COMPLAINTS POLICY

I. INTRODUCTION

3-102-961212 Sociedad de Responsabilidad Limitada (“the Company”) is committed to providing all players with a fair, transparent, and efficient complaints and dispute resolution process.

This Complaints Policy has been developed in accordance with the applicable requirements of the Anjouan Gaming regulatory framework and the standards issued by the Anjouan Gaming Authority (“AGA”).

The purpose of this Policy is to ensure that every player has access to a clear, impartial, and effective mechanism for resolving complaints free of charge, including access to independent Alternative Dispute Resolution (“ADR”) services where applicable. The Company handles all complaints in good faith, with the aim of reaching fair outcomes based on evidence, applicable law, and its Terms and Conditions.

This Policy is publicly available on the Company’s website and forms an integral part of its Terms and Conditions.

II. SUBMITTING A COMPLAINT

Players may submit formal complaints concerning disputes arising from the Company’s licensed gaming activities, subject to the following submission deadlines:

• Game outcome disputes: within fourteen (14) calendar days of the relevant gaming session;

• Account-related disputes, including payments, account suspensions and bonuses: within thirty (30) calendar days of the relevant incident.

All formal complaints must be submitted through the complaint submission mechanism accessible via the Interactive Site Seal displayed on the Company’s website.

Complaints submitted through alternative channels may not be recognised or processed as formal complaints under the applicable regulatory complaints procedure.

Complaints should include sufficient information to enable the Company to identify the player, understand the nature of the dispute and conduct an appropriate investigation. Supporting documentation may be requested where reasonably necessary.

Only the registered account holder may submit a complaint concerning their gaming account, unless otherwise permitted by applicable law.

All formal complaints and related communications shall be conducted in English.

III. VALID GROUNDS FOR COMPLAINT

Players may submit complaints relating to the Company’s licensed gaming activities, including but not limited to:

• Deposit and withdrawal issues;

• Bonus and promotional terms;

• Account closures, suspensions or restrictions;

• Game outcomes and alleged gaming errors;

• Responsible Gaming measures;

• Player balances and transactions;

• KYC and account verification procedures;

• Software or technical malfunctions affecting gaming activities;

• Alleged unfair treatment or breaches of applicable gaming requirements.

The following matters fall outside the regulatory player complaints procedure:

• Complaints submitted by players located in excluded territories;

• Claims unrelated to the Company’s licensed gaming activities;

• Complaints escalated before the applicable thirty (30) calendar-day operator review period has elapsed;

• Commercial disputes, including contractual, affiliate, intellectual property, trademark and domain name disputes.

Commercial disputes shall be addressed through the competent courts or appropriate arbitration mechanisms, where applicable.

IV. COMPLAINT HANDLING AND RESPONSE TIMEFRAMES

The Company shall investigate and respond to formal complaints within thirty (30) calendar days of receipt.

Upon receipt of a complaint submitted through the designated Interactive Site Seal mechanism, the Company shall assess its nature, review the relevant circumstances and conduct an appropriate investigation.

Where additional information or documentation is reasonably required, the Company may request such information from the player.

The Company shall make reasonable efforts to ensure that requests for additional information do not unnecessarily delay the investigation or prevent compliance with the applicable regulatory timeframe.

In exceptional circumstances, where the complexity of the complaint or other justified reasons require additional time, the investigation may take longer than thirty (30) calendar days. In such cases, the Company shall inform the player of the delay, explain the reasons for it and provide an estimated timeframe for resolution.

The Company may communicate with the player during the investigation to request clarification, provide relevant updates or facilitate resolution.

The investigation shall be conducted fairly, objectively and in accordance with the Company’s applicable internal procedures and regulatory obligations.

V. RESOLUTION AND ESCALATION

Once a full review of the complaint has been completed, the player will receive a final written response.

The response will clearly outline:

• The outcome of the investigation and the reasoning behind the decision;

• Any corrective or remedial action, where applicable; or

• The reasons why the complaint could not be upheld or processed.

If the player is dissatisfied with the outcome or if the complaint remains unresolved within the applicable regulatory timeframe, the player may escalate the matter to an independent Alternative Dispute Resolution (ADR) provider.

The Company’s appointed ADR provider is:

Website:

Email:

Additional contact details:

All ADR services will be provided in accordance with the applicable rules and procedures of the appointed ADR provider. The ADR process is conducted in English.

The ADR decision is final within the ADR procedure and the same dispute may not be submitted to another ADR provider once a final decision has been issued. If the player withdraws from the ADR process before completion, the matter will be deemed closed.

Nothing in this section limits the player’s right to pursue any remedy available under applicable law or to initiate legal proceedings independently of the ADR process.

VI. RECORD-KEEPING AND REGULATORY REPORTING

The Company maintains records of all complaints, correspondence, evidence, and outcomes for a minimum period of five (5) years or as otherwise required by applicable law.

Complaint records are maintained for internal compliance purposes and may include:

• Number of complaints received;

• Categories of complaints;

• Resolution outcomes;

• Complaints escalated to ADR;

• Pending complaints.

Where required by applicable regulatory guidance, the Company may provide complaint-related information to the Anjouan Gaming Authority.

VII. ARTIFICIAL INTELLIGENCE IN COMPLAINT MANAGEMENT

The Company may use Artificial Intelligence (“AI”) tools to assist in the classification and administrative handling of complaints.

AI tools are used solely as a support mechanism and do not replace human decision-making in complex or sensitive cases, including Responsible Gaming matters and disputes requiring legal or regulatory interpretation.

All final decisions are made by qualified personnel.

VIII. GOVERNANCE AND REVIEW

The Company shall periodically review this Policy to ensure its continued effectiveness and alignment with applicable regulatory requirements.

The Policy shall be updated where necessary to reflect changes in regulatory obligations, operational procedures or the Company’s complaints handling arrangements.

Responsibility for the implementation and oversight of this Policy shall rest with the Company’s designated management and compliance personnel.