Casino, Slot Machine and Interactive Gambling Guidelines

Casino, Slot Machine & Interactive Gambling Guidelines FINANCIAL SERVICES AUTHORITY Bois De Rose Avenue P.O. Box 991 Victoria Mahé Seychelles Tel : +248 4380800 Fax : +248 4380888 Website : www.fsaseychelles.sc Email : enquiries@fsaseychelles.sc Version: 28th March, 2022

Page 2 of 23 Table of Contents

1. INTRODUCTION.....................................................................................................................................3
2. SCOPE OF THE FINANCIAL SERVICES AUTHORITY ACT, 2013................................................................3
3. SCOPE OF THE SEYCHELLES GAMBLING ACT, 2014...............................................................................3
4. OFFENCES..............................................................................................................................................4
5. APPLICATION REQUIREMENTS..............................................................................................................4
6. PROCESSING OF LICENCE APPLICATIONS..............................................................................................6
7. SERVICE STANDARDS ............................................................................................................................7
8. ASSESSMENT OF APPLICATION BY THE AUTHORITY.............................................................................8 Integrity.................................................................................................................................................8 Competence..........................................................................................................................................8 Risk Profile ............................................................................................................................................9 Financial Soundness..............................................................................................................................9 Systems and procedures.......................................................................................................................9
9. VISIT OF BUSINESS PREMISES .............................................................................................................10
10. GRANTING OF LICENCE.......................................................................................................................10
11. DISPLAY OF LICENCE ...........................................................................................................................12
12. CONDITION OF THE LICENCE ..............................................................................................................12
13. RENEWAL OF LICENCE ........................................................................................................................12
14. OFFENCES – LICNENCE FEES AND OTHER FEES...................................................................................13
15. CHANGE OF SHAREHOLDER, PARTNER AND DIRECTORS....................................................................13
16. DIRECTIONS, DIRECTIVES, GUIDELINES AND CODES ..........................................................................13
17. ROLE OF THE AUTHORITY ...................................................................................................................13
18. ENFORCEMENT ACTION......................................................................................................................14
19. BREAKDOWN IN ADMINISTRATIVE SYSTEMS .....................................................................................14
20. COMPLAINTS.......................................................................................................................................14
21. STANDARD OF ADVERTISING..............................................................................................................15 Appendix 1..........................................................................................................................................16 Appendix 2..........................................................................................................................................18 Appendix 3..........................................................................................................................................20 Appendix 4..........................................................................................................................................21

Page 3 of 23

1. INTRODUCTION These guidelines have been prepared by the Financial Services Authority (“the Authority”) to provide assistance in matters pertaining to the application and licensing of Casino and Slot Machine within the Seychelles Gambling Act, 2014 (“the Act”). These guidelines also provide a summary of the Act; thus it is not intended to be comprehensive nor replace or override any legislative provisions. Applicants and licensees are therefore advised to read these guidelines in conjunction with the Act. Enquiries on licensing related matters should be forwarded to the Authority: By Post: Director of Insurance, Gambling and Pension Supervision Section Financial Services Authority P.O. Box 991 Bois de Rose Avenue, Mahé Victoria Republic of Seychelles By e-mail: igp.supervision@fsaseychelles.sc Tel: +248 4 380 800 Tax: +248 4 380 888
2. SCOPE OF THE FINANCIAL SERVICES AUTHORITY ACT, 2013 2.1 Section 4(1)(d) & (i) of the Financial Services Authority Act, 2013 permits the Financial Services Authority to receive, review and determine licensee applications and to develop appropriate regulatory and supervisory mechanisms for the efficient and effective administration of the Authority. 2.2 In order to ensure the quality and consistency in the standard of the applications, these guidelines establish the criteria required to be approved by the Authority.
3. SCOPE OF THE SEYCHELLES GAMBLING ACT, 2014 As per the requirement of the Seychelles Gambling Act, 2014 it stipulates that no person shall carry out any gambling business without a licence until in accordance to the Act the person is authorise by the Authority to carry out any gambling business. The different kind of licence that may be granted by the Authority includes: (a) casino licence (b) slot machine licence, and (c) interactive gambling licence

