1. Introduction

1.1. This policy sets out our commitment and the approach that we will adopt to provide an environment for gambling activities in a socially responsible way. We believe that social responsibility applies to all of our customers and the aim of this policy is to provide an effective level of protection against problem gambling.

1.2. We understand that most of our customers do gamble responsibly, experiencing both the thrill of victory and the disappointment of a defeat. However, we also acknowledge that there is a responsibility on us to ensure that the pastime of gambling does not become problem gambling for our customers. We are committed to promoting awareness of problem gambling and improving our prevention and intervention processes. From time to time we may send or display social responsibility messages to our customers.

1.3. We want all of our customers to gamble responsibly within their means and to enjoy the entertainment experience across our platform. To help with this, we may provide targeted information to customers about their gambling behaviour in order to inform and prevent harm. If we become aware of a customer’s gambling activities which may indicate a potential gambling problem, we may initiate interaction with this customer or in certain circumstances suspend that customer’s account in order to assist them in obtaining help.

1.4. All of our staff are trained in Social Responsibility. That includes spotting and helping with problem gambling.

1.5. To support our commitment to responsible gambling, we have put in place a number of support measures. These include:

a. Responsible advertising and marketing practices.
b. Prevention of underage gambling.
c. Protecting vulnerable people.
d. Gambling management tools:

• Self-help and gambling awareness information;
• Customer driven deposit and loss limits;
• Time out tools;
• Self-exclusion tools;
• Links to GamCare and other help organisations;

1.6 If you need further information about these tools, please contact us via any of the methods listed in section 8 below.

2. Recognising problem gambling

For many of our customers, gambling is exciting, fun and entertaining and in order to keep it this way they should be in full control of their gambling habits. Sometimes things can get out of control and recognising this fact is the first step in helping you to get back in control. If you feel you are developing a problem with gambling, check our self-assessment tool. We have produced some responsible gambling tips to assist in determining whether you may need to seek help in relation to your gambling.

If you are concerned about your gambling, then honestly answering the questions below may give you an idea of whether your gambling is becoming problematic. The more you answer 'yes' to these questions, the more likely you are to experience a gambling problem.

a. Do you stay away from work, college or university to gamble?
b. Do you gamble to escape from a boring or unhappy life?
c. When gambling and you run out of money, do you feel lost and in despair and need to gamble again as soon as possible?
d. Do you ever gamble to make money to pay off debts?
e. After winning, do you feel the need to try and win more?
f. Have you ever sold anything to finance gambling?
g. Have you ever lied to cover up the amount of money or time you have spent gambling?
h. Have others ever criticised your gambling?
i. Have you lost interest in your family, friends or hobbies?
j. Do arguments, frustrations or disappointments make you want to gamble?
k. Do you feel depressed or even suicidal because of your gambling?

Having answered the above, if you think that you might be experiencing a problem with your gambling, we recommend that you take some time to reflect on your recent gambling experience with us. If you feel that your gambling is no longer fun and entertaining, then it’s probably time to take some action to deal with the situation.

As part of being a responsible gambler, you should remember:

a. Gambling should be entertaining and fun and not seen as a way of making money.
b. Don't gamble when you’re highly stressed, depressed or intoxicated.
c. Decide on your limits ahead of time and stick to them.
d. Only gamble with money set aside for entertainment, never with money for everyday expenses or bills.
e. Never borrow money to gamble.
f. Only gamble what you can afford to lose.
g. Avoid chasing losses.
h. Balance your gambling with other activities.
i. Keep track of the time and amount you spend gambling.
j. Consider taking a break using timeout or self-exclusion facilities.

