DISCOVERY April 2009

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1 PRESENTATION DISCOVERY April 2009

2 BUILDING A REGULATED ENVIRONMENT FOR ONLINE GAMBLING Online Gambling Jurisdictions Self Regulation Responsible Gambling

3 ONLINE GAMBLING INDUSTRY OVERVIEW websites earning $30m sites with projected earnings of $18bn + US and Asia still leading the spending Europe is leading the way in Tier 1 operations New technologies enabling more interactive gambling Current economic climate shows decline in land based visits More and more jurisdictions embracing regulation

4 JURISDICTIONS 48 Online Gambling Jurisdictions Africa Asia Pacific Caribbean Central America North America South America Europe Russia

5 JURISDICTIONS In excess of 1600 licensed sites Including: 888.com listed on the London Stock Exchange market cap at listing of 590m PartyGaming listed on the London Stock Exchange market cap at listing of $9 bn US bwin listed on the Vienna Stock Exchange market cap at listing of 1.9 bn Unibet listed on the Stockholm Stock Market market cap at listing of SEK 5.5bn PlayTech Software listed on London Stock Exchange market cap at listing of 1.01 bn

6 GIBRALTAR

7 GIBRALTAR Located at the southernmost tip of Europe Started offering licenses to online gambling sites in 1998 Gibraltar Regulatory Authority (GRA) Licenses sportsbooks, casinos, poker rooms, betting exchanges, etc. UK White List status 208 sites

8 MALTA

9 MALTA Located in the Mediterranean Sea Started offering licenses to online gambling sites in 2000 Lotteries and Gaming Authority (LGA) Licenses sportsbooks, casinos, poker rooms, betting exchanges, etc. Member of the EU 316 sites

10 ALDERNEY

11 ALDERNEY Located in the Channel Islands Started offering licenses to online gambling sites in 1999 Alderney Gambling Control Commission Licenses sportsbooks, casinos, poker rooms, betting exchanges, etc. UK White List Status 62 sites

12 ISLE of MAN

13 ISLE of MAN Located in the Irish Sea Started offering licenses to online gambling sites in 2001 Gambling Control Commission Licenses sportsbooks, casinos, poker rooms, betting exchanges, etc. UK White List Status 14 sites

14 KAHNAWAKE

15 KAHNAWAKE Mohawk Territory of Kahnawake, Quebec, Canada Started offering licenses to online gambling sites in 1999 Kahnawake Gaming Commission Licenses sportsbooks, casinos, poker rooms, betting exchanges, etc. 248 sites

16 ANTIGUA and BARBUDA

17 ANTIGUA and BARBUDA Located in the Caribbean Sea Started offering licenses to online gambling sites in 1999 Financial Services Regulatory Commission s Division of Gaming Licenses Interactive Gambling (Casino & Poker) and Interactive Wagering (sports betting) UK White List status 76 sites June 2003 initiated WTO dispute process against the US

18 NETHERLANDS ANTILLES

19 NETHERLANDS ANTILLES Island of Curacao located in the Caribbean Sea Started offering licenses to online gambling sites in 1999 Department of Justice The Governor of the Netherlands Antilles may award interactive gambling licenses pursuant to the National Ordinance Offshore Games of Hazard. 258 sites

20 UNITED KINGDOM Member of the European Union 2005 Gambling Act First licenses awarded in September 2007 Gambling Commission Licenses sportsbooks, casinos, poker rooms, betting exchanges, etc. 87 sites

21 UNITED STATES 2006 UIGEA Internet Gambling on Horse Racing is permitted by the Interstate Horse Racing Act in states that have chosen to regulate it. California, Nevada, Oregon and South Dakota Federal Gambling Law does not address games of skill 29 sites Interactive Lottery sites & Horse Racing

22 SELF REGULATION ecogra is the Independent Standards Authority for the online gambling industry

23 e Commerce and Online Gaming Regulation and Assurance Founded in 2003 to establish standards to make online gambling safer for players everywhere. A non profit organization, ecogra specifically oversees Fair Gaming Player Protection Responsible Operator Conduct.

24 Over 130 sites are regulated, monitored and certified with the ecogra Safe & Fair Seal 55 different operations 65 different worldwide locations

25 PLAYER PROTECTION ecogra is an independent entity that strives to provide player protection, ensuring that operators are honest, games are fair, monetary deposits are safe and winning bets are paid in a timely manner.