Page 4 of 23 4. OFFENCES Any person who on any licensed premises conducts any gambling, other than such gambling which that person is authorised to conduct by the license granted for that premises, or keeps any gambling device or part of any gambling device which such person is not authorised in terms of the license to keep on such premises, or conducts any gambling otherwise than in accordance with the rules of such game commits an offence and shall on conviction be liable to imprisonment for a term not exceeding 3 years and fine not exceeding SCR 100,000 or both such imprisonment and fine. 5. APPLICATION REQUIREMENTS 5.1 The application for a licence must be made to the Authority pursuant to the Seychelles Gambling Act, 2014 which stipulate to have a regulatory licence in order to engage in gambling related activities. A licence to carry out gambling related activities within a specified gambling licence is obligatory under the Seychelles’ laws. 5.2 As per Section 6 of the Seychelles Gambling Act, 2014, an application submitting to the Authority for either a casino or slot machine licence must comprise of the following documents: (a) In the case where the applicant is an association of persons1 : (i) A certified copy of the Certificate of Incorporation (ii) Memorandum and Articles of Association (iii) Business Licence (iv) Personal Questionnaire forms completed by all directors and beneficial owners of the company (b) In the case where the applicant is a body corporate: (i) A certified copy of the Certificate of Incorporation (ii) Memorandum and Articles of Association (iii) Business Licence (iv) Personal Questionnaire forms completed by all directors and beneficial owners of the company (c) In the case where the applicant is a partnership: (i) a copy of the Partnership Registration (ii) Business Licence (iii) Personal Questionnaire forms completed by all partners and beneficial owners of the partnership.

1 Section 3(1) of the Registration of Association Act 1959 states: “A registered association shall be a body corporate having perpetual succession and a common seal, and power in its corporate name to acquire, hold, and dispose of property, movable or immovable, and generally to do all such acts and things as bodies corporate may do and perform. It shall sue and be sued in its corporate name and service of process on the secretary of the association shall be deemed to be service on the association.”

Page 5 of 23 (d) In the case where the applicant is a sole trader: (i) a copy of the Business Licence (ii) the completed Personal Questionnaire form. 5.3 In addition to the above, the application must comprise of the following documents: (a) The relevant application fee: (i) SCR 25,000 for a casino licence application (ii) SCR 15,000 for a slot machine licence application (b) Questionnaire form for Shareholders and Beneficial Owners completed by each shareholder and beneficial owner of the applicant (refer to Appendix 1 for due diligence documents required) (c) Proof of source of funds or wealth (d) Certified true copies of the constitutional documents of the applicant (refer to Appendix 2) (e) Proof of Physical Place of Office (Title Deed of Premises or Lease Agreement for premises or Sub Leasing Agreement, Sanction Approval (if applicable) and consent letter from the owner of the premises stipulating that the lessee can sublease) (f) Audited accounts for the past 2 years of each shareholder which is a body corporate (g) In the case of an applicant not incorporated in Seychelles, the agent for service in Seychelles is licensed under the International Corporate Service Providers Act, 2003 or the Financial Institutions Act, 2004 or has been approved in writing by the Authority. (h) A detailed business plan2 (i) Certified true copies of the Auditor’s certificate of membership and certificate of Good Standing as per section 2 of the Act (j) Internal Procedures Manual (k) Compliance Manual (l) Anti-Money Laundering Manual (m) Complaints Handling Manual (n) Responsible Gambling Manual (o) Business Continuity Plan (p) Proposed equipment supplier agreement or quotation - in the case of Casino, it will include but not limited to the Centralised Monitoring System (CMS), Casino tables, shufflers, roulette wheels, chips, playing cards, slot machines, other gambling machines)

2 The Business Plan should include: (a) Business objectives: Previous experiences fund administration and the reason for identifying these objectives as activities to be pursued in Seychelles. (b) Services, business and infrastructural details (Office Space, Office Equipments, Office Furniture, Office Facilities (Telephone, Facsimile, IT Infrastructure), Vehicles) (c) The nature of work being targeted including marketing plans (marketing potentials and strategies) (d) Competency of the directors and other officers who will administer the business (needs to give guidelines regarding the compliance function, who is the proposed compliance officer, is it to be the director, this must be detailed in the business plan) Human Resources: Organizational Chart (including description of key management roles), Job descriptions of all staffs, Training Requirements.