3. Concerned about a family member or friend?

3.1 We understand that some people who develop a problem with their gambling may not always realise it. If you are concerned about a partner, family member or friend, you should consider whether any of the following applies to the person you are worried about:

a. Do you think their gambling has begun to affect their work, College or University studies?
b. Do you think they are lying to cover up the amount of money or time they spend gambling?
c. Is their gambling becoming a focus for arguments and disagreements with family and friends?
d. Have they ever borrowed or stolen money from family or friends in order to gamble?
e. Has their gambling caused them to lose interest in other hobbies and family activities?
f. Have they become violent or abusive towards family or friends as a result of losing money while gambling?
g. Are you concerned that someone under the age of 18 has begun gambling?

3.2 What to do next:

a. Talk to your family member or friend to establish the scale of the problem.
b. Agree to set boundaries and control on spending.
c. Research what support is available and encourage them to accept help.
d. Think about providing a ‘safety net’ of support from family, friends and support agencies.
e. You can find help and advice from the organisations listed below under the title “Gambling Support Organisations”. You may also contact us to discuss appropriate support – our contact details are in section 8 below.

4. Advertising and marketing practices

4.1 To ensure that our services do not appeal to children, young people, or other vulnerable groups, we will pay careful attention to the design and content of our marketing and promotional material.

4.2 We will abide by the codes of practice such as CAP, BCAP, the Gambling Commission’s Advertising/Marketing Rules and the Gambling Industry Code for Socially Responsible Advertising. We will ensure that Customers who self-exclude or take a time out from gambling do not receive any marketing or promotional material from us during their self-exclusion or time out period (except any marketing that has already been posted).

4.3 We will ensure we use social media marketing in a responsible manner and that any marketing is not included near the responsible gambling section of our website.

4.4 We will adhere to the principles set out by the Competition and Markets Authority to ensure that gambling is conducted in a fair and open way.

5. Preventing underage gambling

5.1 Gambling under the age of 18 is a criminal offence. We take our legal responsibilities very seriously in regards to preventing access to our products and services by persons under the age of 18.

5.2 Warnings and symbols about age limits are displayed during registration and throughout our site.

5.3 To ensure that our services are restricted, we use sophisticated age and ID verification systems and robust procedures to minimise the risk of underage customers accessing our services. We carry out ID verification checks on every account application as part of our customer due diligence requirements. Notwithstanding this, we recommend that parents and guardians who use a shared (e.g. “family”) computer to access our services take necessary measures to deny access to our platform to underage persons. We recommend that you do not gamble in front of minors. Do not leave your account logged in while away from the computer if there is a danger that a child can access it. Useful information can be found below in the section titled “Internet Filtering Applications”.

5.4 Should we become aware that a customer is underage, their account will be closed and all deposits in their account will be returned. No winnings will be paid to any underaged customer under any circumstances. Should winnings have already been taken from the account, these winnings shall be taken from any money remaining in the account and if insufficient in amount, we may make a claim against the customer for their return.

5.5 If you suspect that someone under the age of 18 is gambling with us, please contact us via any of the methods listed below and we will take appropriate action. 6. Preventing play by vulnerable people

6.1 As we are a remote gambling operator, it is difficult for us to establish the mental state or capacity of our customers and therefore cannot gauge whether they are vulnerable due to a medical, psychological or physiological condition or through drink or drugs. However, we do not underestimate our obligations towards protecting vulnerable people from being harmed or exploited by gambling.

6.2 When an individual joins our Exchange, we will check that:

• They are aged 18 or over.
• They are in a jurisdiction where they can legally use our facilities.
• They are not subject to any sanctions or other restrictions which prevent them accessing or using our facilities.

6.3 We actively monitor customer accounts for changes in activity and should we notice any unusual account activity or behaviour, or be informed by a third party that a customer is, or may be vulnerable, our customer intervention process will be initiated.

6.4 We record all customer interactions (including reasons for non-interactions) and all events and outcomes are logged to help us to improve our procedures and for audit purposes. This process assists us in identifying vulnerable or potentially vulnerable customers and allows us to provide appropriate support and assistance.