26 OVERVIEW Board structure Independent directors, member directors and executive director Board control Independent directors Michael Hirst, OBE Chairman Bill Galston, OBE Frank Catania Bill Henbrey Member directors John Anderson, 888 Chris Hobbs, MGS Oliver Eckel, bwin Games Executive director Andrew Beveridge

27 OVERVIEW Compliance and Advisory Services Department Preparing and maintaining work programs Onsite inspections and ongoing monitoring Reporting to Seals Compliance Committee Assisting operators with compliance issues Special investigations ecogra Generally Accepted Practices (egap) changes Data Services Department Payout Percentage Reports Random Number Generator (RNG) Reports Responsible Gambling Responsible Gambling measures and tools Dispute Mediation

28 COMPLIANCE AND ADVISORY SERVICES DEPARTMENT Compliance Services egap Reviews EGBA Reviews Affiliate Program Reviews Jackpot Verification Advisory Services Implementation Guidance Consulting Best Practice Development Security Threat and Vulnerability Assessments Client Training

29 DATA SERVICES DEPARTMENT Total Gaming Transactions Review or TGTR Payout Percentage Reviews Random Number Generator (RNG) Reviews Output Based Testing The concern is not so much that the RNG operates randomly, but that there is no manipulation between the number generated and the number displayed. Perform continuous output based testing to ensure the controls are in place and that they perform as intended

30 Payout Percentage Reviews ecogra DATA SERVICES DEPARTMENT Objective is to provide transparency, credibility and fairness Two tier approach Primary Analysis Payouts to wagered as a percentage Reconcile the movement in player balances per casino per currency Secondary Analysis Trend analysis over a 12 month period consolidated per currency, game category, casino based on: Transaction volumes Total bets Total payouts Average bets Payout percentages

31 DATA SERVICES DEPARTMENT Random Number Generator (RNG) Reviews Objective is to provide fairness by demonstrating: Uniformity: each element has an equal chance of being selected Independence: previous game outcomes should not influence subsequent game outcomes

32 KPMG AUDITOR S QUALITY ASSURANCE 1. Review of the Internal Assessment Teams To assess whether the teams have the right people skills and strategy to deliver their objectives and whether the processes are in place to enable them to respond quickly to changing business needs. 2. Review of Casino and Poker egap work Programs To provide quality assurance and advice on whether sufficient testing is performed for each egap requirement, and providing best practice advice on sample sizes. 3. Review of Random Number Generator (RNG) Methodology To provide quality assurance and independent best practice advice on the adequacy and completeness of the RNG methodology. 4. Payout Reconciliation Reviews Conduct a quality assurance review on an annual basis on the process followed to conduct payout reconciliation reviews.

33 Dispute Mediation Offered to players at all ecogra Approved sites Responsible Gambling Provide player with a safe environment Measures Tools

34 Dispute Mediation ecogra Service started in 2004 Covers 130+ sites Casino, Poker, Bingo and Sportsbooks Received in excess of 3000 mediation requests Average of 72 hours to resolve issues

35 Dispute Mediation Statistics 2007/8 ecogra Dispute mediation requests received = 743 (2007 = 783) Number of non ecogra site requests = 97 (13%) Number of Invalid requests received = 96 (13%) Number of Valid dispute mediation requests received = 550 (74%) Number of valid disputes resolved in favour of the player = 272 (49%) An Invalid complaint is a submission that does not address a specific incident or issue with a Safe and Fair sealed site and can therefore not be investigated by the Fair Gaming Advocate.

36 Dispute Mediation Statistics 2007/8 Valid disputes received by type: ecogra Average number of disputes received per week = 10.6 (2007 = 12.4) Average number of disputes received per approved site per month = 0.36 (2007 = 0.44)

37 The responsibility for an individual s gambling is their own The responsibility to exercise a duty of care is that of the operator

38 The over riding moral obligation to exclude underage and problem gamblers felt by most major Internet operators has been seriously boosted by the need to counter the false perceptions being created by the industry's detractors. For online operators that means the continued and diligent application of genuine responsible gambling programs, at the same time ensuring that the rapidly evolving exclusionary technologies and training content are understood and considered.