Page 6 of 23 (q) Proposed equipment supplier agreement or quotation - in the case of Slot Machines (Slot machines, other gambling machines, games per machine) (r) List of Casino and/or Slot Machine games being proposed and certification where applicable. Certifications include but not limited to: (i) Full test report for each slot machine games software (ii) Full test report for each operating system/Base software (iii) Full test report for each slot machine hardware (s) The relevant application fee (refer to paragraph 6 - PROCESSING OF LICENCE APPLICATIONS) payable by: (i) banker’s cheque (ii) swift transfer 5.4 The Authority will only process an application if the application fee (refer to paragraph 6 - PROCESSING OF LICENCE APPLICATIONS) has been submitted. 5.5 During the processing of the application, the Authority may request for additional information or supporting documents for the purpose of determining the application. 5.6 A person who supplies, to the Authority, information in connection with an application which he knows or reasonably knows is false or misleading, is guilty of an offence and liable to conviction to a fine not exceeding SCR 100,000. In the instance where an offence under this act is committed by a corporate, and any of its directors or other officers, knowingly authorised, permitted or acquiesced in the commission of the offence, the director or other officer shall also be guilty of the offence. 5.7 All applications seeking the approval of the Authority must be addressed and either hand delivered or mailed to: The Chief Executive Officer Financial Services Authority P.O. Box 991 Bois De Rose Avenue, Mahé Victoria Republic of Seychelles 6. PROCESSING OF LICENCE APPLICATIONS The Authority will follow the following steps when assessing an application: Step 1: Acknowledge receipt of the application. Step 2: Carry out an initial review of the application to assess whether the application is complete according to the requirements detailed herein (refer to the Application Checklist Appendix 3).

Page 7 of 23 Step 3: Begin to process the application if the application is deemed to be complete; or return the application to the applicant if the application is deemed to be incomplete, highlighting the area(s) of deficiencies/ discrepancies. Note that the Authority may provide general and brief guidance on the area(s) of deficiencies, but it is the responsibility of the applicant to engage suitable professionals or service providers to ensure the completeness of the application. Step 4: Request for additional information or supporting documents for consideration of the application from the applicant, if necessary. Step 5: Upon receipt of the licence application, the Authority for two consecutive days shall publish at the expense of the applicant a notice containing such particulars as may be determined by the Authority in a daily newspaper in the area where the gambling is to take place to invite objections and suggestions from the public on the application. In accordance with Section 7 of the Seychelles Gambling Act, 2014, the person objecting will have thirty days from the date of publication to submit the objection. Step 6: Inform the applicant on whether the application has been approved for licensing or not. 7. SERVICE STANDARDS 7.1 The Act does not provide a time limit within which the Authority must reach a decision in respect of an application. In practice, the Authority always seeks to deal as promptly as possible with each application. The timeframe required to complete initial enquiries may vary, depending on the nature of the issues and the promptness in obtaining any additional information from the applicant. Generally, the Authority would not expect an application to remain outstanding for a period of more than 3 months. 7.2 It is important to note that this service standard will only be achievable if all the requisite information/documents are provided at the time the application is lodged. The Authority is not responsible for delays arising from the submission of incomplete applications. The following is to be further noted: (a) The Authority will only process complete applications. Applications that are deemed to be incomplete after three (3) months upon its submission to the Authority, will be returned to the applicant. Applicants will have a period of 6 months for resubmission of the application. (b) Applications not submitted within the 6-months cut-off period will be considered as void and a new application would have to be lodged along with payment of the required application fee, should the applicant remain interested in proceeding further with the application. 7.3 This service standard is not exhaustive or binding on the Authority. The licensing regime requires the Authority to exercise discretion. How the Authority does this will depend on the applicant’s particular circumstances.

Page 8 of 23 8. ASSESSMENT OF APPLICATION BY THE AUTHORITY 8.1 Upon request of the application, the Authority will assess the application taking into consideration the following aspects: Integrity 8.2 The Authority will have to ensure that there is no adverse evidence of past misconduct and conviction. Such will not be limited to current or on-going investigation vis-à-vis gross misconduct action or allegation, in relation to the standards of business behaviour as well as non-compliance with the law. The evidence does not have to be directly gambling related investments but rather to any business carried on by the applicant within the Seychelles territory and other foreign jurisdiction. Moreover, the same scrutiny process will be applicable and be conducted on the shareholders, irrespective of the shareholding value. Examples of the kind of evidence that may involve integrity issues include the following: (a) criminal offences committed by the applicant, particularly offences involving violence, fraud or dishonesty, whether or not they lead to prosecution or a conviction (b) any breach of the Fair Trading Commission Act, such as rules relating to advertising, agreements, pre- or post-contract information or early settlement (c) any breach of the Financial Consumer Protection laws, including that relating to misleading advertisements, price indications and product descriptions, harassment of debtors and unfair contract terms (d) insolvency, bankruptcy or disqualification as a director (e) providing false or misleading information to the Authority (f) any legitimate complaints about the business whether or not the activity in question is regulated under by the Authority, including evidence of persistent breaches of contract with consumers (g) adverse information from other regulators, professional bodies, trade bodies, consumer organisations or other businesses, including the Fair Trading Commission, Seychelles Revenue Commission and Seychelles Chamber of Commerce and Industry (h) unauthorised use of the Authority’s name or any misrepresentation of the business status to suggest that the business is approved by the Authority (i) evidence of business practices that appear to the Authority to be deceitful or oppressive, or otherwise unfair or improper. Competence 8.3 The Authority will also take into consideration the competence of the applicant to engage in the activities covered by the licence. All licensees are expected to be competent to carry out the

