Employee Gambling Policy

Global

Document Owner Chief Legal Officer

First Originated 1-Aug-2021
Issue Date (this revision) 18 May 2023
 Employee Gambling Policy - Global

1. Introduction
BetMakers is a responsible provider of gambling services, and recognises that when not well-
controlled, gambling can be a problem for some people and for workplace productivity and integrity.
BetMakers therefore takes reasonable steps to ensure team members’ health and safety in connection
with work, and this includes mitigating against potential negative effects of problem gambling.

Responsible gambling is where individuals are able to make informed decisions about how they
gamble. It occurs through the actions and ownership by individuals, communities, and the gambling
industry in achieving socially acceptable gambling outcomes.

Social responsibility is important to BetMakers, and we want to ensure our products are offered,
promoted, and enjoyed in a safe and secure manner, avoiding the risks of gambling-related harm.

The overriding principle of this Policy is that all wagering (whether with BetMakers or otherwise)
should be in moderation, and must not affect an employee’s job performance or productivity.

2. Purpose of this Policy

This Policy outlines the requirements imposed by BetMakers on the operation and use of personal
wagering accounts by its employees and contractors in the work environment.

3. Scope of this Policy

This Policy applies to all individuals that are employees and contractors of any BetMakers Group
Company (including those on secondment), whether permanent, temporary, casual, part-time, fixed-
term employees, contractors or consultants. A reference to an ‘employee’ or ‘team member’ in this
Policy is a reference to any of these persons.

4. Wagering accounts with our customers

Integrity, both actual and perceived, is critically important to BetMakers. BetMakers employees and
contractors must not hold personal wagering accounts with any brand for which BetMakers provides
managed trading services or platform development services.

Prior to opening a wagering account with any operator, you should confirm whether BetMakers
provides managed trading services or platform development services to that operator by asking the
Head of MTS.

Without exception, employees must not use or to disclose to any person confidential information,
whether derived directly or indirectly, in connection with their roles (including, but not limited to,
information regarding bets placed by particular persons). BetMakers reserves the right to restrict
employees from betting with any operator in circumstances where it considers that an employee is or
may be in breach of this requirement in addition to taking any other disciplinary action as set out in
clause 6 below.
 Employees are strongly encouraged to use deposit limits and other responsible gambling tools.
Employees are expected to ensure that their personal gambling does not impact on their performance
at work.

Employees must not, without their manager’s prior written approval, accept any wagering account
gratuities (such as bonus bets) from any wagering operator customer of BetMakers unless those
gratuities are of the type ordinarily offered to all customers of that wagering operator. For example,
participating in a money back or bonus back special promotion for racing events that are made
available to all customers of the wagering operator will not require managerial approval, however an
offer of a funded or matched deposit account specifically for a BetMakers employee would require
prior managerial approval.

Employees must make themselves aware of and, at all times, comply with the terms and conditions of
any wagering operator customer, including any particular requirements that they may impose in
relation to industry participants.

Test Accounts:
Employees are permitted to hold test accounts with our platform customers where required for them
to test products to effectively operate in their role and to improve our products and services. Where a
test account is required, the responsibility is on the employee to inform their direct manager of their
test account details.

All managers are responsible for monitoring and escalating any concerns with test accounts. These will
also be periodically monitored by the Security Team.

5. Rules relating to gambling during business hours

BetMakers has determined not to prohibit employees from gambling during business hours, subject to
employees complying with the provisions and restrictions outlined in this Policy at all times, including
the following:

• it must be done only to a responsible level, and it must stop if an employee has any concern with
their gambling;
• the gambling must not interfere to any extent with the fulfilment of the employee’s role and
responsibilities;
• employees must not gamble if they are self-excluded with any operator or experiencing gambling-
related harm;
• the gambling should be done only during scheduled breaks;
• gambling must always be conducted without regard to or use of any confidential information to
which an employee may have access; and
• the employee must comply with any reasonable direction from BetMakers in relation to gambling
during business hours.
All employees acknowledges that while product familiarity is important, BetMakers only condones
responsible gambling and does not encourage gambling during working hours or otherwise.
6. Breach of Policy
It is an employee’s responsibility to act in accordance with this Policy at all times, and to ask for
clarification if there’s anything they’re not sure about.
 If an employee sees or suspects others engaging in conduct in breach of this Policy, they are expected
to speak up, and report those concerns to their manager or the Chief Legal Officer.

Breaches of this Policy will be regarded seriously and will likely lead to disciplinary action which could
include termination of an employee’s employment/engagement.

7. Responsibility for oversight

The Chief Legal Officer is responsible for the implementation, management and enforcement of this
Policy. The Chief Legal Officer is to report directly to the Board on any material issue arising under or in
connection with this Policy.

8. Monitoring and review

The Chief Legal Officer and Chief People Officer will review this Policy in respect of its suitability,
adequacy and effectiveness. Any improvements identified are to be made as soon as possible.

All employees must attend responsible gambling training on a regular basis and as directed by
BetMakers.

9. Support
If an employee has questions about this Policy, they are expected to ask for help from their manager or
the Chief Legal Officer.

If you think that you, or someone you know, may be experiencing harm from gambling, you can contact
Gamblers Help on:

Australia Ph: 1800 858 858

USA Ph: 1800 522 4700
UK Ph: 0808 8020 133
Europe: https://www.problemgamblingguide.com/find_help___europe1.html

Or to access help from the confidential Employee Assistance Program, Converge International at 1300
687 327 (Australia) or +613 8620 5300 (International).

10. Document Management

Document Details

Role Title Name

Document Author Executive Assistant/Office Jaime Fitzpatrick
Manager
Document Reviewer Chief People Officer Chelsey Abbott
People & Culture Tahlia Smith
Coordinator
Document Owner Chief Legal Officer Sam Adams
Document Approver Chief Legal Officer Sam Adams
Revision History

Date Version Comments

26/8/2021 Draft V0.1 Draft completed by Jaime Fitzpatrick
06/10/2021 Draft V0.2 Draft completed by Chelsey Abbott
22/11/2021 Draft V0.3 Draft completed by Sam Adams
23/11/2021 Final V1.0 Final version approved for publishing
28/11/2022 Final V2.0 Updated V2 completed by Sam Adams and Chelsey
Abbott. Updated version prohibits employees from
opening wagering accounts with MTS clients.
18/05/2023 Final V3.0 Third version edited by Tahlia Smith to update title of
Chelsey Abbott from Head of People & Culture to
Chief People Officer.