7. Customer intervention process

7.1 The customer intervention process will be initiated when we are made aware, or have reason to suspect, that a customer is or may be vulnerable or otherwise at risk. This will be determined either through our direct interactions with the customer e.g. through emails or phone calls or through normal monitoring of account activity. It may also be brought to our attention via third parties such as a family member or friend.

7.2 Decisions about customer interventions will be proportionate to the risk associated with the customer and can be initiated by either our Customer Services Team or our Responsible Gambling/Compliance Officer in accordance with our Responsible Gambling procedure.

7.3 The type of behaviour that may trigger the intervention is usually related to increased deposits and losses, significant losses, sudden change in behaviour, chasing losses, increased time spent on gambling.

7.4 When we have reason to suspect that a person is, or may be vulnerable, we may temporarily freeze the account for 24 hours in order to contact the customer to discuss their needs further and initiate the intervention process. During the customer intervention process, we will provide the customer with information about how to use our gambling management tools, where to seek help from gambling support organisations if they feel they are experiencing a gambling problem and discuss the options available, including how to self-exclude from our exchange or take a break from gambling.

7.5 All communication(s) with the customer will be recorded and a decision will be made on how to proceed, which may include the closure of the customer’s account. This will provide the best outcome for the customer and ensure compliance with our obligations regarding responsible gambling and social responsibility.

8. Gambling support organisations

If you feel your gambling is becoming a problem, or you are worried about a family member or friend, you may seek assistance and advice from the organisations below:

GamCare is a registered charity that provides confidential telephone and online support and counselling to anyone affected directly or indirectly by problem gambling.
The GamCare National Helpline can be contacted on free phone number 0808 8020 133 (free calls from all UK landlines and most major mobile networks) every day from 8am to midnight. Alternatively, you can visit their website at www.gamcare.org.uk

Gamble Aware offers more information on responsible gambling and provides useful advice and assistance, including access to resources.
GambleAware is the operating name of the Responsible Gambling Trust.
You can access their website at: www.begambleaware.org

Gambling Therapy offer many different online services for problem gamblers and their friends and families. These include online groups, forums, e-mail support, a resource database and a multilingual live advice helpline. Gambling Therapy is a free online service that provides practical advice and emotional support to people affected by problem gambling who reside in and outside Great Britain. For more information, visit www.gamblingtherapy.org

Gamblers Anonymous UK
Gamblers Anonymous provide various types of help for compulsive gamblers and anyone who is affected by problem gambling. Their help includes a forum, chat room, literature, confidential face-to-face counselling and meetings every day of the week throughout the UK. Gamblers Anonymous can be contacted at www.gamblersanonymous.org.uk

The Gordon Moody Association is a registered charity with over 40 years’ experience in providing residential support and treatment for people who are severely addicted to gambling. They have two treatment centres, one in the West Midlands and the other on the Kent/London borders.
www.gordonmoody.org.uk
Tel: 01384 241292
Email: help@gordonmoody.org.uk

National Problem Gambling Clinic
www.cnwl.nhs.uk
The National Problem Gambling Clinic is part of the national system of treatment provision for problem gambling in the UK. The system includes other providers such as GamCare and The Gordon Moody Association.
The National Problem Gambling Clinic is working alongside these other providers to deliver the most appropriate package of care for individuals experiencing difficulties with gambling.
Tel: 020 7381 7722
Fax: 020 7381 7723
Email: gambling.cnwl@nhs.net

Further details on responsible gambling and other support organisations can be accessed on the Gambling Commission’s website at:

www.gamblingcommission.gov.uk

If you would prefer to talk to us, our contact details are below:
Post: Bet Ltd, Thorp Arch Grange, Thorp Arch, Wetherby, LS23 7BA
Email: support@bet.me

Please note that any communication made to our Customer Services Team may be monitored or recorded for training and quality management purposes.

9. Gambling Management tools. What measures are available to control your gambling?

9.1 Access to your account history

We will provide Customers with a full history of their account activity with us, including their complete payment and winnings history. This will be accessible through their Account at any time and on request. We will maintain records of a Customer’s gambling transactions for a minimum of 12 months.