Page 9 of 23 regulated activities for which they hold a licence. The Authority will take into account the skills, knowledge and experience of the Directors and managerial staff of the applicant to carry out the activities covered by the licence to a reasonable standard. The Authority will also consider the practices and procedures that the applicant is planning to operate in connection with the licensable business activities and assess whether the applicant’s ability to handle consumer complaints through its complaints manual is adequate and suitable for the nature of the activity to be undertaking. Risk Profile 8.4 In assessing the application, the Authority will verify whether the policies and practices that the applicant intends to follow are not deceitful, oppressive, unfair or improper. Licensees should always take full account of the interests of consumers in doing so. The authority will asselss from the submitted Personal Questionnaire Form and Questionnaire for Shareholder and Beneficial Ownership whether the associations of persons/body corporate/partnerships or sole trader is credit worthy and assess its ability to repay its debt (if any), prior to venturing into either a casino or slot machine license. The checks will be proportionate, taking into account the nature of the activity, relationship the activity will have with the players and the degree of risk for the players. 8.5 The Authority will also take into account any relevant positive factors such as: (a) A record of fair dealing over a significant period (e.g. no evidence of serious consumer complaints) (b) Proof that no enforcement action has been taken against the applicant’s current or previous business activities. Financial Soundness 8.6 The Authority will assess the financial resources and viability of the business. That is, whether such individuals or business will be in a position to provide relevant documents stating the steps that are to be taken to ensure that the business is credit competent. Systems and procedures 8.7 A licensee must organize and control its internal affairs in a reasonable manner and have in place well-documented control systems and procedures, commensurate with the level, nature and scope of its business, to enable it to comply with the relevant laws. 8.8 A licensee must be able to demonstrate its compliance to the Authority by being able to produce and maintain relevant records. All records and documents must be easily retrievable and in such form at which the licensee thinks its best fit. However, where the records and documents are kept in magnetic, electronic or any other data storage form, the licensee must be able to produce legible evidence of its contents. For the purpose of clarity, records shall mean but not limited to: (a) All records as specified in the checklist in Appendix 3

Page 10 of 23 (b) Agreements between shareholders, directors, employees and other clients (c) Customer personal details – KYC manual (d) Bank details (e) Record of periodical payments 8.9 A licensee must ensure that members of its managerial staff and other employees, involved in performance of the gambling related activities should carry out their duties in a diligent and proper manner, with professionalism and confidentially. 9. VISIT OF BUSINESS PREMISES A visit to the business premises of the applicant will be scheduled and undertaken by the Authority during the application process. At least one director or managerial staff must be present at the business premises during the visit. For the purpose of the visit, the Authority may request other relevant authorities/agencies to visit the sites as well. This may include but not limited to the Ministry of Health (Public Health Authority), Ministry of Land Use and Housing, Fire and Rescue Services Agency and the Police Force. Note: The licensee must notify the Authority of its intention to change business premises or to acquire additional business premises at least 5 working days prior to the event. 10. GRANTING OF LICENCE 10.1 Where the Authority is satisfied with the application, a letter of approval would be issued which will advise the applicant to pay the required license fee as per the table below: 1 2 (a) Interactive Gambling Licence SCR 300,000 (b) Casino Licence Base fee Fee per table Fee per slot machine SCR 1,000,000 SCR 3,500 SCR 2,500

