1. Purpose and Scope

This Responsible Gaming Policy (“Policy”) sets out the commitment of Winlot 888 to promoting safe, ethical, and socially responsible gambling. The objectives of this Policy are to protect customers from potential gambling-related harm, comply with applicable Nigerian laws and regulatory requirements, and support a sustainable and responsible gaming environment.

This Policy applies to all directors, employees, agents, contractors, and customers across all jurisdictions in Nigeria in which KBET operates.

2. Regulatory Compliance

2.1 KBET shall comply at all times with applicable gambling laws and regulations in Nigeria, including licensing conditions issued by relevant State Gaming Authorities (such as the Lagos State Lotteries and Gaming Authority) and any applicable federal legislation or regulatory guidance.

2.2 KBET recognises that gambling regulation in Nigeria is predominantly state-led and that regulatory requirements may differ between jurisdictions. KBET shall take reasonable steps to ensure compliance with the responsible gaming obligations imposed by each relevant licensing authority.

2.3 This Policy shall be reviewed and updated promptly to reflect changes in legislation, regulatory guidance, or licence conditions relating to responsible gaming.

3. Minimum Legal Age and Identity Verification

3.1 Gambling services shall only be provided to individuals who are 18 years of age or older, or the minimum legal age prescribed by the applicable State Gaming Authority, whichever is higher.

3.2 KBET shall implement robust age and identity verification procedures at account registration and, where appropriate, on an ongoing basis, to prevent underage gambling and identity misuse.

4. Responsible Gaming Information and Awareness

4.1 KBET shall provide clear, accessible information to customers about the risks associated with gambling and the principles of responsible play.

4.2 Responsible gaming information shall be prominently displayed across KBET’s platforms, including websites, mobile applications, and customer communications.

4.3 Customers shall be provided with transparent information regarding game rules, odds, payout structures, and the inherent risks associated with gambling.

5.  Player Tools and Account Controls

5.1 KBET shall make available a range of player protection tools designed to support responsible gambling, including:

●      Deposit limits

●      Loss limits

●      Wager limits

●      Session time limits

●      Temporary and permanent self-exclusion options

5.2 Customers shall be able to activate, adjust, or request these tools in a straightforward manner, subject to applicable regulatory requirements.

5.3 Requests for self-exclusion shall be implemented without undue delay and shall be maintained in accordance with applicable laws and licence conditions.

6.     Monitoring and Early Intervention

6.1 KBET shall monitor customer gambling activity to identify behavioural indicators that may suggest gambling-related harm, including repeated chasing of losses or significant increases in gambling frequency or expenditure.

6.2 Where such indicators are identified, KBET shall take proportionate and appropriate action, which may include:

●      Providing responsible gaming information and reminders

●      Recommending the use of player protection tools

●      Encouraging time-outs or -exclusion

6.3 Customer interactions for responsible gaming purposes shall be conducted in a supportive, non-judgmental, and confidential manner.

7. Advertising and Marketing Standards

7.1 All advertising, promotional, and sponsorship activities shall be conducted in a socially responsible manner and in compliance with applicable state and federal advertising requirements.

7.2 Marketing communications shall not:

●      Target or appeal to minors

●      Portray gambling as a solution to financial, personal, or social difficulties

●      Glamourize excessive or irresponsible gambling behaviour

7.3 Responsible gaming messages shall be included in marketing materials where required by applicable regulations or codes of practice.

8. Support and Referral Services

8.1 KBET shall provide customers with information about available support services for gambling-related harm, including counselling services, helplines, and educational resources accessible to customers in Nigeria.

8.2 Where local support services are limited, KBET may also reference reputable international organisations, while continuing to monitor developments in domestic responsible gambling infrastructure.

8.3 Where regulator-supported or multi-operator self-exclusion frameworks exist, KBET shall take reasonable steps to participate in or integrate with such systems.

9. Training and Staff Responsibility

9.1 KBET shall provide periodic responsible gaming training to employees whose roles involve customer interaction, compliance oversight, marketing, or operational decision-making.

9.2 Training shall cover:

●      Responsible gaming principles

●      Recognition of potential problem gambling indicators

●      Applicable Nigerian regulatory requirements

●      Internal escalation and support procedures

10. Data Protection and Privacy

10.1 KBET shall process and protect customer personal and financial data in accordance with the Nigeria Data Protection Act 2023 (NDPA) and other applicable data protection laws and industry standards.

10.2 Monitoring and analysis conducted for responsible gaming purposes shall be limited to what is necessary and lawful and shall respect customer privacy rights.

11. Governance

11.1 The Board of Directors and senior management endorse this Policy and are responsible for ensuring its effective implementation.

11.2 KBET shall appoint a Responsible Gaming Officer or designate an appropriate senior function to oversee compliance with this Policy, maintain relevant records, and report responsible gaming matters to senior management.

11.3 Failure by employees, agents, or contractors to comply with this Policy may result in disciplinary action in accordance with internal policies.

11.4 This Policy shall be reviewed at least annually, or more frequently where required by changes in law, regulation, licence conditions, or operational risk.

11.5 KBET is committed to continuous improvement of its responsible gaming measures in line with evolving regulatory expectations and industry best practice.