GAME BÀI ĐẲNG CẤP

Complaints and Dispute Resolution Policy

1. Objective and Application

This Complaints and Dispute Resolution Policy (“Policy”) defines the internal standards and procedures applied by Ventures Lab Limited Malta (the “Company”, “we”, “us”, or “our”) for the fair, consistent, and timely management of customer complaints and disputes.

The Policy forms part of the Company’s governance and compliance system and is endorsed by Senior Management. It is designed to comply with applicable Maltese legislation, Malta Gaming Authority (MGA) licence conditions, and relevant regulatory guidance.

This Policy applies to:

  • All customers using the Company’s gaming and betting services
  • All products and services offered under the Company’s MGA licences
  • All employees, contractors, and third-party service providers involved in service delivery or customer support

Ultimate oversight and accountability for compliance with this Policy rests with Senior Management and the Board.

2. Regulatory Alignment

This Policy is implemented in accordance with:

  • The Gaming Act (Chapter 583 of the Laws of Malta)
  • Applicable MGA licence terms, directives, and standards
  • Relevant consumer protection requirements
  • Data protection obligations, including the General Data Protection Regulation (GDPR)

The Company maintains this Policy to ensure that:

  • Customers are treated fairly and consistently
  • Complaint channels are accessible and clearly communicated
  • Disputes are escalated appropriately when necessary
  • Regulatory expectations for transparency and accountability are met
  • Records are maintained for audit and supervisory review

3. Governance Framework and Operating Principles

The complaints handling structure is based on the following principles:

Fairness – Each complaint is assessed on its merits without bias or pre-determination.

Responsibility – Clear allocation of ownership across operational and compliance functions.

Transparency – Customers receive clear explanations of outcomes and reasoning.

Independence – Escalated reviews are, where practicable, conducted by personnel not involved in the original decision.

Risk Sensitivity – Complaints involving vulnerable customers or gambling harm are prioritised appropriately.

Senior Management reviews performance indicators and systemic complaint trends on a regular basis.

4. Competence, Training, and Internal Controls

Employees responsible for complaint handling are trained in:

  • Regulatory and licensing obligations
  • Investigation and evidence assessment procedures
  • Escalation and reporting workflows
  • Identification of responsible gambling risks

Internal safeguards include:

  • Defined roles and responsibilities
  • Documented handling procedures
  • Controlled access to complaint data
  • Ongoing compliance monitoring and internal audit review

5. Complaint Intake Channels

Customers may lodge complaints through:

  • Dedicated complaints email address
  • Customer service chat or support portal
  • Telephone support lines
  • Written correspondence to the Company’s registered office

To support efficient handling, customers are encouraged to provide:

  • Account identifiers
  • Description of the issue
  • Relevant transaction or game references
  • Any supporting documentation or screenshots

Submitting a complaint is free of charge and does not limit the customer’s right to pursue external remedies.

6. Handling Procedure

6.1 Receipt and Confirmation

All complaints are acknowledged within a reasonable timeframe, typically within 48 hours. The acknowledgement confirms receipt, provides a reference number, and outlines the expected handling timeframe and escalation options.

6.2 Assessment and Investigation

Each complaint is reviewed in accordance with internal procedures and may be escalated to Compliance, Responsible Gaming, or Senior Management where appropriate.

Investigations may include:

  • System and game log analysis
  • Financial transaction review
  • Customer interaction records
  • Policy and procedural verification

All steps are recorded in the Company’s complaints management register.

6.3 Decision and Communication

The Company aims to issue a final response within 14 business days. Where additional time is required, customers will be informed and provided with updates.

All outcomes are:

  • Based on documented evidence
  • Clearly explained to the customer
  • Recorded for compliance and audit purposes
  • Subject to internal oversight review

Customers may request a written explanation of any decision issued.

7. Escalation and External Resolution Routes

7.1 Internal Review Process

If a customer is dissatisfied with the outcome, they may request an internal escalation. This review is conducted by a more senior or independent function not involved in the original assessment where practicable. All escalations are logged and subject to governance oversight.

7.2 External Options

If a dispute remains unresolved after internal review, customers may escalate the matter to:

  • The Malta Gaming Authority (MGA)
  • An Alternative Dispute Resolution (ADR) body recognised by the MGA
  • The courts of Malta

The Company cooperates fully with all external bodies and provides relevant records upon lawful request.

8. ADR Outcomes, Legal Effects, and Judicial Rights

Where a dispute is referred to an Alternative Dispute Resolution (ADR) entity, customers should be aware of the following implications:

  • The ADR body will independently assess the dispute and may issue a proposed outcome, recommendation, or decision depending on its mandate.
  • Such outcomes may be non-binding unless accepted by the parties or made binding through applicable legal mechanisms.
  • Participation in ADR does not, in itself, remove or limit the customer’s right to pursue further legal action.

Where the Company offers access to a non-binding ADR process in accordance with Article 10(2) of Directive 2013/11/EU (as transposed by Directive 5 of 2018), customers will be clearly informed that:

  • the ADR outcome does not constitute a binding legal determination;
  • acceptance of a non-binding outcome may affect how and whether the dispute proceeds further; and
  • in order to obtain a binding decision, the customer may need to pursue the matter before the competent courts or other legally binding adjudicatory bodies in Malta.

The Company ensures that customers are fully informed of the potential consequences of ADR participation, including its impact on subsequent legal or judicial recourse, before or during the ADR process.

9. Responsible Gambling-Related Complaints

Complaints involving potential gambling harm, self-exclusion, underage access, or vulnerability concerns are treated as high priority.

These matters:

  • Are escalated immediately to specialist teams
  • Receive expedited review
  • Are subject to enhanced compliance oversight

Serious cases may be escalated to Senior Management and included in regulatory reporting where required.

10. Complaints Register and Reporting Obligations

The Company maintains a secure complaints register for governance, audit, and regulatory purposes. This includes:

  • Complaint classification and nature
  • Investigation records
  • Resolution details and rationale
  • Escalation history and outcomes

Records are retained for a minimum of five years.

Regular reporting includes:

  • Complaint trends and volumes
  • Root cause identification
  • Escalation statistics
  • Responsible gambling indicators

Where required, information may be shared with the MGA in line with licence obligations.

11. Confidentiality and Data Protection

All complaints are handled confidentially and in accordance with applicable data protection laws.

Access to complaint information is strictly limited to authorised personnel, and all processing activities are governed by:

  • Role-based access controls
  • Audit trails and monitoring systems
  • Internal security policies and procedures

12. Policy Oversight and Review Cycle

This Policy is approved by Senior Management and forms part of the Company’s compliance governance framework.

It is:

  • Reviewed at least annually
  • Updated when regulatory or legal requirements change
  • Subject to ongoing oversight by Senior Management and the Board

All material amendments are formally recorded and communicated where necessary.