Page 11 of 23 (c) Slot machine licence Fee per slot machine Base fee 0-10 slot machines 11-50 slot machines 51-100 slot machines 101-200 slot machines 200 slot machines or more SCR 2,500 SCR 125,000 SCR 250,000 SCR 375,000 SCR 500,000 SCR 1,000,000 10.2 Once the payment has been made the licence certificate will be issued for one (1) year and may be renewed. As such the license fee payable on renewal of a licence under section 30 of the SGA shall be the same amount as depicted per the table above. 10.3 If the applicant fails to make payment for the annual licence renewal fee within 10 working days (or any other timeframe as may be approved in writing by the Authority) from the date of issue of the letter of approval without a valid reason, the Authority may rescind the approval and will issue a letter with the reason for such determination. 10.4 If a licensee makes any amendments to its licence condition such as changes its name or game, the licensee must formally notify the Authority prior to effecting the change and the Authority shall process the documents submitted for the change and inform the licensee of the Authority’s determination on the matter. The fee shall be as follow: 1 2 Transfer of licence to another person subject to joint application under section 15(4)(a) and (7) 100% of the respective licence application fee Remove the gambling and other activities authorised under a licence, from the licensed premises to any other premises, whether permanently or temporarily under section 15(4)(c) and (7) 20% of the respective licence application fee Request to have a licence or any conditions to the licence amended in anyway whatsoever under section 15(4)(c) and (7) 30% of the respective licence application fee Note: The Authority has discretion in granting or refusing a licence. The Authority may in dealing with an application take into consideration matters other than those mentioned above including, but not limited to, ensuring that all other parties to an application (e.g. legal advisors and company secretaries) are of satisfactory repute. In the event that the application is successful and the licence is issued, the Authority may publish on its website or other publications, the name of the licensee and contact details.

Page 12 of 23 11. DISPLAY OF LICENCE The licence certificate must at all times prominently be on displayed on the licensed premises and should be visible to view. The holder of a licence or holder of a certificate of approval or a person acting on behalf any such holder or a holder of a certificate of approval shall, on demand of relevant authorities produce the licence certificate. 12. CONDITION OF THE LICENCE 12.1 Activities permitted under the approved gambling licence are only those that are contained within the licence and are limited to only such gambling related activities as stated. The licensed gambling establishment must comply with the conditions contained in its licence. 12.2 The Authority may impose such conditions and restrictions to the scope of business as it deems fit. 12.3 The Authority may, by notice in writing, add, delete, vary or determine any condition, restriction or limitation in the licence and the licence shall be deemed to have been issued with such addition, deletion, variation or determination. 13. RENEWAL OF LICENCE 13.1 The licence granted under the Act is valid for a period of one (1) year and as per Section 30 (1) and Section 30 (2) of the SGA, 2014. The licensee shall submit a formal letter to the Chief Executive Officer of the Authority requesting for approval, if there is the intention to renew the licence. 13.2 Further to such, the licensee will need to submit the Casino/Slot Machine Licence Renewal Application Form along with the necessary declaration to indicate whether or not there have been any changes to the information provided to the Authority in relation to the submitted licence application. In the event, if there are any changes and in accordance to the above mentioned form checklist, the licensee should submit a respective supporting documents if applicable. 13.3 The formal notification for renewal of the licensee should be done not later than thirty (30) days prior to the date on which the current licence expires and should be submitted within the Authority’s business working hour. In the event that the licensee fails to submit the letter of intention to renew the licence and the applicable renewal forms/documents promptly (i.e. until the last day that the licence is valid) the following date upon the expiration of the licence the gambling establishment should remain close until the Authority completes its analysis and provides a determination. If the licensee fails to confirm to the Authority that it wishes to renew its licence or fails to pay the annual fee on or before the date of expiry of the licence shall that no person shall carry out any gambling business without a licence granted in accordance with this Act. Moreover, Section 43(1) (b) provides that no person shall without a licence. Subsequently, Section 43(4) includes that any that any person who contravenes the provisions

Page 13 of 23 of this section commits an offence and the person shall be liable on conviction to imprisonment for a term not exceeding 5 years and a fine not exceeding SCR 500,000 or both. 14. OFFENCES – LICNENCE FEES AND OTHER FEES In the instance that the licence fees and other fees as may be prescribed is not paid as and when it is due, the holder of the licence shall in addition to such fees, pay a surcharge of 10% of the fees for each week or part thereof during which the fee remains unpaid. The amount of such surcharge shall not exceed twice the amount of the fee applicable to the licence concerned. 15. CHANGE OF SHAREHOLDER, PARTNER AND DIRECTORS 15.1 A licensee must submit to the Authority a written notice of any proposed change in its shareholding (in the case of a company), partner (in case of a partnership) and directors at least 14 days prior to the proposed change. Subsequent, to the amendments, the notice should be accompanied with the certified copy of the Board resolution. 15.2 The notice referred to above must be accompanied by relevant due diligence documents. 16. DIRECTIONS, DIRECTIVES, GUIDELINES AND CODES 16.1 The Authority may issue directions, directives, guidelines or codes for the purpose of the performance of its functions in accordance with Section 33 of the Financial Services Authority Act, 2013. All directions, guidelines or codes issued by the Authority are binding on licensees and hence have the force of law. 16.2 Any person who fails to comply with the above requirements commits an offence and will be subjected to enforcement actions under the relevant laws. Furthermore, the Authority may subsequently suspend or revoke a licence should it deemed appropriate. 16.3 In addition, the Authority may, for the purpose of the performance of its functions under the FSA Act, request any licensee, its director or partners or member of its managerial staff to furnish such information or documents as the Authority may reasonably require. 17. ROLE OF THE AUTHORITY 17.1 The Authority monitors and supervises the provision of services by licensees and where necessary make enquiries and inspections to ensure that the provisions of the Act are being complied with. 17.2 For the purpose of the above, the Authority may during business hours, after giving reasonable notice or not, access the business premise of a licensee for the purpose of inspecting procedures, systems, controls, books, records and other relevant documents of the licensee to

