Responsible Gaming Hub

Curacao Lottery Issuance Center B.V. 01 September 2026

Responsible Gaming Policy v.1.0

1. Purpose and Commitment

Curacao Lottery Issuance Center B.V. is committed to providing a safe and responsible gaming environment. Gambling is intended to be a form of entertainment and not a source of income. The Company acknowledges that gambling may lead to financial, social, or psychological harm if not managed responsibly and therefore implements measures designed to prevent, detect, and mitigate problem gambling behaviors. Curacao Lottery Issuance Center B.V. ensures full alignment with applicable CGA Responsible Gaming Policy requirements and continuously improves its internal controls to safeguard customers.

2. Player Protection Principles Curacao Lottery Issuance Center B.V. operates in accordance with key responsible gaming principles which include the prevention of gambling-related harm, early identification of at- risk behavior, timely and proportionate intervention, protection of vulnerable persons including minors, and strict compliance with all regulatory obligations. The Company applies a proactive approach by combining automated monitoring systems with manual oversight to ensure effective protection of customers.

3. Responsible Gaming Tools Curacao Lottery Issuance Center B.V. provides customers with a range of tools to manage their gambling behavior. Customers are able to set deposit limits on a daily, weekly, or monthly basis, with any decrease taking effect immediately and any increase subject to a mandatory cooling-off period of at least 24 hours. Customers may also set loss limits to control the amount they are willing to lose within a specified timeframe and session limits to restrict the duration of their gaming activity. In addition, reality check notifications are implemented to inform customers about the time spent and activity on the platform, enabling them to make informed decisions about their continued participation.

4. Self-Exclusion and Cool-Off Periods Curacao Lottery Issuance Center B.V. offers both short-term cool-off periods and long-term self-exclusion options. Cool- off periods include 24 hours, 7 days, and 30 days and are applied immediately upon request without the possibility of reversal during the selected period. In line with CGA Responsible Gaming Policy requirements, self-exclusion options include a minimum period of six months as well as options for one year, three years, and permanent

Curacao Lottery Issuance Center B.V. 26 June 2026 exclusion. Upon activation of self- exclusion, the customer account is immediately blocked, preventing login, deposits, withdrawals, and gameplay, and all marketing communications are terminated without delay. Self-exclusion cannot be revoked before the expiry of the selected period under any circumstances. Reactivation is only possible upon expiration of the exclusion period and requires a formal request by the customer followed by an internal risk assessment. Requests for self-exclusion may be submitted via account settings or by direct communication with the Company through the designated support email contact@lottorbit.com.

5. Detection of Problem Gambling Curacao Lottery Issuance Center B.V. applies a risk-based monitoring framework to identify potential indicators of problem gambling. This includes the use of automated systems and manual reviews to detect behavioral patterns such as rapid increases in deposits, frequent or repeated transactions, extended gaming sessions without breaks, indications of financial distress, attempts to circumvent imposed limits, or the creation of multiple accounts. Identified cases are subject to further analysis and classification based on the level of risk.

6. Escalation Workflow When risk indicators are detected, Curacao Lottery Issuance Center B.V. follows a structured escalation process. The initial step involves the identification and verification of the trigger event, followed by classification of the customer into low, medium, or high risk categories. Depending on the level of risk, proportionate intervention measures are applied, which may include automated notifications, direct communication with the customer, imposition of mandatory limits, temporary suspension, or enforced self-exclusion. All actions are documented and retained for audit and compliance purposes, and follow-up monitoring is conducted to assess the effectiveness of the intervention.

7. Underage Gambling Prevention Curacao Lottery Issuance Center B.V. strictly prohibits access to its services by individuals under the age of 18. The Company implements robust identity verification procedures as part of its KYC process and reserves the right to request supporting documentation at any time. Accounts suspected of being operated by underage individuals are immediately suspended pending verification, and confirmed cases result in permanent account closure and restriction of access to services.

8. Staff Training and Responsibilities All relevant employees receive ongoing training in responsible gaming practices, including the identification of problem gambling indicators, appropriate handling of vulnerable customers, and application of escalation procedures. Staff are required to act in accordance with internal

Curacao Lottery Issuance Center B.V. 26 June 2026

policies and regulatory requirements at all times and are supported by clear operational guidelines.

9. External Support Curacao Lottery Issuance Center B.V. encourages customers to seek external assistance where necessary and provides access to independent support organizations and tools designed to limit gambling activity. These include services such as GamCare, Gambling Therapy, Betfilter, and Gamblock, which offer professional advice, counseling, and technical solutions for restricting access to gambling platforms.

10. AML and Cross-Policy Alignment Responsible Gaming measures are integrated with the Company’s Anti-Money Laundering framework to ensure a consistent approach to risk management. This includes the identification of financial behaviors that may indicate harm or misuse of services, monitoring of suspicious transactions, and appropriate reporting in accordance with AML Policy.

11. Monitoring and KPIs Curacao Lottery Issuance Center B.V. measures the effectiveness of its Responsible Gaming framework through defined key performance indicators, including the percentage of customers utilizing responsible gaming tools, the rate of failed age verification checks, the number of self-exclusion requests, response and intervention times within established service level agreements of 24 to 48 hours, and the volume of high-risk cases requiring escalation. These metrics are reviewed regularly to ensure continuous improvement.

12. Customer Responsibility and Liability While Curacao Lottery Issuance Center B.V. provides tools and safeguards to support responsible gaming, customers are expected to act in good faith and provide accurate information. Any attempt to bypass controls, including the provision of false information or the creation of multiple accounts, may result in account suspension or permanent closure. The Company does not accept liability for losses incurred where a customer deliberately circumvents implemented safeguards.

13. Review and Updates This policy is subject to periodic review to ensure ongoing compliance with CGA requirements and alignment with industry best practices. Updates are implemented as necessary to address regulatory changes and operational improvements.