Responsible Gambling Policy

1. Introduction

This Responsible Gambling Policy (“Policy”) is established by Zplnn Casino (“we”, “us”, “operator”), a licensed remote gaming operator regulated by the Tobique First Nation Gaming Commission. The objective of this Policy is to outline the operator’s obligations and procedures with respect to the promotion of responsible gambling practices, the identification and mitigation of gambling-related harm, and the implementation of tools and interventions designed to safeguard vulnerable persons.

We recognise that while the provision of gambling services constitutes a lawful and regulated form of entertainment, such activity may present a risk of harm to a small percentage of individuals. As a licensed operator, we accept a duty of care to identify and mitigate such risks through a structured program of responsible gambling measures. This Policy is aligned with applicable Canadian responsible gambling standards, including but not limited to:

• Tobique First Nation Gaming Regulation;
• Canadian Centre on Substance Use and Addiction (CCSA) Guidelines; and
• Responsible Gambling Council (RGC) Best Practices.

Accordingly, this Policy outlines the operator’s internal procedures and controls, which include, but are not limited to:

• Prevention of access to gambling services by individuals under the legal age;
• Implementation of voluntary player protection mechanisms such as deposit and loss limits, reality checks, time-outs and self-exclusion;
• Provision of accurate and accessible information to assist players in making informed decisions;
• Monitoring and review of player behaviour to identify potential indicators of problem gambling;
• Staff training on the identification and handling of gambling-related harm;
• Cooperation with external organisations that provide support, treatment, or guidance;
• Ensuring that marketing and promotional activity is conducted in a socially responsible manner.

The implementation of this Policy is mandatory across all platforms and services operated under our licence and is subject to regular review.

2. Responsible Gambling Objectives

The primary objective of this Policy is to ensure that all gambling activity is conducted in a manner that upholds player welfare and minimises the potential for harm. The following core goals are adopted:

• Preventing Gambling-Related Harm: identifying and reducing risks by promoting informed player behaviour, limiting excessive play, and supporting individuals at risk of harm.
• Promoting Player Control and Informed Choice: empowering players with practical tools and accessible information, including the ability to set personal limits, access account history, and request time-outs or permanent exclusion.
• Protecting Minors and Vulnerable Persons: enforcing strict access controls so that individuals under the legal gambling age, and persons identified as vulnerable, are not permitted to register, deposit, or play.
• Ensuring Transparency and Accountability: operating transparently so players understand the games offered, the risks involved, and the resources available to them.
• Supporting Early Detection and Intervention: monitoring player behaviour and transaction patterns to detect indicators of potential problem gambling and intervening where appropriate.
• Training and Oversight: maintaining a formal training program so relevant staff can recognise signs of gambling-related harm and respond appropriately.
• Collaboration and Referral: maintaining relationships with external support organisations and treatment providers, and referring players to such services where appropriate.

3. Access and Age Restrictions

Access to gambling services provided by us is restricted to individuals who meet the following eligibility criteria:

• The individual must reach the minimum legal age for gambling applicable in their jurisdiction or under applicable law;
• The individual must not be subject to any self-exclusion measure, account suspension, or permanent exclusion;
• The individual must not be identified as a vulnerable person or otherwise prohibited from participation under applicable law or internal policy.

The operator enforces age restrictions as a condition of its licence and takes reasonable steps to prevent unauthorised access through age verification processes and technical safeguards.

Age Verification Protocols

All players are subject to age and identity verification as part of the registration and onboarding process, which may include the submission and validation of government-issued identification; electronic verification against approved databases; and manual review of supporting documentation confirming name, date of birth and permanent address. In all cases, age verification must be completed prior to any withdrawals and within the timeframe specified in the operator’s internal procedures. Where age cannot be verified, access to gambling services may be withheld until verification is complete.