Page 14 of 23 ensure compliance with the Act. Nonetheless, the Authority may conduct un-announced visit/spot checks and may access the business premise after business hours. 17.3 A person who in any way impedes, prevents or obstructs the Authority or any of its employees or authorised agent in the conduct of an inspection commits an offence and is liable on conviction to a fine not exceeding SR100,000. 17.4 The Financial Services Authority Act, 2013 prohibits the Authority or any employee or agent of the Authority to disclose any information or document acquired in the performance of the duties under the Act in respect of any licensee or the affairs of any licensee. 18. ENFORCEMENT ACTION 18.1 The Authority has wide ranging powers to ensure that a licensee meets its obligation under the Act. In addition to penalties and fines which may be applied under various sections of the Act for non-compliance, the Authority may suspend or revoke a licence in accordance to the Financial Services Authority Act, 2013. 18.2 The Authority may suspend a licence for up to thirty (30) days, unless a longer period is ordered by the Court upon application to the Authority. Prior to suspension or revocation of a licence, the Authority may require the licensee to take such steps as the Authority deems necessary to comply with the law, within a specified timeframe. 18.3 In the event that the Authority revokes a licence, the licensee must surrender the licence to the Authority within three (3) working days from the effective date of revocation of the licence. 19. BREAKDOWN IN ADMINISTRATIVE SYSTEMS A licensee must notify the Authority of any serious or prolonged breakdown in its administrative or control systems as soon as it becomes aware that such a breakdown could result in an inability to maintain proper records or is likely to result in failure to comply with any provisions of the Act. 20. COMPLAINTS 20.1 Complaints relating to gambling activitiesshould be directed to the Authority who shall evaluate the complaint in accordance with the Complaints Handling Procedure. 20.2 Complaints should be made using the Compliant Handling form which can be viewed on the Authority’s website ( https://fsaseychelles.sc/complaint-handling ). For further guidance, the Complaint Handling Guidelines provides details as to the manner in which complaints is to be filled and the manner in which the Authority carries out its functions vis a vis complaints received. 20.3 Unless the Authority is satisfied that a complaint is trivial, frivolous or vexatious, not made in good faith or a complainant does not have sufficient interest in the matter, the Authority will

Page 15 of 23 proceed to investigate the complaint and will advise the complainant in writing about the steps or actions it proposes to take to remedy the matters of the complaint. 20.4 The form can be submitted by any of the following means: (a) By e-mail: complaints@fsaseychelles.sc (b) By post: Director of Insurance, Gambling and Pension Supervision Section Financial Services Authority P.O. Box 991 Bois de Rose Avenue, Mahé Victoria Republic of Seychelles (c) Hand-delivered directly to the Authority 20.5 The Authority will acknowledge receipt of the complaint within two working days. 21. STANDARD OF ADVERTISING 21.1 As per Section 23 (1) of the Seychelles Gambling Act, 2014 it is lawful to advertise any gambling as stipulated by the Act and while advertising the gambling related activities, a licensee must ensure that any advertisement that is published or causes to be published does not damage the good image and reputation of the Republic of Seychelles. Advertisements shall not be deceptive and misleading to the public. 21.2 Moreover, in accordance with section 23 (2) of the Seychelles Gambling Act, 2014 the licensee or any person acting on his/her behalf shall not advertise gambling at or in close vicinity of any school or other institution or place where persons under the age of 18 years are the dominant frequenters e.g. school

