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European Gaming and Betting Association Code of Conduct
The EGBA and its members are committed to legal and responsible internet betting and gaming where customers are given a fair and reliable product.
All EGBA members support the goals of a regulated and competitive cross border betting and gaming market and are bound to comply with this code of conduct.
The EGBA regards the Code of Conduct as an important statement by its members of their commitment to socially responsible internet betting and gaming. The Code should be understood and seen in conjunction with each member’s national licensing requirements, imposed by its home EU regulator.
This Code is to be adopted as a means of business self-regulation for the EGBA members and is intended to be rigorously applied to all forms of business and advertising whether conducted directly by an EGBA operator member or by a third party on behalf of such operator. The Code is intended to supplement, but not supersede, applicable legislative requirements within a jurisdiction.
EGBA members are to be audited by an appropriately qualified and professional third party audit organisation, on an annual basis, for compliance of this code of conduct and the further detailed standards which are to be approved by the EGBA board from time to time. This is in addition to any such policies, processes or compliance already undertaken by any EGBA members individually e.g. GamCare certification, ecogra or other such organisations.
General
The following minimum requirements and features should be included and implemented by all EGBA members, without prejudice to those members who decide to go further or adopt additional relevant policies:
• stringent player verification processes for underage and identity checks (as further detailed below);
• the ability for players to be excluded and self-exclude;
• the ability for players to establish bet and deposit limits;
• the ability to provide players with a statement of their account activity;
• accessible and responsive customer support on a 24/7 basis;
• links to problem gambling and betting information and qualified advice services where available in a territory; and
• measures to combat fraud including player-fraud, money-laundering and fraud against the operator;
Website
EGBA operator websites should contain the following:
• the name of the operator and the address of its registered office;
• contact information for resolving customer complaints and disputes on a 24/7 basis;
• a statement identifying the jurisdiction from which the gaming or betting is conducted, preferably with a link / contact for the licensing jurisdiction for better understanding and dealing with consumer complaints;
• clear information about the terms and conditions for the service;
• clear wording that underage persons are not permitted to register or to participate in gaming or betting; and
• instructions on play and dispute resolution should be readily accessible
Problem Betting and Gambling Issues
Despite the belief and experience of EGBA members that problem betting and gambling issues affect the small minority of customers, the EGBA believes that further detailed research in this area is warranted.
However, the EGBA is committed to socially responsible gambling and betting and the reduction of problem gambling. Therefore, EGBA members agree to adopt the self-regulatory controls identified here and agree to adhere to responsible gambling and betting regulations / guidelines established in their respective licensing jurisdiction. In the case of conflict, the licensing jurisdiction takes precedence. EGBA members shall:
• make reasonable efforts to identify problem gamblers;
• provide a link to a website or websites (where available) offering information and assistance with respect to problem gambling including access to qualified support where reasonably available;
• offer the ability to their customers to set their own betting/deposit limits in an attempt to mitigate problem gambling;
• offer the ability to self-exclude from the site and where any customers self-excluding will cease to receive any further marketing material, within a reasonably short period, for the period of self-exclusion; and
• agree not to give credit to customers - specifically, members cannot permit a player to wager, win and get a payout where the funding of that wager comes from the operator other than through a promotion or bonus given by the operator.
Player Verification – Underage, Identity, Know-your-customer issues
EGBA members shall implement reasonable security measures to prevent access to remote gambling and betting products (including player registration) by users who have not reached the legal age for betting in their jurisdiction (underage), and shall:
• post a prominent age restriction notice on the home page and in the website terms and conditions;
• consider any credible and/or Financial Services Authority standard verification service providers and implement appropriate verification solutions;
• work with verification service providers to improve coverage and quality of verification services available;
• lobby governments to provide access to a wider range of databases to improve verification capabilities;
• adopt complimentary measures to manage risk (customer risk and operator risk) by way of deposit and/or time-based limits and manual verification using copies of government issued identification documents;
• immediately close the account of any underage or suspected underage person found to have accessed its services; and
• avoid advertising in media publications which target the underage and will not portray anyone underage in any gaming or betting adverts or promotional material.
The goal of these measures is:
• to know who the customers accessing the website are and that they are adults;
• to ensure that appropriate risk-management is being adopted that is proportionate to the actual risks of underage or unverified customers accessing the services;
• to ensure that EGBA members are operating at comparable or higher standards of verification than those of the relevant state-monopoly provider, where applicable; and
• to ensure that the coverage, quality and capability of real-time verification is continuously improved with the necessary development and assistance from the verification services industry and governments who have an important role to play on this issue.
Anti-money laundering issues
EGBA members shall implement an Anti-Money Laundering (AML) Policy approved and supported by its senior management which will provide reasonable security measures to prevent transactions which are potentially connected to money laundering; including the appointment of a person or persons with responsibility for implementing and ensuring effectiveness of anti-money laundering systems. This will include:
• implementation of appropriate know your customer processes;
• the provision of suspicious transaction reports to the relevant national Financial Investigation Unit and international institutions;
• the necessary training of staff involved in that business; and
• a formal annual report to Senior Management detailing the company’s compliance/non-compliance with its AML obligations.
The goal of these measures is:
• to ensure a safe and stable regulatory environment for both operators and players;
• to try to ensure that no money laundering occurs with regard to gaming and betting activities;
• to provide regulatory safeguards to minimise the operators’ exposure to customers by ensuring adherence to national and international Money Laundering laws and relevant e-gaming standards; and
• establishing compliance, audit testing and monitoring.
Consumer Privacy and Data Protection
Players’ accounts shall be managed in a secure, safe and efficient environment. The privacy and confidentiality of all player information submitted at any point in time shall be protected from unauthorised or unnecessary disclosure.
Payouts and Cashouts
EGBA members will ensure prompt and accurate processing of winnings and cashouts, subject to appropriate and necessary checks and verifications.
Product Testing
EGBA members shall implement a product testing and fairness policy to ensure that players have a positive experience on their sites. This policy will make sure that all systems used by the customer are fair and that the Random Number Generator is truly random. The policy will include:
• both internal and external testing of all products for fairness;
• ensuring that all products are tested both pre and post launch for fairness;
• all major changes are individually tested and a system-wide regression test is completed annually;
• frequent testing of all Random Number Generators so that all games will be conducted fairly and openly; and
• testing of all game rules to ensure fairness.
Advertising
EGBA members will ensure that players are not mislead through advertising or promotional activities, and will ensure that the terms and conditions of their promotions are followed.
• Advertising should not be false or misleading, particularly with regard to winning, and should be based on fact;
• Advertisements should not entice the underage to bet or be displayed at sites clearly targeted at the underage;
• An operator should not knowingly engage in the distribution of unsolicited advertising (i.e. SPAM) either directly or through a third party. Email advertising should have an unsubscribe, or opt out, facility;
• Advertisements should not contain a misrepresentation that is likely to cause damage to the business or goodwill of another person; and
• An operator should ensure that a third party performing advertising on their behalf abides by this code.
