Internal Control

The Board of Directors bears the ultimate responsibility for an effective system of internal control and risk management being in place.

Critical accounting issues and issues related to financial reporting are addressed by the Board. To ensure a well-functioning control environment, the Board has established a number of policies of importance to the corporate governance and the financial reporting. These include the rules of procedure of the Board, the CEO instructions and an instruction for financial reporting. The CEO has the primary responsibility to maintain the control environment on a day-to-day basis. The CEO continuously reports to the company’s Board.

The Group has established a Risk Management Committee, in which representatives of various relevant parts of the organisation meet quarterly to assess, discuss and mitigate potential risks. Furthermore, the Group has established routines and internal control systems for risk management, including but not limited to a yearly risk analysis for all business areas within the group, with the purpose of identify, assess and manage risks that threaten the group’s objectives and strategies. The risk analysis is divided in strategic, operational, compliance, legal and financial risks. With the purpose to ensure a relevant level of control, each business area must establish a number of control activities that prevent the most significant risks that have been identified in the analysis. A self-assessment of these control activities shall be conducted on a yearly basis and be reported to the Risk Management Committee, which compiles and reports the outcome to the Audit Committee and the Board. The group has also established a Mission Control Room (MCR) in Riga and Malta. The MCR monitors transactions, volumes and patterns in real time to help discovering attempted money laundering and fraud by customers, end users, third parties and dealers as well as illicit collusion between operators and end users.

As certain jurisdictions have laws that explicitly consider the offering of and participation in gaming services a criminal offence, the group carries out regular precautionary measures, including requiring in its agreements that operators comply with the laws and regulations applicable to gaming services. These provisions in the agreements constitute a form of legal protection and prevent certain end users from accessing the group’s products and services, as the group’s customers screen and limit the end users’ access to their online gaming platforms at the local level and in accordance with local laws and regulations. Also, the group has established technical systems and controls that prevent certain jurisdictions access to its Live Casino offering.

At the statutory Board meeting following the Annual General Meeting, a formal work plan is established for the Board and instructions for the work of the CEO are determined, in which responsibilities and powers are further defined.

The Board or one Board member together with Jens von Bahr may sign on behalf of the company. In addition, the company’s CFO and CLO together has authority to sign on behalf of the company. In accordance with the Companies Act, the CEO may sign alone on behalf of the company with regard to matters of ongoing administration.

The company has no separate review function (internal audit). The Board does not consider there to be special circumstances in operations or other conditions that would warrant such a function.