Page 16 of 23 Appendix 1

1. Application form
2. Constitutional documents; (a) Memorandum of Association (b) Articles of Association (c) Certificate of Incorporation
3. Registers; (a) Register of Directors (b) Register of Members (c) Registers of Beneficial Owners
4. Personal Questionnaire form for directors and shareholders holding a minimum of 15% shares (must also include any document required by the personal questionnaire form).
5. In relation to the property where the gambling activity is to take place; (a) Location for operations (b) Lease agreement/proof of ownership of property (c) Sanction to own property in Seychelles (for non-Seychellois) (d) Occupancy certificate (e) Approval from planning to conduct the gambling activities. (f) Approval from Ministry of Health (g) Approval from Seychelles Fire and Rescue Services (h) Change of use of property (if required) (i) Floor plan/layout (an updated floor plan may be required once the applicant has obtained slot machines and casino tables)
6. Manuals and Procedures; (a) AML/CFT manual (b) Internal Control System manual (c) Business Continuation Plan (What to do in the event that the business is interrupted (etc. pandemic, natural disaster, what kind of business interruption that may happen, data backups, this is important for player protection and AML/CFT) (d) Responsible Gambling Plan (e) Player Protection Plan (what system the establishment have in place to ensure that wins are paid to players) (f) Business plan (g) Company description (h) Business objective (i) Business strategy (j) Mission and vision (k) Marketing strategy (l) Market analysis (m) Risk analysis (n) Human resource (o) Organisation structure

Page 17 of 23 (p) Shareholding structure (q) Job descriptions (r) Training plan (s) Budget (t) Financial forecast for three years. (u) Statement of financial position (v) Income statement (w) Forecasted cash flow for upcoming three years (x) Internal Control System 4. Source of fund 5. Bank Statement for at least the past three month for every bank of the company holds an account with 6. Bank reference 7. Audited financial statement (for existing companies) 8. Tax clearance certificate (for existing companies) 9. Number of casino tables and/or slot machines to be used for operations. (Licence certificate may be required to purchase gambling equipment.) 10. Electronic Monitoring System (EMS); (a) Proof of purchase (b) Test reports 11. Details of manufacturer and suppliers of the slot machines and casino games 12. Specification of slot machines must include; (a) Test reports (b) Game names (c) Vendor/manufacturer (d) Slot machine serial number (e) Cabinet model/model number (f) Game software version (g) Operating system version (h) Denomination (i) Minimum and maximum bets; and (j) Return to Player(RTP)% 13. Specification of casino tables must include; (a) Table vendor/manufacturer; and (b) Casino game or (games if the table is reversible).

Page 18 of 23 Appendix 2 Due Diligence Requirements

1. The completed Personal Questionnaire 3 Forms by all Beneficial Owners & Directors in connection with the application should be accompanied by: (a) 1 certified true copy of passport(s) (b) 1 recent passport sized photograph signed at the back by certifier (c) 1 certified proof of residential address that is not older than three months e.g. utility bill (water and/or electricity) and/or bank statement and/or tenancy agreement (d) 1 original bank reference from each bank with which you are affiliated and/or a report from Credit Rating Agency from Country of Residence (if available) (e) Certified copies of stated higher academic qualifications (f) Certified copies of stated professional qualifications (g) Certified copies of stated membership to professional bodies (h) Detailed job description of your proposed role or position (i) Latest Employment references (if applicable) (j) A list of directorships, partnerships, other business interests or affiliations (if applicable) (k) Original Police Character Reference/certificate not older than three (3) months from the Country in which the applicant resides/origin or its equivalent (l) Tax Clearance Certificate from the Country in which the applicant resides/origin or its equivalent (m) Politically Exposed Person Self-Declaration Form Non-executive staff (i.e. managers, senior officer and other staff) working directly on the casino floor should complete the ‘Certificate of Approval’ application.
2. The completed Questionnaire Form for Shareholders and Beneficial Owners 4 by all shareholders and beneficial owners who do not have a management position in the company should be accompanied by: (n) 1 certified true copy of passport(s) (o) 1 recent sized passport photograph signed at the back by certifier (p) Proof of Appointment as Nominee E.g. Declaration of Trust, Deed of Indemnity or its equivalent (q) 1 certified proof of residential address that is not older than three months e.g. utility bill (water and/or electricity) and/or bank statement and/or tenancy agreement (r) 1 original bank reference from each bank with which you are affiliated and/or a report from Credit Rating Agency from Country of Residence (if available) (s) A list of directorships, partnerships, other business interests or affiliations (if applicable) (t) Original Police Character Reference/certificate not older than three (3) months from the Country in which the applicant resides/origin or its equivalent

3 The PQ should be filled out by all individuals holding a management and executive role within the entity. If the applicant is also the Shareholder or Beneficial Owner, both forms should be filled out. 4 This form is deemed as a Simplified PQ to be filled by non-executive persons who are not involved in the management of the entity

