GH GambleHub

Gender equality and inclusion

1) Introduction and objectives

Gender equality is equal access to recruitment, training, pay, promotion, benefits and safety for employees of all gender identities and expressions. The goal of the policy is to remove systemic barriers, reduce the risk of discrimination and harassment, and increase team engagement and decision quality.

2) Principles and scope

Zero discrimination on gender, gender identity and expression, pregnancy, parental status, marital status, sexual orientation.
Equal opportunities in recruitment, pay, development and leadership.
Safe environment: banning harassment and bullying.
Confidentiality and respect for personal data (including health and transition).
The policy applies to employees, candidates, contractors, affiliates and partners.

3) Pay Equity

Single grades and forks by roles/locations; transparent criteria for offers and promotions.
Annual pay equity audit and adjustments when unexplained gaps are identified.
Prohibition to demand/take into account the candidate's salary history; reliance on market data and internal grade.
Public bonus/RSU principles and allocation criteria.

4) Inclusive hiring and growth

Gender-neutral jobs; a list of "required/desirable" skills.
Structured interviews and scorecards, panel format for bias reduction.
Transparent career ladders and access to mentoring/training programs.
Quotas do not replace meritocracy: goals for representation are like OKR benchmarks, not rigid quotas in hiring.

5) Safety and antiharassment

Zero tolerance for sexual harassment, "jokes," intrusive comments, uninvited touching and any form of online/offline harassment.
Confidential channels of calls (external line/internal bot), protection against repression.
SLA: confirmation - 7 days, initial review - 30, total/interim response - 90 days.
Mandatory trainings for everyone, in-depth trainings for managers.

6) Support for parenthood and work-life balance

Maternity, paternity and partner leave are gender neutral.
Flexible schedule/hybrid/remote, right to disconnect.
Return after vacations without penalties to career and bonuses; target remapping and soft entry programs.
Support for caring for loved ones (caregiver policy).

7) Support for gender transition

Confidential transition plan: new display-name/addresses/accesses, updating HR systems, if necessary - changing the uniform/bathrooms.
Medical benefits, where applicable (consultations, medications, therapy).
Trainings for the team, appointment of an ally coordinator.
Policy of access to spaces and systems - by self-identification and local law.

8) Infrastructure and availability

Accessible gender-neutral bathrooms along with traditional markings.
Dress code - neutral and safe, allows cultural/religious elements.
Protocols for corporate events: no alcohol "mandatory," nutrition options, safe transfers.

9) Communication and etiquette

Respectful use of employee and customer names and pronouns.
Standards of visuals and content without sexualization/stereotyping.
Guide for internal and external communication (instant messengers, social networks, streams, conferences).

10) Products, marketing and iGaming specifics

Advertising and promo - without stereotypes and hypersexualized images, without targeting vulnerable groups.
UX/content - inclusive avatars/characters, neutral forms of appeal, the option "do not indicate" in the gender fields.
Algorithms of bonuses/limits/scoring - regular fairness tests for gender bias; possibility of appeal to a person.
Tournament/eSports policies - transparent rules, inadmissibility of toxic behavior and harassment in chats/streams.

11) Data and privacy

Minimization and legal grounds for processing data on gender, gender identity, family status and health.

Separate storage of sensitive attributes, restriction of access on the principle of "strictly necessary to know."

In reporting - pseudonymization/aggregation; consent to publish stories/cases.

12) Metrics and goals (DEI-dashboard)

Representation by level (Tech/Non-Tech, leadership), pay-equity-gap and its dynamics.
Hiring funnel: share of candidates/finalists; time to promo by group.
Culture and safety: engagement/psychological safety index; number of calls, proportion confirmed, reaction time.
Training: Covering basic and leadership courses, NPS mentoring programs.
Review frequency by board - at least a quarter; public ESG status annually.

13) RACI (roles and responsibilities)

AreaRACI
Gender equality policyHR/ComplianceCEO/BoardLegal, Security, ESGAll
Pay Equity and GradeComp&BenCOOFinance, HR AnalyticsInternal Audit
Hiring and growthTalent/ManagersCOOHRBP, DEI LeadBoard
Anticharassment and appealsInvestigationsGC/ComplianceHR, SecurityBoard
Parenting/transition supportHRBP/WorkplaceCOOLegal, Health/BenefitsHeads
Marketing/Product (Inclusion)Product/MarketingCPTO/CMOLegal, DEI, DataESG/Board

14) Template positions (fragments)

Non-discrimination: "All forms of discrimination based on gender, gender identity/expression, sexual orientation, pregnancy and parenthood are prohibited. Hiring/pay/promotion decisions are made by competencies and outcomes."

Addresses and pronouns: "Employees have the right to indicate their preferred name and pronouns; their use is mandatory in business communications and systems."

Antiharassment: "The company provides a harassment-free environment; violations lead to disciplinary measures up to dismissal."

Pay Equity: "The company conducts regular equal pay audits and clears unexplained gaps."

Parenthood support: "Leave and flexible forms of employment are provided on a gender-neutral basis."

Transition support: "The Company supports the gender transition by ensuring confidentiality and reasonable adaptations."

15) Implementation checklist (60-120 days)

1. Approve policy, assign DEI Lead and metric owners.
2. Conduct pay-equity audit, update grades/forks and promotional criteria.
3. Rewrite vacancies and guide by interview; train panel interviewers.
4. Launch a mentoring program, leadership courses for underrepresented groups.
5. Update anti-escalation procedures, referral channels and SLAs; conduct trainings.
6. Introduce transition policies and gender-neutral vacations; update benefits.
7. Set up a DEI board and quarterly board reviews; publish a short report.
8. Conduct a fairness assessment of marketing and product algorithms; implement appeals.

16) Related Documents

Code of Ethics and Conduct

Ethics in the work environment and equal opportunities

Whistleblower policy and personnel protection

Anti-discrimination and anti-harassment policies

Privacy and data processing policy

Parenthood Support Policy

Transition Policy

Responsible Marketing & Inclusive Product Guidelines

Output

Gender equality is not a campaign, but a management system: transparent rules → inclusive processes → measurable metrics → safe channels → continuous learning and improvement. When equal opportunity is enshrined in hiring, pay, growth and daily communication, companies get stronger teams, a sustainable reputation and better business results.

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