Rights of stakeholders and partners

1) Introduction: who are the "stakeholders"

• Users/clients,
• Employees/contractors,
• Suppliers/providers (game studios, PSP/acquiring bank, KYC providers, hosting, anti-fraud),
• Affiliates/agency networks and marketing partners,
• Investors/shareholders,
• Regulators and Ombudsmen/ADRs,
• Local communities and NGOs.
• The purpose of this policy is to clearly record their rights, expectations and protection mechanisms, embedding them in contracts, processes and metrics.

2) Principles of interaction (basis for all groups)

1. Transparency and awareness (understandable conditions, changelogs).
2. Integrity and non-discrimination (equal terms and access).
3. Data and privacy protection (minimization, security, legality).
4. Safety and quality (SLA/SLO, monitoring, post-mortems).
5. Accountability (complaint channels, independent review, right to appeal).
6. Right to audit and audit within reasonable limits.
7. Responsible AI and marketing (explainability of decisions, prohibition of manipulations).
8. Zero tolerance for corruption, conflicts of interest and repression.

3) Matrix of rights and protection mechanisms

4) Binding contractual clauses (fragments)

Anti-corruption and conflicts of interest

"The Parties confirm compliance with applicable anti-corruption laws; the breach is material and shall result in immediate termination"

Data protection and privacy

"Each party acts as a controller/processor within its roles, provides a legitimate basis for the processing, minimization, security and fulfillment of the requests of the entities within the established time frame."

Right to audit

"Upon reasonable notice and working hours, a party may conduct a documentary verification of compliance with the contract, including sub-contractors in the service area, subject to confidentiality."

SLAs and penalties for unavailability

"Service availability - 99.9% per quarter; for violation - service loans/fines. For payments - TtW not more than X hours at the median; violation - commission compensation"

Change Transparency

"Changes affecting rights and financial terms are published with a changelog and grace period of at least N days."

ADR/Arbitration

"Disputes are referred to an independent ADR/arbitration after the claim procedure; place and right - as per annex"

5) Complaint and dispute resolution channels (general procedure)

Reception and registration: application ID, confirmation ≤ 7 days.
Initial analysis: qualification, collection of facts ≤ 30 days.
Decision/interim response: ≤ 90 days, possibility of appeal.
Escalation: internal compliance/board → ombudsman/ADR → arbitration/court.
Prohibition of reprisals against the applicant; protection of whistleblowers.

6) SLA/operating standards (benchmarks)

7) Specificity by group

7. 1 Users

Rights: honest advertising, transparent bonuses/vager, clear KYC levels and reasons for refusals, appeal restrictions, data protection, available Responsible Gaming channels.
Mechanisms: FAQ with examples of commission calculations, status page, self-exclusion/limits, ADR channel.

7. 2 Suppliers/Providers

Rights: clear scope, API release and decrement calendar, timely payment, return of defects according to the agreed process.
Mechanisms: MSA/SOW, OLA between tech teams, CAB procedures, UAT environment, incident statuses.

7. 3 Affiliates/Agents

Rights: transparent attribution, access to raw metrics/postback calendar, timely payments and understandable reasons for deductions.
Mechanisms: anti-fraud rules, register of sources, revisions of creatives, limitation of geo and age segments.

7. 4 Employees/Contractors

Rights: security, equal opportunities, understandable grades and promotional criteria, protection against harassment and repression, data privacy.
Mechanisms: Code, Equal Opportunity Policy, Whistleblower Policy, DEI-board, fair investigation procedures.

7. 5 Investors

Rights: regular and reliable reporting, information about risks/compliance/ESG, access to board materials according to the regulations.
Mechanisms: reporting calendar, KPI summaries (uptime, TtW, compliance), audit, insider policy.

7. 6 Regulators/Ombudsmen

Rights: Timely notifications, full facts, access to investigative artifacts.
Mechanisms: regulatory contacts 24/7, 72h-runbook, incident log and CAPA.

7. 7 Communities/NGOs

Rights: honest communication, protection of vulnerable groups, dialogue with significant changes.
Mechanisms: responsible marketing policy, consulting, public ESG reports.

8) Responsible AI and algorithmic transparency

Stakeholder rights: to know about the use of AI, to receive explanations of significant decisions (limits, KYC escalation), to have an appeal channel, protection against discrimination and manipulation.
Mechanisms: Model Cards, DPIA/AI risk assessments, fairness tests, human-in-the-loop, red teaming, decision and appeal journal.

9) Right to audit and compliance certificates

Mutual audit within reasonable limits (ISO 27001/27701, SOC 2, PCI DSS, GLI/eCOGRA laboratories - if relevant).
Clarify: N days notice, sample size, confidentiality, prohibition of copying sources/secrets.
For affiliates/marketing - audit of traffic sources and compliance with advertising ethics.

10) Changes to Terms and Conditions and Notices

Chenglog with the date, "what/why has changed," the time of entry, a link to the archive of versions.
Grace period for critical changes (tariffs, limits, marketing rules).
Multi-channel communication: e-mail, banner in the office, partner portal.

11) RACI (who is responsible for what)

12) Implementation checklist (60-90 days)

1. Stakeholder map and register of their rights/expectations.
2. Update MSA/SOW/Affiliate-T & C: anti-corruption, data, SLA, ADR, audit, changelog.
3. Launch public pages: CUS/payments/commissions, Responsible Gaming, status page.
4. Set up a single complaint showcase (ID, statuses, SLA) and ADR route.
5. Approve AI/algorithmic transparency: Model Cards, appeals, fairness monitoring.
6. Introduce quarterly reports to the board: uptime, TtW, compliance incidents, complaints and CAPAs.
7. Sign supplier code and audit procedures; Create a revision calendar.
8. Conduct trainings for teams: contractual obligations, incident comas, anti-fraud affiliates.

13) Typical risks and mitigation

14) Related Documents

Transparency of corporate processes

Code of Ethics and Conduct

Whistleblower policy and personnel protection

Anti-Corruption Standards and ISO 37001

Compliance and audit certificates

Privacy and data processing policy

Ethics of artificial intelligence

Responsible Marketing & Affiliate Policy

Output

Stakeholder rights are implemented through clear contracts, transparent rules, measurable SLAs, independent complaint channels, and the right to audit. By anchoring these elements in processes and communications (including AI transparency), the platform reduces legal and reputational risks, builds trust and builds sustainable partnerships for years.