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Complaints Management and Dispute Resolution Policy

1. Policy Intent and Coverage

This Complaints Management and Dispute Resolution Policy (“Policy”) outlines the approach adopted by Ventures Lab Limited Malta (the “Company”, “we”, “our”, or “us”) to ensure that customer complaints and disputes are handled in a structured, fair, and efficient manner.

The Policy is an integral component of the Company’s regulatory compliance and governance framework and is approved by Senior Management. It is intended to align with all applicable Maltese legal requirements, MGA regulatory obligations, and relevant consumer protection standards.

This Policy applies to:

  • All registered customers and users of the Company’s services
  • All gaming, wagering, and related services operated under MGA authorisations
  • Employees, contractors, agents, and outsourced service providers involved in customer-facing or operational activities

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

2. Regulatory Foundations

This Policy is developed in accordance with:

  • The Gaming Act (Chapter 583 of the Laws of Malta)
  • Licence conditions, directives, and guidance issued by the Malta Gaming Authority (MGA)
  • Applicable consumer protection legislation
  • Data protection obligations, including the General Data Protection Regulation (GDPR)

The Policy ensures that the Company maintains:

  • A fair and accessible complaints framework
  • Transparent investigation and decision-making procedures
  • Appropriate escalation and review mechanisms
  • Compliance with regulatory reporting and audit requirements

3. Core Principles of Complaint Handling

The Company applies the following principles when managing complaints:

Integrity – All complaints are assessed honestly and without undue influence.

Fair Process – Decisions are based on documented facts and applicable rules.

Transparency – Customers are provided with clear explanations of outcomes.

Consistency – Similar cases are treated in a uniform manner.

Escalation Availability – Customers have access to structured internal and external review options.

Senior Management retains oversight responsibility and reviews complaint metrics and governance effectiveness on a regular basis.

4. Staff Capability and Control Environment

Employees involved in complaints handling are required to complete appropriate training covering:

  • Regulatory obligations and MGA requirements
  • Complaint assessment methodology
  • Escalation and reporting processes
  • Responsible gambling awareness

The internal control framework includes:

  • Defined roles and approval hierarchies
  • Documented investigation procedures
  • Restricted system access controls
  • Ongoing monitoring and internal audit review

5. Methods for Submitting Complaints

Customers may submit complaints through the following channels:

  • Dedicated complaints email contact
  • Live chat or customer support system
  • Telephone support services
  • Written communication to the Company’s registered office

To assist in timely resolution, customers should include:

  • Account or user identification details
  • A clear description of the issue
  • Relevant transaction or game references
  • Supporting evidence where available

Submitting a complaint is free of charge and does not affect any rights to external escalation.

6. Complaint Lifecycle

6.1 Receipt Confirmation

All complaints are acknowledged promptly, typically within 48 hours. The acknowledgement confirms receipt, provides a reference number, and outlines expected timelines and escalation rights.

6.2 Investigation and Review

Complaints are assessed objectively and may be escalated internally to Compliance, Responsible Gaming, or Senior Management where appropriate.

The investigation process may include:

  • Review of system logs and technical records
  • Transaction and payment analysis
  • Review of customer communications
  • Examination of applicable internal policies

All actions are documented within the Company’s complaints tracking system.

6.3 Outcome and Communication

The Company aims to provide a final response within 14 business days. Where delays occur due to complexity, customers will be informed and updated throughout the process.

Final determinations are:

  • Evidence-based
  • Clearly communicated to the customer
  • Recorded for audit and compliance purposes
  • Subject to internal governance review

Customers may request a written explanation of the outcome at any time.

7. Escalation Framework and External Remedies

7.1 Internal Escalation

Customers who are dissatisfied with a decision may request an internal review. This escalation is handled by a more senior or independent function, where operationally feasible, and is reviewed separately from the original decision-making team.

7.2 External Escalation Options

If a complaint remains unresolved after internal escalation, customers may refer the matter to:

  • The Malta Gaming Authority (MGA)
  • An MGA-approved Alternative Dispute Resolution (ADR) entity
  • The competent courts of Malta

The Company will cooperate fully with all external dispute resolution processes and provide relevant information where legally required.

8. ADR Outcomes, Binding Effect, and Legal Recourse

Where a dispute is submitted to an Alternative Dispute Resolution (ADR) entity, the following should be noted:

  • The ADR entity will independently assess the dispute and may issue a determination, recommendation, or proposed resolution depending on its mandate.
  • Such outcomes may be non-binding unless formally accepted by the parties or otherwise rendered binding through applicable legal mechanisms.
  • Participation in ADR does not waive or extinguish the customer’s right to pursue judicial proceedings.

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

  • the ADR process does not produce a binding legal decision by default;
  • acceptance of a non-binding outcome may affect the progression of the dispute; and
  • to obtain a binding and enforceable decision, customers may need to pursue the matter through the competent Maltese courts or other legally binding adjudicatory mechanisms.

Customers will be clearly informed of the implications of engaging in ADR, including how it may impact subsequent legal or judicial recourse.

9. Responsible Gambling and Sensitive Complaints

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

These complaints:

  • Are escalated immediately for specialist handling
  • Receive expedited assessment
  • Are subject to enhanced compliance oversight

Where appropriate, such matters may be escalated to Senior Management and included in regulatory reporting.

10. Record Management and Reporting

The Company maintains a secure complaints register for governance, compliance, and regulatory purposes. Records include:

  • Complaint type and classification
  • Investigation steps and evidence reviewed
  • Outcome and rationale
  • Escalation history

All records are retained for a minimum of five years in accordance with regulatory requirements.

Regular reporting may include:

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

Reports may be shared with the MGA where required by licence conditions.

11. Confidentiality and Data Protection

All complaint data is handled in strict confidence and in compliance with applicable data protection legislation.

Access is limited to authorised personnel and safeguarded through:

  • Role-based permissions
  • Audit logging and monitoring
  • Internal security controls and procedures

12. Governance and Policy Review

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

It is:

  • Reviewed on at least an annual basis
  • Updated in response to regulatory, legal, or operational changes
  • Subject to ongoing Board and Senior Management oversight

All material revisions are formally documented and communicated where required.