Orange Entertainment B.V.

Responsible gambling policy

1. Introduction

This Responsible Gaming Policy outlines the principles and procedures applied by Orange Entertainment B.V. to ensure that all gaming activities are conducted responsibly and in compliance with the requirements of the Curacao Gaming Authority.

The purpose of this Policy is to protect vulnerable persons, prevent gambling-related harm, and promote a safe and transparent gaming environment.

It applies to all staff, systems, and third parties involved in the operation of the Company’s licensed online gaming platforms.

2. Policy overview

2.1 General Responsible Gaming Policy

The Company is committed to maintaining a safe, transparent, and fair gaming environment where gambling remains an enjoyable form of entertainment rather than a source of harm. The Company integrates Responsible Gaming principles into all areas of its business operations and applies proactive measures to prevent gambling-related harm and protect vulnerable persons.

The Responsible Gaming framework of the Company includes the following core elements:

• A clear Responsible Gaming Policy that is easily accessible to players at all times.
• A comprehensive suite of Responsible Gaming tools and educational resourcesdesigned to promote healthy play and prevent excessive gambling.
• Continuous monitoring mechanisms to identify and address early signs of problematic gambling behaviour.
• Full compliance with applicable regulatory reporting, monitoring, and auditing obligations

The Company does not offer a credit to players for the purpose of gambling under any circumstances.

The Responsible Gaming Policy is reviewed annually and submitted to the Curacao Gaming Authority for evaluation and approval. All material changes are reported to the CGA in accordance with licensing requirements.

2.2. High-Risk Business Model

As the players may include VIP/high-roller players, the Responsible Gaming Policy incorporates enhanced measures proportionate to these risks. Such measures include increased monitoring frequency, advanced behavioral analytics, and mandatory escalation protocols to ensure the highest standard of player protection.

The Company does not allow direct cryptocurrency usage or any intermediary/agent account.

3. Mandatory requirements

The Company implements the following Responsible Gaming measures as mandatory components of its operational framework in compliance with the licensing requirements of the Curacao Gaming Authority.

These elements are integrated into the Company’s daily operations, systems, and player interaction procedures to ensure continuous compliance and effective harm prevention.

3.1. Core Responsible Gaming Elements

The mandatory elements include:

1. Age Verification – strict prevention of underage gambling through multi-layered age and identity checks.

2. Information Accessibility – ensuring that all Responsible Gaming tools, policies, and resources are easily accessible and clearly visible to players.

3. Player Self-Assessment – availability of self-evaluation tools to help players recognize risky behaviours.

4. Behaviour Tracking – systematic monitoring of player activity and early detection of potential problem gambling indicators.

5. Cooling-Off Periods – functionality enabling players to take short-term breaks from gambling activities.

6. Self-Exclusion – effective, long-term exclusion options available to players across all brands and platforms.

7. Deposit Limits – player-controlled financial limits (daily, weekly, and monthly).

8. Consumer Advertising and Marketing Controls – responsible promotional practices that do not target vulnerable persons.

9. Staff Training and Readiness – regular training of employees involved in customer- facing and marketing functions.

These elements collectively form the Company’s Responsible Gaming control environmentand are continuously tested, reviewed, and enhanced to align with evolving regulatory expectations and operational risks.

3.2. Responsible Gaming Governance and Accountability

The Company designates a competent person responsible for overseeing Responsible Gaming activities within the organization. Until a dedicated Responsible Gaming Officer is appointed, the Compliance Officer (separate from the AML/CFT function) assumes this responsibility.

The Responsible Gaming Officer is responsible for:

• implementing and enforcing this Policy across all departments and operational entities;
• ensuring that all Responsible Gaming controls are functioning effectively;
• eviewing incidents and escalating material findings to senior management;
• preparing and submitting an annual Responsible Gaming Effectiveness Report to management, summarizing operational performance, identified deficiencies, and recommendations for improvement.

This report is presented at least once every twelve (12) months and serves as the basis for management review and strategic updates to the Company’s Responsible Gaming program.