9.2 Deposit and loss limits

a. What are deposit and loss limits?

Deposit and loss limits allow you to set a limit on the amount of money deposited or lost in play within a defined period. Therefore, you are always in control of your money and the maximum amount spent on gambling. You may set a deposit and/or loss limit at any point after registration and may apply a limit at any time on the Account via the “Limits” section in the “My Account” area.

b. How long does a deposit or loss limit last?

You have the option of applying a deposit loss limit for the following periods/duration:

• 24 hours
• 7 days
• one month
• one year

c. What happens during the limit period?

When you have requested a limit, this will be applied immediately after your request and you will be informed of the limit being in force on your account.
When you apply a deposit limit, our system will automatically prevent any deposit above the limit that you have set. Similarly, when a loss limit is applied, you will be prevented from making any bets once the limit has been reached (until that period expires and a new limit period begins).
Where you set more than one limit e.g. a daily deposit limit and a weekly limit, the lowest limit will always apply.

d. Can I increase/decrease my limit?

You may request a decrease in your limit with via the “Limits” in the “My Account” area. This will be applied immediately and you will be notified when the change has been effected.
If you wish to increase your limit, you will need to contact us via telephone to make the request. There will be a mandatory ‘cooling-off’ period of 24 hours (from the time of the request made by you) before the increase can be effected. You may call us during the cooling off period to cancel the increase. Otherwise, you will be notified at the end of the cooling-off period when the change comes into effect.

9.3 Time out

a. What is time out?

A “time out” allows you to take a break from gambling for a set period and is similar to self-exclusion. The main difference is that “time out” has a minimum duration of 24 hours and has a shorter maximum duration. The time out facility can therefore, be a useful way of regulating the amount of time or money (or both) you are spending on gambling.

b. How long does a time out last?

You may take a time out with us for the following periods:

i. 24 hours
ii. 1 week
iii. 1 month
iv. Other period as you may reasonably request up to a maximum of 70 days.

c. How do I request a time out?

To request a time out, you will need to contact us via telephone and advise us of the length of time that you wish to opt out for. If you do choose to take a time out from us, we would strongly advise that you take a time out from any other companies with whom you have a gambling account. Details on how to do this will be available on the responsible gambling section of the website.

d. What happens during a time out?

Once we have received your request by telephone, you will be prevented from logging into your Account for the entire duration of the time out period requested. You will not be able to deposit funds, withdraw funds or place any bets with us until the time out period has expired.
Once your time out request has been made, you will not be able to cancel it.

9.4 Self-Exclusion

a. What is ‘self-exclusion’?

If you have decided that you wish to take a break from gambling, we provide a self-exclusion facility that supports you and prevents you from accessing your account with us for at least six months. Your account will be closed for the time of your self-exclusion (6 months, 1 year, 3 years or 5 years). It will not be activated until the self-exclusion period has ended and only after you have telephoned us to request a return to gambling (a positive action to start gambling again). A 24-hour cooling-off period will apply after a request to return to gambling.

b. How can you self-exclude?

The process is instigated by you if you think you are spending too much time and/or money gambling. You can do this by calling us directly or by completing the self-exclusion drop-down box on our website.

c. What happens when you self-exclude from gambling?

We will close your account and it cannot be reactivated until the expiry of the self-exclusion period. Any funds held in your account will be returned to you. Any bets that are not yet settled (Ante-Post etc.) will be kept open until they can be settled and then any funds resulting from those bets will be returned to you.

d. How long does self-exclusion last for?

When you decide to self-exclude from gambling, this will be for a minimum of 6 months. You have the option of extending this for one or more further periods of at least 6 months each up to at least 5 years. At the end of a self-exclusion period chosen by you, the self-exclusion will remain in place for a minimum of 7 years, unless you take positive action to gamble again, following the end of your initial self-exclusion.
If at the end of the self-exclusion period chosen by you, you make a request to resume gambling again, we will give you 24h to cool off before being allowed to gambling again.

e. What are your obligations during self-exclusion?

