Responsible Gambling Policy

Orange Entertainment B.V.

1. Purpose

Orange Entertainment B.V. (the “Company”, “We”, “Our”) operates under the gaming laws of Curaçao. We are committed to providing a safe and enjoyable gambling environment and to preventing gambling-related harm. This Responsible Gambling Policy (“Policy”) explains how we promote responsible play, detect and reduce harm, and ensure compliance with the regulations of Curaçao.

Our approach focuses on using customer knowledge to identify risky behavior, interacting proactively with customers to prevent harm, evaluating our processes for effectiveness, and maintaining full legal compliance. To achieve these goals, the Company uses advanced player monitoring tools, applies industry research, and provides regular training for staff to ensure responsible gambling is understood and practiced across the organization.

Objective

Description

Identify risk

Analyze player activity such as betting patterns, time spent playing, and financial losses to recognize risky behavior.

Interact proactively

Communicate with players showing signs of harm and act to reduce risks.

Evaluate effectiveness

Regularly review and measure our approach both on an individual and company-wide level.

Ensure compliance

Follow all relevant regulations, codes of practice, and licensing conditions.

2. Responsible Gambling Information

We help players make informed decisions about their gambling. Information is available on our website about setting limits, managing play, and finding professional help. This information is always accessible through one click from the homepage, registration pages, and game pages. The Responsible Gaming page does not contain any promotional or advertising material. It focuses entirely on education and player protection.

Topic

Explanation

Setting limits

Players can set deposit, loss, wager, and session limits, as well as daily, weekly, or monthly caps.

Time management

Tools are provided to help manage gambling sessions and balance everyday activities.

Responsible play

Information explains how to keep gambling fun and safe.

Self-assessment

Tools help players check their gambling behavior.

Transaction review

Players can view their gambling history and spending.

Self-exclusion

Details are provided about how to exclude oneself temporarily or permanently.

Professional help

Contact details for free and confidential support organizations are available.

3. Player-Controlled Limits

Players can manage their own gambling by setting limits that apply instantly once confirmed. These limits are designed to help players stay in control of their spending and time.

Limit Type

Description

Available Periods

Activation

Deposit limit

Restricts how much a player can deposit into their account.

Daily, weekly, or monthly

Effective immediately

Loss limit

Stops play once a set loss amount has been reached.

Daily, weekly, or monthly

Effective immediately

Wager limit

Restricts how much money can be wagered during a specific time frame.

Daily, weekly, or monthly

Effective immediately

Session limit

Controls how long a gambling session can last before requiring a break.

Per session

Effective immediately

When players reduce their limits, the change takes effect as soon as possible. When they request an increase, the new limit becomes active only after a 24-hour cooling-off period to ensure the decision is well considered.

4. Cool-Off Period

Players can activate a cool-off period for any length of time.

- During this period, no deposits or real-money play are allowed.

- The restriction begins immediately after activation.

- When the chosen period ends, the account does not automatically reopen.

- Players must visit their account settings and manually reactivate gambling access.

5. Self-Exclusion

Self-exclusion allows players to block access to gambling for a specific duration or permanently. Once a request is received, it is applied as soon as possible, and the player cannot place new bets or make deposits during that time. The remaining balance always remains available for withdrawal.

Type

Description

Temporary exclusion

Can last from 24 hours to several months. The player is blocked from gambling during the chosen period.

Permanent exclusion

The player’s account is closed permanently, the balance is returned, and all marketing communication is stopped.

Company-wide exclusion

Self-exclusion applies across all brands operated by the Company.

Reinstatement after exclusion

If a player wishes to return after six months or more, written confirmation is required before reopening the account.

In some situations, the Company may impose an exclusion. A discretionary exclusion may be applied if there are signs of problem gambling, cheating, or improper behavior. A mandatory exclusion is required if there is evidence of cheating, collusion, threatening behavior, uncontrollable gambling addiction, intoxication, or if the player is under 18 years of age. All such cases are documented, and balances are returned when applicable.

The Company ensures that no promotional or marketing communication is sent to excluded players. If a player breaches the exclusion, the Company will review the case individually. Deposits may not be refunded, and winnings may be withheld depending on the circumstances.

6. Prevention of Underage Gambling

The Company strictly prohibits gambling by anyone under the age of 18 or below the legal gambling age in their country. We apply strong age verification and refuse service to anyone who cannot verify their age. All marketing is designed to avoid appeal to minors, and every website includes clear warnings about the minimum legal age for gambling.

Filtering software may also be used to block access to gambling websites for minors. Our staff is regularly trained to ensure full awareness of underage prevention procedures.

Measure

Implementation

Age verification

All players must verify their age before deposits or bonuses are allowed.

Refusal of service

Unverified accounts are not allowed to gamble.

Marketing control

Content is created to avoid any appeal to minors.

Legal warnings

Age limit messages are shown on all pages.

Software filters

Parental controls are supported.

Staff training

Regular sessions ensure proper enforcement.

7. Customer Identification

Each player account is managed individually. This separation ensures that all personal limits, self-exclusions, and timeouts are applied accurately and cannot affect other users.

8. Employment of Young People

The Company does not employ any person under the age of 18 in any role related to gambling. This rule applies to all departments and job types without exception.

9. Staff Responsibilities and Support

Company employees are not allowed to use any of our gambling services. If any staff member violates this rule, disciplinary action may be taken, including possible dismissal. When the Company becomes aware that an employee or a family member may be affected by gambling issues, management will offer confidential advice and refer them to professional counseling organizations. We provide access to the same support resources offered to our players, ensuring that our workplace remains safe, supportive, and responsible.

10. Vulnerable People

Certain individuals may be considered vulnerable due to reasons such as mental health challenges, bereavement, financial problems, or addiction. When information about a player’s vulnerability is received, it is reviewed by the Chief Compliance Officer. A suitable action is then decided, which may include temporary account suspension, self-exclusion, or permanent account closure. Each case is handled individually with the goal of protecting the player.

11. Staff Training

All employees receive responsible gambling training when they join the Company. Training covers internal procedures, early signs of gambling harm, and proper communication with at-risk customers. Customer service employees receive additional instruction on handling responsible gambling situations and escalating issues to the responsible gambling team.

Training Type

Timing

Purpose

Initial training

During onboarding

Introduction to responsible gambling policies and procedures.

Specialized training

For customer support

Learning how to identify and manage problem gambling behavior.

Annual refresher

Once per year

Update staff on new regulations and internal practices.

Ad hoc training

When required

Applied after any policy change or breach to maintain compliance.

Training effectiveness is regularly monitored to ensure that all staff understand and follow responsible gambling standards.

12. Policy Access and Communication

This Policy is shared with all staff during onboarding and stored in a shared, easily accessible location. When updates are made, employees are informed, and any significant changes are reviewed and approved by management. Supervisors are responsible for ensuring compliance across all teams.

13. Policy Review and Effectiveness

The Company remains up to date with responsible gambling regulations and best practices. Information from regulatory bodies and industry sources is reviewed regularly. A formal review of this Policy takes place at least once per year. Whenever legal or procedural changes are required, updates are made immediately and communicated to all staff.

Review Area

Frequency

Purpose

Policy review

Annually

To confirm full compliance with all laws and regulations.

Industry updates

Ongoing

To stay informed about changes and new requirements.

Internal audits

As needed

To identify weaknesses or breaches and correct them.

Corrective actions

Case-by-case

To provide training or adjust procedures after non-compliance.

Every update is approved by a Company Director, and relevant staff members receive updated training to ensure full understanding of the new requirements.

We are committed to Responsible Gaming, Player Protection, and Full Compliance.