Code of Conduct

In being committed to following serious and transparent policies in a responsible manner and whilst respecting the legal principles, BetJuego sets out, through this code of conduct, the principles and standards that seek to guide the attitude, behaviour and values of managers, officials, employees and people who are indirectly related to BetJuego, so that they can actively contribute to the growth and strengthening of the sector of games of chance.

RECIPIENTS OF THE CODE OF CONDUCT: it applies to all managers, officials, employees and personnel indirectly linked to BetJuego.

CORPORATE VALUES: our corporate values, such as integrity, respect, responsibility, honesty, transparency as the fundamental axis of our company’s actions, amongst others, are implemented in all BetJuego activities which are the basis of our operation and they support both the ways of working and the way of doing things inside the company.

GENERAL PRINCIPLES: the recipients of this code of conduct are obliged not only to comply with the laws and provisions that regulate games of chance, the regulations issued by the competent authorities, as well as the policies established by COLJUEGOS, as they are also obliged to act in compliance with our principles and with the highest standards of quality and efficiency.

SPECIFIC PROVISIONS: As a result of the foregoing, the managers, officials and employees of BetJuego shall be obliged in all their actions to respect and comply with the following specific principles that safeguard the integrity of the Company’s actions.

  1. In the exercise of their duties, they must act with the greatest integrity, freedom and knowledge in the decision-making, whilst acting in good faith and in compliance with the Law.
  2. Non-disclosure of information of operators and customers, who they get to know in the carrying out of their duties and tasks, thus avoiding prejudices with the disclosure of certain aspects that for contractual, personal or legal reasons must not be freely accessible to the public.

In the carrying out of the above they must refrain from:

– Providing, supplying or disclosing information on the company’s operations, sales, business, customers and databases to third parties, except when required by State Authorities, which must be provided by the Compliance Officer.

– Communicating or disclosing confidential information that could damage the image or prestige of BetJuego or third parties.

– Performing any transaction for themselves or for a third party using inside information of BetJuego or its providers, partners or the like.

Conflict of Interest. In the event where a situation arises in which the individual interests of the recipients of this Code of Conduct clash with the personal activities or in the dealings with third parties or others, in such a way that this affects the freedom and independence in the decision, the transaction must be analysed on the basis of the legal standards which govern it, and the manuals and procedures established by BetJuego. Likewise, the hierarchical superior must be informed before any decision is taken.

Prevention and control of money laundering and terrorist financing. They must ensure compliance with the standards on the prevention and control of ML/TF, for which it must be taken into account that all the officials linked to the company have the recognised qualities and moral integrity and a lawful and transparent activity. When information is known about the suspicious activity of a customer, provider or partner and it is considered that the contractual relationship should not be extended, immediate notice must be given to the Compliance Officer in order to unify the criterion, prevent adverse repercussions and send the ROS (Suspicious Transaction) reports to the UIAF (Financial Information and Analysis Unit) and other competent authorities and to ensure compliance with the ethical principles, for the achievement of the goals.

Confidentiality. Due confidentiality must be maintained with regard to the work documents and confidential information in their care.

Appropriate use of resources. In accordance with the principles of efficiency and effectiveness, the tools, equipment and other work elements of the company must be used appropriately and properly.

Relationship with the authorities. BetJuego’s relationships with other governmental entities and public authorities must be conducted within the framework of the law and in accordance with the principles described in this Code of Ethics.

Bribery and corruption. BetJuego’s decisions must be based on contractual criteria, without being influenced by external factors. Consequently, managers, officials and employees cannot give, offer or accept, directly or indirectly, gifts, favours, donations, invitations, travel or payments during the course of the activities carried out in the company, which may influence its decisions to facilitate operations for its own benefit or the benefit of third parties.

PREVENTION OF IMPROPER ACTS

BetJuego’s main aim is to optimise its resources by proactively identifying, analysing and managing the risks to which it is exposed. Therefore, the managers, officials and employees must have a preventive attitude, identifying potential risks in the processes under their responsibility, and they must make the necessary efforts to exercise control over all the operations under their responsibility, in accordance with the law and best administrative practices.

INFORMATION CHANNELS

The Code contains some general guidelines that will allow assessing a large part of the situations that may be faced by its recipients.