, but are not limited to: Previous interaction history Attitude and behaviour when dealing with the Customer Services team Time spent gambling Velocity of bet placement Number of bets placed as opposed to simply money lost Frequent changes to deposit limits Frequent time-outs Spikes in gambling activity Age of the customer Previous self-exclusion Erratic stakes Net loss Interaction 888bet has developed a range of different ways to interact with a customer who it has identified as a displaying potential problem gambling behaviour. These include but may not be limited to: Sending a ‘soft’ interaction email to make sure the customer is aware of the responsible gambling tools we have available Sending a tailored email prompting a reply from the customer to make sure they are not feeling at risk of developing a gambling problem or currently have a gambling problem Attempting to call the customer to discuss their activity directly Encouraging the customer to implement an appropriate responsible gambling tool Recommending the customer for operator exclusion to Senior Management Guidance on how such interactions should be undertaken/structured is provided by the Compliance team in the Interaction Procedure. Details of all interactions, via email or telephone call, are saved within the customer communication tool ‘Zendesk’ and staff are also required to leave audit notes in the Pronet system on individual customer accounts. Self-harm 888bet recognises that occasionally gambling related harm can become so severe that its customers may consider self-harming; threatening to self-harm, committing suicide, or threatening to commit suicide. A detailed process has been implemented for staff to use when dealing with such situations via both direct and indirect contacts (for example social media posts). Staff training All relevant staff receive responsible gambling training, which is bespoke to their role. This includes but is not limited to ensuring staff are able to: Identify potential problem behaviour (signs that can indicate whether a customer has a gambling issue) Respond appropriately to the customer's concerns (have effective conversations and interactions in the context of the diversity of customer incidents) Where appropriate, inform customers about gambling help services, including the Company’s internal responsible gambling tools Carry out all types of interactions, which are logged and recorded in our back-office system Where appropriate suspend the account to prevent further activity Follow processes and procedures on how to escalate relevant cases to the correct level of management or the Compliance team Training is delivered whenever required, for example whenever there is a regulatory update or when process changes are implemented. Irrelevant of updates, refresher training is delivered at least annually. Publication Staff are made aware of this policy as part of their initial onboarding process and are required to confirm that they have reviewed and understood the document within two weeks of the beginning of their employment with 888bet. This policy is reviewed at least annually or more frequently when changes in the regulatory environment occur. Upon update of the policy, all staff are notified via email and are encouraged to review the most recent version. Policy Effectiveness All staff are required to confirm to the Compliance team, that they have reviewed and understood this policy within two weeks of them beginning their term of employment with 888bet. The Compliance team also completes regular spot checks of the handling of Responsible Gambling procedures to ensure that operations are being undertaken in accordance with this policy. In instances whereby non-compliance with the policy is identified, this will be fed back to relevant heads of department and process changes/additional staff training will be implemented where required.