4. Player Control Tools

In accordance with applicable laws and standards, we may provide players with access to gaming management tools designed to support responsible gambling practices. These tools are made available at the discretion of the operator and subject to licensing conditions and technical feasibility. The operator may offer one or more of the following features:

• Deposit Limit: a voluntary limit that restricts the total amount a player may deposit over a defined time period (e.g. daily, weekly, or monthly);
• Loss Limit: a limit on the amount a player may lose within a set timeframe;
• Time Played Reminder: a session-based alert that informs players of the duration of their gameplay.

Where such tools are made available, access may be provided through the player’s account interface or by contacting customer support. The availability of any given tool is not guaranteed and may vary depending on jurisdiction, platform capabilities, or licence conditions. These features assist players in making informed decisions but do not constitute a guarantee against gambling-related harm.

5. Self-Exclusion and Account Closure

Voluntary Self-Exclusion

We provide players with the option to request self-exclusion from gambling services for a defined or indefinite period, subject to applicable licensing conditions and technical availability. Upon receipt of a valid request, the operator shall take reasonable measures to restrict access to the player’s account for the duration specified. Self-exclusion requests may result in suspension of access to gambling functionality; ineligibility to receive promotional materials; and deactivation of deposit and wagering capabilities.

Requests and Confirmation

A self-exclusion request may be submitted through the player account interface or through customer support channels. The operator may require identity verification prior to activating the exclusion. Once processed, confirmation will be provided and the exclusion will take effect as soon as reasonably practicable. Self-exclusion periods are not reversible prior to expiry unless permitted by law and subject to a formal reactivation procedure.

Permanent Account Closure

Players may request permanent closure of their accounts at any time. Account closure does not constitute self-exclusion unless explicitly stated by the player and accepted by the operator as such. Upon closure, residual balances (if any) will be returned to the player in accordance with the applicable withdrawal procedures, unless the account is under investigation or subject to legal or regulatory restriction.

Operator Discretion

The operator reserves the right to impose an exclusion or suspend access to services where it identifies activity that may indicate gambling-related harm, misuse of the platform, or other concerns, including compliance risks.

6. Identifying Problem Gambling Behaviour

We recognise that while most individuals engage in gambling as a form of entertainment, certain patterns of play may indicate elevated risk or the presence of gambling-related harm. As part of its responsible gambling framework, the operator may monitor account activity for indicators that could suggest problematic behaviour.

Behavioural Indicators

While not exhaustive or determinative, the following behaviours may be relevant for identifying risk:

• Frequent or large increases in deposits or betting activity without a clear source of funds;
• Repeated requests to reverse withdrawals;
• Extended gaming sessions without breaks;
• Indications of financial distress or repeated contact regarding losses;
• Use of multiple accounts or third-party payment methods;
• Player communications referencing loss of control or emotional distress.

The presence of one or more of these factors does not conclusively indicate a gambling problem but may prompt further review or precautionary action.

Monitoring and Action

The operator may, at its discretion and subject to applicable laws and technical capacity, flag accounts exhibiting patterns of concern for internal review; initiate communication with the player; provide or suggest the use of responsible gambling tools; and impose temporary restrictions or exclusions if deemed necessary to protect the player or fulfil licensing obligations. While the operator may review activity for signs of problem gambling, no monitoring system can identify all instances of gambling-related harm; players are encouraged to act responsibly and seek assistance where appropriate.

7. Staff Training and Intervention

We recognise that front-line and compliance personnel play an essential role in supporting responsible gambling objectives. Internal procedures may include staff training programs designed to promote awareness of gambling-related harm and appropriate methods of response.

Staff Awareness and Roles

Employees in relevant operational areas may receive training on recognizing common indicators of problem gambling behaviour; understanding the tools available to players (e.g. deposit limits, self-exclusion); communicating with players in a respectful and supportive manner when concerns arise; and referring players to appropriate internal processes or external support services. Training content and frequency may vary depending on the employee’s role, scope of authority and level of interaction with players.