Page 19 of 23 (u) Tax Clearance Certificate from the Country in which the applicant resides/origin or its equivalent (v) Politically Exposed Person Self-Declaration Form

Page 20 of 23 Appendix 3 List of Constitutional documents Certified true copies of the following documents:  Certificate of Incorporation  Memorandum and Articles of Association  Partnership Agreement (if applicable)  Notice of situation of Registered Office or any change thereof  Particulars of Directors and Secretaries  Audited/Forecasted financial statements for the past 3 years

Page 21 of 23 Appendix 4 Checklist TheApplicationFee ☐ Part 1: CONSTITUTIONALDOCUMENTS FOR APPLICANT COMPANY, PARENT COMPANYAND SUBSIDIARY COMPANY Certified copy of Certificate ofIncorporation ☐ Certified copy of MemorandumofAssociation ☐ Certified copy of Articles of Association ☐ Shareholding Structure ☐ Part 2 – BUSINESS PLAN A. BusinessObjectives ☐ B. Services and Infrastructure InvestmentDetails Proposedgamblingpremiseslease/purchaseagreement ☐ Details of HeadOffice and other premisesif differentfrom above (including office space, equipment and fittings) ☐ Proposed equipmentsupplier agreement or quotation and licence certificate andsample – In the case of Casino (Casino tables, shufflers, roulettewheels, chips, playing cards,slot machines, other gambling machines) ☐ Proposedequipmentsupplier’ agreement or quotation, and licence certificate– In the case of Slot Machines (Slot machines, other gamblingmachines, games permachine) ☐ Methodofsecurityandsurveillance equipment provider and agreement. A layout ofthe security and surveillance system equipment with a full description of their functions and location. ☐ List of Casinoand/or SlotMachinegames being proposed and certificationwhere applicable. Certificationsinclude but notlimited to:  Fulltest report for each slot machine gamessoftware;  Fulltestreport for each operating system/Base software;  Fulltest report for each slot machine hardware;  Letter of certificate for each test report issued by an independentRegulatoryAuthority (where applicable) ☐ C. Electronic Monitoring System (EMS)

Page 22 of 23 Certification of EMS ☐ Test Report ☐ Manufacturer and supplier details (if different) ☐ Applicant and Supplier Agreement (if applicable) ☐ EMS manual system (if available) ☐ D. Marketing Overview of Marketing strategy and adherence to regulatory standards (premises, media, etc.) ☐ Details of acquisition and promotional offers ☐ E. Human Resources Organizational Chart ☐ Job Descriptions ☐ Training Requirements ☐ F. Financial Forecast (three year forecast) – which includes information on General Overheads ☐ Salaries and Wages ☐ Administrative Costs, Training Costs ☐ Marketing, Insurance ☐ Consultancy Fees, Finance Charges ☐ A payments schematic diagram showing the flow of cash and other funds ☐ PART 3 – FINANCIAL ACCOUNTS Audited Financial Statements of existing company for the past three years or since incorporation (if applicable) ☐ The most recent set of annual accounts of the parent company, subsidiary and any associated company (if applicable) ☐ PART 4 – DUE DILIGENCE / KYC PROCEDURES – Money Laundering, Terrorist Financing and Proceeds of Crime Minimum Standards to be at least in line with the revised 40 recommendations of the FATF on Money Laundering. ☐ PART 5 – INTERNAL CONTROL SYSTEM Internal Control System (ICS) indicating how the applicant proposes to manage its operations including its procedures and processes. ☐ PART 6 – PERSONAL QUESTIONNAIRE

Page 23 of 23 Personal Questionnaire completed for all directors, managerial staff, designated officials, all other key functions and employees, individual shareholders holding 15% or more and beneficial owners. ☐ PART 7 – ADDITIONAL DOCUMENTS 1 original bank statement from each bank for all accounts the applicant currently holds ☐ 1 original bank reference from each bank of the applicant ☐ Certified copy of the Resolution of Directors approving the signatory to the bank account ☐ Certification from relevant authorities for premises as follows:  Planning approval for development/construction of a new premise  Planning approval for change of use for exiting premise  Occupancy certificate  Agreement between the Managing Company/Operator and the applicant/licencee5 ☐

5 The Managing Company/Operator would be the person who has the authority to lease the premises. For example, if a space is being rented from Company X; Company X would be the lessor as they have the autonomy and right to lease a property. The applicant/licensee would be the lessee. The lease will have to be in the name of the lessee; with the lease countersigned by the individual who has the authority to do so.