39 Ultimately, the player is responsible for their actions, but there needs to be a level of prevention and support in place. Through the use of well thought out policies and procedures we can establish a culture of social responsibility within the industry. Responsible Gambling is about giving players the tools they need to play in a secure and supportive environment and guiding those who require assistance to places of help.

40 103.R.1 The homepage of the operator s website must clearly display a no under 18 s or no under 21 s sign, which links through to a clear message about underage play.

41 103.R.2 The registration process shall include a clear message regarding underage play. Limitations of use: It is each player's responsibility to follow his/her local gambling age restrictions. Please note that you need to check with your local authority to check on the gambling legislation that applies to your region. A message that pops up when an age under 18 is entered during the registration process is acceptable. The site should then prohibit the registration.

42 103.R.3 The operator s responsible gambling page must provide a link to a recognised filtering programme to enable players to prevent minors from accessing gambling sites

43 103.R.4 A legal disclaimer shall be displayed on the operator s website stating that no player below the legal age of gambling is legally permitted to participate in Internet gambling. The services offered by this website are to be used for the purposes of legal online gaming and gambling only. It is the responsibility of players to verify that they are legally entitled to take part in gaming and gambling.

44 103.R.5 Websites shall clearly state the terms and conditions applicable in the event that an underage individual is identified. The following is recommended: If [site name] becomes aware that a player is underage, we will, except where there are grounds to believe that a fraud has been perpetrated: Suspend the account immediately; Void all wagers that have taken place; Refund the value of all deposits net of withdrawals; and Close the account.

45 103.R.6 Preventative and detective controls and technology shall be in place to ensure that the prospect of players registering from jurisdictions specifically excluded by the operator is prevented. Technology should be in place in to prevent the registration of player s from excluded jurisdictions as listed in the site s Terms and Conditions. In the absence of a technical solution, documented procedures must be in place.

46 103.R.7 A legal disclaimer shall be displayed on the operator s website stating that only players legally permitted by their jurisdiction in which they are located can participate in Internet gambling, and both players and operators shall be aware of the legal responsibilities in the player s jurisdiction. The services offered by this website are to be used for the purposes of legal online gaming and gambling only. It is the responsibility of players to verify that they are legally entitled to take part in gaming and gambling.

47 103.R.8 Those operators which permit under 18 s to use their free play websites shall require all players to such sites to confirm in some manner whether they are underage or not. This should be done when the player first enters the Free Play site. This information is crucial to the marketing department to ensure that they are not marketing to underage players.

48 103.R.9 Appropriate operator personnel shall be trained on the issues of social responsibility and problem gambling. ecogra hosts a bi annual training course for all approved operators in conjunction with GamCare. GamCare is also available for further staff training and accreditation.

49 103.R.10 Players self exclusion shall be in accordance with the following: 103.R.10.1 Procedures for self exclusion due to problem gambling must be clearly communicated to players on the operator s website. 103.R.10.2 Self exclusion due to a gambling addiction must be for a minimum period of six months. 103.R.10.3 The site shall also provide a cooling off exclusion option. The operator reserves the right to exclude a player for a longer period of time at their discretion.

50 103.R.10 Players self exclusion shall be in accordance with the following: If you feel that you have played to long but still have the urge to play some more, we offer you the following options; A cooling off period A minimum 6 month self exclusion period This will mean that you will not be able to logon to our website during the exclusion period. The casino will make every effort to ensure that you are timeously blocked from entering the site. If you would like to request a cooling off period or self exclusion, please call our Customer Care hotline any time, day or night, for immediate action or click here.

51 103.R.10 Players self exclusion shall be in accordance with the following: 103.R.10.4 Once a player has requested an exclusion due to a gambling addiction, operators shall take reasonable steps to ensure that the player does not receive any promotional materials during the exclusion period. Remove the player s details from any and all promotional databases and make every effort to remove the player from affiliate databases.

52 103.R.11 The homepage of the operator s website must contain a clear link to a Player Protection and Responsible Gambling page, which shall contain at a minimum: 103.R.11.1 A warning that gambling could be harmful if not controlled and kept in moderation. WARNING While most players at an online casino or poker room gamble for entertainment and within their means, there are a small percentage of players who may lose control of their play. In order to prevent this, please bear the following in mind; Gambling should be entertaining and not seen as a means to make money Keep track of the amount of money you spend and only gamble what you can afford to lose. Do not chase your losses. Keep track of the amount of time you spend gambling.