Internal Reporting and Escalation

Where staff members identify behaviour consistent with potential gambling harm, they may be instructed to document the concern and escalate the matter through defined internal channels. All such reports are handled in accordance with internal risk management protocols and applicable privacy obligations. Interventions may include proactive outreach, temporary restrictions, or account reviews, with final decisions made by designated personnel with appropriate training and authority. Employees acting in good faith and in accordance with internal procedures shall not be personally liable for actions taken or not taken in relation to suspected problem gambling unless otherwise required by law.

8. Information and Player Awareness

We may provide players with access to information relating to responsible gambling, including general guidance on the risks associated with gambling, tools for self-assessment, and contact details for professional support services. Where made available, responsible gambling content may include:

• Explanations of how gambling works, including the role of chance and odds;
• Warnings against gambling as a source of income or a solution to financial hardship;
• Guidance on staying in control of time and money spent on gambling;
• Descriptions of the player protection tools (e.g. deposit limits, self-exclusion), where applicable.

The operator may display warnings regarding gambling risks, such as “Please play responsibly” notices, age restriction disclaimers, and reminders not to chase losses. These notices are intended for general awareness and do not constitute legal or financial advice. Players who identify potential gambling-related issues may be directed to recognised third-party support organisations, which may include national or regional helplines, counselling or treatment services, and online self-assessment tools. The operator does not provide therapeutic or diagnostic services and shall not be held responsible for the content or conduct of third-party support providers.

9. Marketing and Promotional Practices

We are committed to ensuring that all marketing and promotional materials are communicated in a socially responsible manner and do not undermine the principles of responsible gambling. Our marketing does not:

• Portray gambling as a solution to financial problems;
• Encourage excessive or reckless gambling;
• Imply that gambling guarantees success, popularity, or personal fulfilment;
• Target or appeal to individuals who are underage or self-excluded.

Where promotional offers (such as bonuses or free plays) are made available, the applicable terms and conditions are clearly disclosed, and all promotional materials are intended to be accurate, fair and not misleading. Individuals who have self-excluded will not knowingly receive marketing communications during the exclusion period, subject to technical limitations and jurisdictional constraints.

10. Support and Referral to External Help Services

We acknowledge that some individuals may require external support in managing their gambling behaviour. While the operator does not provide diagnostic or therapeutic services, information about independent help organisations may be made available for the benefit of players. Where applicable, players may be referred to recognised third-party support organisations, which may include:

• ConnexOntario — a confidential 24/7 helpline connecting individuals to support services across Ontario. Website: www.connexontario.ca.
• Responsible Gambling Council (Canada) — provides education, tools and information on safe gambling practices. Website: www.responsiblegambling.org.

Other support services may be listed depending on the player’s jurisdiction. References to third-party support services are provided for informational purposes only. We do not endorse the content, advice, or effectiveness of any external provider, and accept no responsibility for any services rendered by such organisations.

You can also contact our responsible gaming team directly at responsiblegaming@zplnn.st.

11. Data Protection and Confidentiality

The protection of player information, particularly where it relates to responsible gambling measures, is an important part of our overall risk management framework. All matters concerning the handling of personal data, including information arising from self-exclusion requests, account-level controls, and behavioural monitoring, are addressed separately under our Player Privacy and Protection Policy.

12. Monitoring, Review and Continuous Improvement

We maintain internal processes to monitor the effectiveness of our responsible gambling measures and to support the ongoing development of our risk mitigation practices. This Policy is subject to regular review by designated personnel or departments. Reviews may consider:

• Operational effectiveness of player protection tools;
• Feedback from regulatory authorities, players, or staff;
• Developments in technology or best practices;
• Changes to applicable laws or licensing requirements.

Revisions may be made as necessary to ensure the Policy remains current, practical and aligned with the expectations of the Tobique Gaming Commission and other relevant stakeholders. Implementation may be supported by monitoring systems or periodic audits to ensure procedures are applied consistently and that any deficiencies are identified and addressed. Where appropriate, the operator may consider emerging methods for detecting and reducing gambling-related harm, subject to regulatory requirements, operational feasibility and management discretion.