4. Prevention of underage gambling

The Company enforces robust measures to ensure that no individual under the legal gambling age participates in any gambling activity provided under the Company’s Curacao gaming licence.

Preventing underage gambling is a cornerstone of the Company’s Responsible Gaming framework and is treated as a matter of zero tolerance.

4.1. Age Verification

The Company doesn’t permit minors to participate in games of chance.

The Company applies a multi-layered age verification process designed to confirm that all players are of legal gambling age (18 years or older).

4.1.1 Verification Process

• During account registration, each player must declare their date of birth and confirm that they are over 18 years of age by selecting an explicit confirmation checkbox.
• The system automatically blocks registration attempts where the entered date of birth indicates that the individual is underage.
• Prior to the withdrawal which exceeds 2,000 EUR, and in any case upon reaching thresholds defined under the Company’s KYC and AML procedures, the player must submit a valid government-issued identity document (such as a passport, national ID, or driver’s licence).
• The document is verified through secure third-party services and/or manual review by the Company’s verification team.

4.1.2 Supplementary Verification Measures

The Company may, where appropriate, apply additional verification controls including:

• electronic database or government registry checks;
• payment method validation;
• selfie or biometric verification;
• cross-checks with third-party identity verification providers.

These methods are used to enhance assurance but do not replace the requirement for government-issued ID verification.

4.1.3 Detection and Action in Case of Minor Accounts

If, at any stage, it is discovered that an individual registered or engaged in gambling while

being a minor:

• the player account is immediately closed;
• all deposited funds are refunded to the payment source, and any winnings are forfeited;
• the player is notified in writing of the reason for the account closure;
• internal records are updated and flagged to prevent re-registration attempts.

4.1.4 Record Keeping

The Company maintains comprehensive records of all age verification checks performed, including:

• verification dates and methods used;
• document types and verification results;
• any exceptions or escalations handled.

4.1.5 Awareness and Communication

The Company prominently communicates the prohibition of underage gambling by:

• displaying the “18+” symbol and warning notices on its websites and mobile applications;
• including an explicit statement in the footer of each website confirming that gamblingis prohibited for minors;
• ensuring that all marketing, promotions, and social media

5. Player information and accessibility

The Company ensures that all information related to Responsible Gaming is easily accessible, clearly visible, and presented in a manner that enables players to make informed decisions.

5.1. Responsible Gaming Section and Accessibility

The Company maintains a dedicated and easily identifiable Responsible Gaming Section on all brand websites and mobile applications.

A clear and permanent link to this section is displayed on the homepage and within navigation menus, ensuring that players can access Responsible Gaming information at any time.

The Responsible Gaming Section:

• provides clear and easily understandable information on how players can manage their gambling activity responsibly;
• offers direct access to Responsible Gaming tools, including self-exclusion, cooling-off periods, limit setting, and reality checks;
• includes contact option (email) for Responsible Gaming inquiries;
• is available in English and in the language of the target market, with English prevailing in the event of discrepancies.

All Responsible Gaming information is presented in clear, accessible language and reviewed regularly to ensure compliance with regulatory requirements and player protection standards.

5.2. Terms & Conditions Inclusion

The Company explicitly references Responsible Gaming obligations and tools within its Terms & Conditions (T&C).

Accordingly:

• the Responsible Gaming Section is incorporated by reference in the T&C and linked within one click from the homepage;
• the T&C contain a clear explanation of available player protection tools (self- exclusion, deposit limits, cooling-off, etc.) and their functionality.
• all information regarding Responsible Gaming measures is presented in a transparent and comprehensible way, ensuring that players understand how to activate and use each feature.

The Responsible Gaming provisions within the T&C are updated promptly following any regulatory or operational change.

5.3. Footer Information Requirements

The Company ensures that every website and application operated under its license includes, in the footer of the homepage, the following mandatory information:

• A clear and visible indication that underage gambling (under 18) is prohibited.
• The name and registered address of the licensed company.
• The official licence number issued by the Curacao Gaming Authority (CGA).
• A statement confirming the regulatory oversight of the Company’s operations by the CGA.
• A link to the Responsible Gaming Section.
• The CGA Digital Seal issued to the licensee.
• A direct link to one or more reputable problem-gambling support organizations, such as GamCare, Gamblers Anonymous.

