Complaints and Dispute Resolution Framework

1. Purpose and Scope

This Complaints and Dispute Resolution Framework (“Framework”) sets out the principles and procedures applied by Ventures Lab Limited Malta (“the Company”, “we”, “us”, or “our”) to ensure that all customer complaints and disputes are managed in a consistent, fair, transparent, and timely manner.

The Framework is an integral part of the Company’s compliance and internal governance system and has been formally approved by Senior Management. It is designed to comply with applicable Maltese gaming laws, licence obligations, and regulatory expectations issued by the Malta Gaming Authority (MGA).

This Framework applies to:

  • All customers and users of the Company’s services
  • All gambling, betting, lottery, and related offerings operated under the Company’s licences
  • All employees, officers, contractors, and third-party service providers acting on the Company’s behalf

Ultimate responsibility for the effectiveness of this Framework rests with the Board and Senior Management, who ensure adherence to applicable regulatory and consumer protection standards.

2. Regulatory and Compliance Context

This Framework is developed in line with:

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

The Company’s complaints handling arrangements are designed to ensure:

  • Fair and transparent treatment of customers
  • Accessible and efficient complaint submission routes
  • Proper escalation and independent review mechanisms
  • Regulatory compliance and audit readiness
  • Strong governance and accountability controls

3. Governance and Core Principles

The Company applies the following principles in managing complaints:

  • Accountability – Clear assignment of responsibility for handling and escalating complaints.
  • Impartiality – Reviews are conducted objectively, with separation from initial decision-making where feasible.
  • Transparency – Outcomes are clearly explained and properly recorded for audit and regulatory review.
  • Proportionality – The level of investigation is aligned with the seriousness and complexity of the complaint.
  • Customer Protection – Player welfare, including responsible gambling considerations, is prioritised where relevant.

Senior Management monitors overall performance and effectiveness through periodic reporting and governance review.

4. Staff Training and Internal Controls

Employees involved in complaints management receive structured training covering:

  • Regulatory obligations and MGA expectations
  • Fair investigation standards and decision-making practices
  • Escalation procedures and governance pathways
  • Identification of responsible gambling concerns

Internal control measures include:

  • Segregation of duties where practicable
  • Documented operating procedures
  • Ongoing compliance monitoring
  • Internal and external audit readiness

The effectiveness of these controls is reviewed regularly through compliance and audit functions.

5. Complaint Submission Methods

Customers may submit complaints using any of the following channels:

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

To facilitate efficient handling, customers are encouraged to include:

  • Account identification details
  • A clear description of the issue
  • Relevant transaction or reference numbers
  • Supporting documentation where available

Submitting a complaint is free of charge and does not restrict or affect the customer’s right to pursue further escalation.

6. Complaint Handling Process

6.1 Initial Acknowledgement

All complaints are acknowledged within a reasonable timeframe, typically within 48 hours. The acknowledgement will confirm receipt, provide reference details, and outline indicative timelines and escalation options.

6.2 Review and Investigation

Each complaint is assessed objectively based on internal procedures. Where necessary, the matter may be escalated to Compliance, Responsible Gaming specialists, or Senior Management.

Investigations may involve:

  • Game and system logs
  • Transaction and payment records
  • Customer correspondence
  • Relevant internal policies and operational data

All investigative actions are recorded in a central complaints register.

6.3 Resolution and Outcome

The Company aims to resolve complaints within 14 business days. Where this is not possible due to complexity or the need for further review, the customer will be informed and provided with progress updates.

Final decisions are:

  • Documented with supporting rationale
  • Based on relevant evidence and records
  • Communicated clearly to the customer
  • Subject to internal governance review

Customers may request a written explanation of the decision at any stage.

7. Escalation and Dispute Resolution

7.1 Internal Escalation

If a customer disagrees with the outcome, they may request an internal review by a senior or compliance-level function not involved in the original decision. Escalations are handled independently where operationally possible and subject to documented governance procedures.

7.2 External Dispute Resolution Options

Where a dispute remains unresolved following internal processes, customers may escalate the matter to:

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

The Company fully cooperates with all external bodies and provides requested documentation in accordance with legal and regulatory obligations.

7.3 Important Notice on ADR Outcomes and Legal Rights

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

  • The ADR entity’s determination may result in a recommendation or decision regarding the dispute outcome.
  • Depending on the nature of the ADR mechanism used, the decision may be non-binding unless and until accepted by the relevant parties or otherwise enforced through legal channels.

If a non-binding ADR process is used in accordance with Article 10(2) of Directive 2013/11/EU (as implemented under Directive 5 of 2018), customers will be clearly informed that:

  • participation in such a process does not automatically result in a legally enforceable decision; and
  • the customer retains the right to pursue a binding resolution through the competent courts of Malta or other legally available judicial avenues.

Where applicable, customers will also be informed of the steps required to obtain a binding decision, including escalation to judicial proceedings following completion of ADR processes.

The Company ensures that customers are not misled regarding the legal effect of ADR participation and that all consequences relating to further legal or judicial recourse are clearly communicated.

8. Responsible Gambling and High-Risk Complaints

Complaints involving responsible gambling concerns, including self-exclusion, underage access, or potential harm indicators, are treated as priority matters.

Such cases are:

  • Fast-tracked for review
  • Handled by trained specialists
  • Subject to enhanced oversight by Senior Management

Serious responsible gambling matters may be escalated into compliance reporting and risk monitoring processes.

9. Record Keeping and Reporting

The Company maintains a secure complaints register used for monitoring and regulatory reporting purposes. This includes:

  • Complaint classification and category
  • Investigation steps taken
  • Timeline of handling
  • Outcome and justification
  • Escalation history

Records are retained for a minimum of five years in accordance with applicable regulatory and data retention requirements.

Regular reporting to Senior Management includes:

  • Complaint volumes and trends
  • Root cause analysis
  • Escalation patterns
  • Responsible gambling-related metrics

Where required, complaint data may be reported to the MGA in line with licence obligations.

10. Data Protection and Confidentiality

All complaint-related information is treated as confidential and processed in accordance with applicable data protection laws.

Access is restricted to authorised personnel only, and all processing activities are subject to:

  • Access controls
  • Audit logging
  • Security oversight procedures

11. Policy Governance and Review

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

It is:

  • Reviewed at least annually
  • Updated in response to regulatory, legal, or operational changes
  • Subject to oversight by Senior Management and, where applicable, the Board

All material updates are documented and communicated where necessary to relevant stakeholders.

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