In terms of material historical regulatory actions, and by way of status update, the
following is deemed relevant:
Betway Limited was the subject of two Section 116 License Reviews by the Great Britain Gambling Commission.
Pursuant to the first review, a Regulatory Settlement was entered into with the Great Britain Gambling Commission, with final sign-off subject to its final endorsement of additionally required remedial action. Warnings were also issued against
certain Personal Management License Holders. On September 22, 2021, the Great Britain Gambling Commission formally concluded that, based on all the steps taken by Betway, and all the subsequent information provided, that the relevant Section 116
reviews were both now complete, finalized and that no further action would be taken in this specific regard.
Additionally, the Company is
currently involved in the following material legal proceedings:
On October 25, 2019, Betway Limited issued a claim against the
prohibition order issued against it in relation to its online casino operations in North-Rhine-Düsseldorf (NRW) and 12 additional German federal states (Bavaria, Berlin, Bremen, Hamburg,
Mecklenburg-Western Pomerania, Hessen, Lower Saxony, Rhineland Palatinate, Saarland, Saxony, Saxony-Anhalt and Thuringia). The main claim procedure is still pending in the first instance. The preliminary application to stall the enforceability of
the prohibition order was finally rejected at the second instance with the decision of the higher administrative court of NRW of June 23, 2021.
On April 14, 2020, Bayton Limited, an indirect subsidiary of the Company, initiated proceedings in the Administrative Court Darmstadt,
Hessen against a prohibition order issued in February 2020 against Bayton Limiteds online sports betting operations in several German federal states (Baden-Wurttemberg, Bayern, Bremen, Mecklenburg-Western Pomerania, North-Rhine-Westphalia,
Rhineland Palatinate, Saarland, Saxony, Saxony-Anhalt, Schleswig-Holstein, Thuringia and Hessen; Hessen was added with the writ of May 2020). The main claim proceedings remain pending in the first instance.
On May 27, 2020, Bayton Limited submitted an objection to the Berlin State Office for Residents and Regulatory Affairs regarding
the prohibition order issued in April 2020 against Bayton Limiteds online sports betting operations in Berlin and Hamburg. No court proceedings have been initiated yet, and the objection submitted to the Berlin State Office for Residents
and Regulatory Affairs remains pending.
On September 27, 2021, Betway Limited submitted a claim at the Supreme Administrative Court in
Sweden in relation to a fine of initially SEK 5,000,000 issued against it by the Swedish Gambling Authority on the basis that it allegedly offered players recurring offers on registration. The fine was reduced to SEK 4,700,000 by the
Administrative Court in June 2020. Betway Limited appealed the judgment at the Administrative Court of Appeal and in June 2021, this Court dismissed its challenge to expunge or further reduce the fine, hence the current appeal at the Supreme
Administrative Court.
The Company offers its products and services to Austrian residents under its Malta license. The Company has faced
litigation from customers, related to its casino offering, and expects to continue to do so.
Some of these claims have been settled and
some are being and have been contested. Attention is drawn to the following cases:
On January 15, 2021, Bayton Limited issued a claim at
the Czech Supreme Administrative Court against the penalty against it of CZK 30 million for allegedly offering products to Czech residents without a license during a limited period in 2017. On October 21, 2019, Bayton Limited issued an
administrative action at the Municipal Court Prague. The Court dismissed the claim on December 18, 2020, hence the appeal at the Supreme Administrative Court.
On October 20, 2021, Manfred Boll issued a claim against Bayton Limited in the Darmstadt Regional Court, Germany for 194,395 on the
basis that gambling is illegal in Germany. The Defence was filed on February 16, 2022.
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