All such links are periodically reviewed to ensure functionality and relevance.

6. Self - assessment

The Company promotes player awareness and self-control by providing transparent access to account information and practical tool for self-evaluation.

These mechanisms enable players to monitor their gambling activity, recognize early warning signs of harm, and make informed decisions about their play.

6.1. Access to Account History

The Company provides players with access to their gaming and transactional history through the player account interface, subject to technical availability and third-party provider integrations.

Available account information may include:

• timestamps of deposits, withdrawals, wagers, and wins;
• amounts and types of games played;
• active bonuses or limits applied to the account.

Where full historical data is not directly accessible via the player interface due to third-party system limitations, players may request extended or consolidated account history from Customer Support.

Upon request, the Company provides available historical gaming and transactional data within ten (10) working days.

All account data are stored and processed in accordance with applicable data-protection and retention requirements.

6.2. Purpose of Self-Assessment

The self-assessment process encourages players to regularly reflect on their gambling behaviour and to recognise whether their activity remains within healthy, recreational limits

The Company provides tools and questionnaires that help players identify potential risks and take control of their behaviour before it escalates into harm.

Players are prompted, both proactively and through the Responsible Gaming Section, to complete a voluntary self-assessment whenever behavioural markers indicate signs of potential risk (e.g., increased frequency of play, cancelled withdrawals, repeated limit changes).

6.3. Self-Assessment Tools Provided

The Company provides access to a self-assessment screening tool to assist players in evaluating their gambling behaviour.

The Gamblers Anonymous 20-Question Test is accessible via the Responsible Gaming Section and linked to the official website of Gamblers Anonymous (https://gamblersanonymous.org/20-questions/).

The Company issues periodic reminders, at least every six (6) months, through an on-platform pop-up notification directing players to the Responsible Gaming Section where the self assessment tool is available.

7. Behavior tracking

The Company applies proportionate and structured monitoring of player behaviour in order to identify potential indicators of gambling-related harm and to implement timely and appropriate interventions where necessary.

Behaviour monitoring forms part of the Company’s Responsible Gaming framework and is conducted in accordance with applicable regulatory requirements, including the prohibition on offering gaming opportunities to individuals who may reasonably be considered vulnerable.

The monitoring approach is risk-based and considers patterns of behaviour rather than isolated events.

7.1. Key Risk Indicators

The Company monitors behavioural and transactional indicators that may suggest elevated risk. These may include, but are not limited to:

• Sudden or significant increases in deposit or wagering frequency;
• Repeated failed payment attempts due to insufficient funds;
• Frequent cancellation of withdrawal requests;
• Prolonged or intensive gaming sessions;
• Frequent changes to deposit, loss, or session limits;
• Repeated use of cooling-off periods;
• Multiple account attempts intended to bypass restrictions;
• Signs of distress or agitation communicated to Customer Support.

The presence of a single indicator does not automatically classify a player as experiencing gambling harm. Risk assessment is based on the overall behavioural pattern.

7.2. Escalation and Intervention Process

Where behavioural indicators suggest elevated risk, the Company applies a graduated and proportionate intervention approach:

1. Informative Intervention

The player may be contacted and reminded of available Responsible Gaming tools, including deposit limits, time-outs, and self-exclusion options.

2. Restrictive Measures

Where appropriate, the Company may apply proportionate restrictions, such as deposit limits or temporary account suspension pending review.

3. Account Closure

In cases of persistent or severe risk, the Company may close the account in order to prevent further harm.

All measures are applied in a manner that is proportionate, documented, and consistent with internal procedures.

7.3 Documentation and Record-Keeping

All Responsible Gaming interactions, whether initiated by the player or the Company, are recorded in the Player Account Management (PAM) system.

Records include:

• the identified indicator(s);
• actions taken;
• date and responsible staff member.