53 103.R.11 The homepage of the operator s website must contain a clear link to a Player Protection and Responsible Gambling page, which shall contain at a minimum: 103.R.11.2 Advice on responsible gambling and a link to sources of help on problem gambling, including helpline numbers. GamCare UK Gamblers Anonymous International National Council on Problem Gambling Responsible Gambling Council

54 103.R.11 The homepage of the operator s website must contain a clear link to a Player Protection and Responsible Gambling page, which shall contain at a minimum: 103.R.11.3 An accepted and simple self assessment process to determine risk potential. CPGI/PGSI (Ferris & Wynne 2001) The NORC Diagnostic Screen for Gambling Problems

55 103.R.11 The homepage of the operator s website must contain a clear link to a Player Protection and Responsible Gambling page, which shall contain at a minimum: 103.R.11.4 A list of player protection measures (deposit limits and selfexclusion) that are available on the site, and access to these measures. The Responsible Gambling page should clearly state that deposit limits and self exclusion are available, details of the limits and exclusions should be readily available and there should be a prominent link to either an automated system or customer service department.

56 103.R.11 The homepage of the operator s website must contain a clear link to a Player Protection and Responsible Gambling page, which shall contain at a minimum: 103.R.11.5 Details, or a link to a page with the operator s responsible gambling policy. While most people gamble for social enjoyment, we acknowledges that gambling can create problems and harm some individuals. These problems can range from over spending to pathological gambling addiction. We are committed to creating a responsible gambling environment by implementing and maintaining ecogra s responsible gambling requirements, for the benefit of both players and staff.

57 103.R.12 The casino software shall contain a clear reminder to the player about responsible gambling, and a link to the Player Protection and Responsible Gambling page. A link to the Player Protection and Responsible Gambling page must be available to the player in the downloaded software. This can be in the shape of radio button, menu option, or on the main page.

58 103.R.13 Messages of an operator s support of responsible gambling shall not be misleading. Ensure that all information on Responsible Gambling is true, clear and achievable. There should be no bonuses or other advertising on the Responsible Gambling page.

59 103.R.14 Players shall be able to decrease their deposit limits per day, week and month, and these requests shall be dealt with timeously by the operator. Increases in previously decreased deposit limits requested by players shall only be effective after 24 hours. This is automated in most software, however where this is not the case operators will need to ensure that policies and procedures are in place for an effective manual system.

60 103.R.15 A clock shall be available on the screen at all times. The PC clock being available in the operating software meets this requirement. Where the software covers the entire screen, there must be clock visible in the gambling software

61 103.R.16 The start time between each slots game play shall be at least 3 seconds. Reality Check 103.R.17 The denomination of each credit shall be clearly displayed on the games screen. Reality Check

62 103.R.18 The free play game website must provide links to the same age restriction, responsible gambling and player protection information as the real money website. Most sites will make use of the same Responsible Gambling and Player Protection pages.

63 103.R.19 All disputes received from players shall be dealt with timeously and conducted through a formal documented process. 103.R.20 An easy and obvious mechanism for escalating player complaints shall be provided. Policies and procedures should be in place to document the internal dispute mediation process and the escalation of any dispute that can not be resolved internally.

64 103.P.1 Where convenient, direct communication with the player should carry a responsible gambling message as a footer. The wording of a footer can vary from something short and concise to more detailed: Gamble Responsibly We support Responsible Gambling please visit our Responsible Gambling page at [URL]. Smart player s gamble responsibly! We want you to enjoy your gambling experience, but do not forget that being responsible is key to making sure things remain fun.

65 107.R.4 The theoretical statistical return percentage for a particular game type should be no less than that of the equivalent game in free play mode. This requirement ensures that player s are not given a false sense of payout percentages on a Free Play site that they then expect on the Real Money site. A gambling experience in Free Play mode should be the same as in Real Money mode.

66 113.R.2 The placement and content of adverts shall not target those under the legal gambling age. Adverts should not be placed in publications or on sites targeted at children or made attractive to children through the use of overtly child friendly material. Adverts cannot present gambling as a solution to problems or misrepresent the rules of the game.

67 Thank you

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