You will be unable to gamble via our website. When you self-exclude from using our Services, we recommend that you also self-exclude from other gambling establishments of which you are a member as this will assist you to refrain from gambling while you seek help to deal with your problem. In addition, you can consider the use of blocking software which blocks access to gambling websites.

f. What are our obligations during self-exclusion?

During your period of self-exclusion, we will remove your details from our marketing mailing lists and databases. Please note that this may not prevent you from receiving marketing material which has already been dispatched to you by post. Any such material received should be disposed of immediately.
During a self-exclusion agreement, we will employ reasonable automated checks to ensure that you can no longer transact with any Accounts held with us and to ensure that you are complying with the self-exclusion agreement.
If you continue to gamble or circumvent any self-exclusion agreement by, for example, opening and operating new Accounts with us, we are under no obligation to return any deposits, winnings, or other funds in respect of such activity.

g. When can you resume gambling?

You can resume gambling only after the expiry of your self-exclusion period. The self-exclusion agreement will remain in place for a minimum of 7 years, unless you take positive action to gamble with us again.
If you wish to resume your gambling with us, you will need to contact our Customer Services Team by telephone to confirm that you have taken steps to control your gambling and that you feel you can safely return to gambling. Following telephone contact from you, there will be a 24-hour cooling off period (from the telephone contact from you) before your Account can be reactivated and you can resume any gambling activities with us. By default, your marketing and promotional communication will be switched off. You can change this if you wish to receive such communications.

10. National Online Self-Exclusion Scheme (GAMSTOP)

The Remote Gambling Association (RGA) operates the National Online Self-Exclusion Scheme (NOSES) referred to as GAMSTOP with the following features:

a. Enables online customers gambling with remote operators licensed by the Gambling Commission to self-exclude from all of those operators via a single interface (nominally a central website supported by a database system).
b. The site also contains information and advice about responsible gambling and where to obtain further advice and support
c. Existing customers will still have the option of self-excluding with individual operators that they have accounts with rather than go for national self-exclusion if they choose to do so.
d. Other remote gambling operators provide signposting on their sites to GAMSTOP.

We participate in the scheme to further assist our customers in keeping their gambling under control. Further details on the Scheme can be accessed at: www.gamstop.co.uk.

11. Internet filtering applications

If you self-exclude or take a time out from gambling, we would also advise unfollowing any gambling sites and/or social media platforms, and removing any apps or notifications relating to gambling you may have on your devices.
You may also install internet filtering software on your computer to prevent access to gambling sites. It is important that you conduct your own research in finding the right software best suited for your needs. It is advisable to ask someone else to enter/choose the password when using blocking software.
You may find filtering software at the following sites:

i. www.netnanny.com www.netnanny.com
ii. www.cybersitter.com www.cybersitter.com
iii. www.contentwatch.com www.contentwatch.com
iv. www.gamblock.com/ www.gamblock.com
v. www.betfilter.com/ www.betfilter.com

12. Staff training

Our staff are experienced and trained to recognise and respond to the signs of problem gambling. Regular discussions, evaluation of our policy and procedure and scheduled refresher courses are designed to keep us up to date with new advice from the Gambling Commission and continue to improve the protection we offer to our customers.

13. Review and revision

This policy and associated topic-specific policies will be reviewed annually and revised according to:

a. Developments in technology and software.
b. Amendments to changes in legislation or regulatory responsibilities.
c. Outcomes of risk assessments, internal audits and management reviews performed by the company or contractors on behalf of the company.
d. Feedback from relevant stakeholders.

Any policy amendments made during these annual reviews will be communicated to our customer and relevant stakeholders.

Last updated V2 on 09/10/2018