This ensures traceability, accountability, and regulatory compliance.

7.4 Protection of Legitimate Withdrawals

Under no circumstances shall Responsible Gaming measures be used as a pretext to delay, refuse, or interfere with legitimate withdrawal requests.

Responsible Gaming interventions are applied solely for player protection purposes and not for commercial advantage.

8. Cooling-off and self exclusion

The Company maintains effective processes and technological tools that empower players to manage their own gambling behavior through self-regulation and temporary or long-term restrictions.

Two mechanisms are permanently available via the Responsible Gaming Section on all Company websites and applications:

• Cooling-Off: a short-term, temporary restriction from gambling activities, customizable by the player.
• Self-Exclusion: a long-term, irrevocable exclusion from all gambling activities covered by the Company’s license.

Players are free to choose either mechanism without influence or persuasion from the Company.

The Company prohibits any bonuses, incentives, or reassurances intended to discourage players from activating these options.

Players are clearly informed of the differences between both mechanisms before confirming their selection.

8.1. Cooling-Off

8.1.1 Overview

The Company offers players the option to activate a Cooling-Off period during which they are temporarily restricted from gambling activity. The Cooling-Off period can be activated online through the Responsible Gaming tools available in the Player’s account.

When submitting the request, the player must specify the selected duration and confirm their marketing opt-out preference.

8.1.2 Duration Options

Available durations include:

• 24 hours
• 7 days
• 1 month
• 3 months

8.1.3 Actions and Implementation

The restrictions take effect immediately upon activation.m

The Company:

• does not question or discourage the player’s decision;
• does not offer bonuses or promotions during this period;
• ensures that activation of the Cooling-Off period is not subject to unnecessary delay.

For Cooling-Off periods of one (1) or three (3) months, the Company may request an online confirmation (“You wish to cool off for one month. Please confirm.”) — expressed neutrally and processed automatically.

Player Account Management:

During the Cooling-Off period, player funds remain accessible for withdrawal, and the account stays open while all gambling functions are disabled.

Marketing and Communications:

Players who have opted out of marketing do not receive any promotional content throughout the Cooling-Off period, and no bonuses, free play, or other incentives are offered during this time.

8.1.4 Reactivation

After the selected Cooling-Off period expires, the account is automatically reactivated. No further player action is required.

8.2. Self-Exclusion

8.2.1 Overview

The Company enables players to self-exclude from all gambling activities for a fixed, non- revocable duration.

The self-exclusion parameters include:

1. Duration: minimum of one (1) year.

2. Vertical: all forms of gambling activity.

3. Marketing: automatic opt-out from all promotional communications.

Players may activate self-exclusion online through the Responsible Gaming tools available in their player account.

8.2.2 Duration Options

The following durations are available:

• 1 year
• 3 years
• 5 years
• 10 years
• Lifetime

8.2.3 Actions and Implementation

The self-exclusion takes effect immediately after activation.

The Company ensures that:

• player accounts are closed and login access is disabled;
• all wagering after the self-exclusion request but before enforcement is voided andrefunded to the player (subject to AML/CFT controls);
• any ongoing tournaments may be completed before closure;
• contributions to progressive jackpots remain valid but participation ceases after exclusion.

Verification and Consent:

The player confirms awareness of the exclusion duration through a neutral online confirmation (e.g., “You have chosen to self-exclude for five years. Please confirm.”).

Duplicate Account Prevention:

The Company maintains robust procedures to detect and block new accounts attempted by self-excluded individuals, including name, email, payment method, and device checks

Marketing and Communications:

No direct or indirect marketing communications are sent to self-excluded players for the duration of the exclusion.

8.2.4 Reactivation

At the end of the self-exclusion period, the player must submit a written request (via email) to reopen their account. Reactivation cannot occur automatically and cannot be initiated by the Company. The exclusion remains irreversible and irrevocable for the full selected duration.

The Company retains all records of self-excluded players in accordance with applicable retention periods. Any known payment method linked to a self-excluded player is blocked for future use during the exclusion period to prevent circumvention.

8.3. Operator-Initiated Exclusion

The Company reserves the right to exclude a player as part of its Responsible Gaming and risk- management procedures where necessary to prevent gambling-related harm.

Operator-initiated exclusion may be applied when:

• a player displays persistent problematic gambling behaviour;
• there is reasonable evidence of criminal or fraudulent activity on the account;
• the exclusion is deemed necessary to protect the player or the integrity of operations.

Operator-initiated exclusions are fully documented, justified, and recorded in the Playerb Account Management (PAM) system.

All records are retained for a minimum of five (5) years and are made available to the Curacao Gaming Authority upon request.

Players are notified in writing of the exclusion reason and duration.

9. Limits

The Company provides players with tools to control their gambling activity by setting deposit limits. Players may establish deposit limits on a daily, weekly, or monthly basis.

Deposit limits may be requested by contacting Customer Support via email and will be applied without undue delay upon processing of the request.

9.1. Deposit Limits

Players may set a restriction on the total amount they are permitted to deposit within a defined period (daily, weekly, or monthly).

The following principles apply:

• Once a deposit limit is reached, no further deposits may be made until the relevant period resets.
• Requests to increase an existing limit (making it less restrictive) take effect after a mandatory 24-hour waiting period.
• Requests to decrease a limit (making it more restrictive) take effect immediately.
• Any wagers placed prior to the activation or modification of a deposit limit remain valid.

Deposit limits apply only to new deposits made after implementation.

9.2. Exceptions to Limits and Exclusions

Where a deposit limit or restriction is activated while a player is engaged in ongoing gameplay or has unresolved wagers (including tournaments or future-event bets), the following applies:

• No new deposits or wagering activity may be initiated after activation of the limit.
• Existing gameplay or previously placed wagers may continue until completion.
• Upon completion of the active gameplay or wager, the restriction applies fully.

9.3 Transparency

Information regarding deposit limits and modification rules is available within the Responsible Gaming Section and player account settings.

Players receive confirmation when a limit is set or modified.

10. TRAINING AND STAFF READINESS

The Company trains all customer service and Responsible Gaming staff to handle player interactions professionally, empathetically, and in accordance with Responsible Gaming standards.

Training covers, at minimum:

• recognising signs of gambling distress, such as agitation, aggression, or financial desperation;
• conducting sensitive and structured conversations with at-risk players;
• directing players to appropriate support services and Responsible Gaming tools.

Training materials are reviewed periodically to ensure alignment with regulatory updates and best practices in Responsible Gambling management.

11. Consumer advertising and marketing

The Company does not engage in irresponsible advertising or any activity that could encourage excessive or harmful gambling.

All marketing and communication activities comply with Curacao Gaming Authority standards and Responsible Gaming principles.

The following requirements apply:

• No targeting of vulnerable persons: Marketing, including all visual materials, must not directly or indirectly target vulnerable groups or minors.
• No portrayal of gambling as an investment: Advertising must not depict gambling as a means to achieve financial success or resolve financial issues.
• No misrepresentation of skill versus chance: Marketing materials must not suggest that skill can influence the outcome of games of chance.
• No emotional manipulation: Gambling must never be presented as a substitute for emotional, mental, or financial well-being.
• No minors or inappropriate content: Marketing materials must not include minors or depict them engaging with gambling content.
• No explicit or sexualised content: All adverts and messaging must remain appropriate and free of any pornographic or suggestive imagery.
• No linkage with harmful behaviors: There must be no association between gambling and smoking, drug or alcohol use, seduction, or enhanced attractiveness.
• Bonus transparency: All bonuses and promotions are communicated clearly, with full terms and conditions available to players.

Bonuses must not be used to promote excessive gambling or encourage risky behavior.

• Third-party involvement: The Company remains responsible for all materials prepared or distributed by affiliates, representatives, sponsorships, ambassadors, or paid social media influencers.

All third parties must be made aware of, and agree to comply with, the Company’sResponsible Gaming Policy.

• Responsible Gaming message: Every advertisement must include a clear and visible Responsible Gaming message or slogan.

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