Internal Complaints Handling and Escalation Policy

This Internal Complaints Handling and Escalation Policy (“Policy”) outlines the procedures established by AfriSlots (“we”, “us”, “operator”) for receiving, assessing, managing, and resolving player complaints in a fair, timely, and transparent manner. The purpose of this Policy is to ensure that all concerns raised by players are handled consistently and respectfully and that appropriate mechanisms exist to address both routine service issues and complex regulatory matters.

We are committed to maintaining a high standard of customer care and regulatory compliance. Our complaints-handling framework is designed to comply with the requirements set out by the Tobique Gaming Commission and to align with applicable consumer protection laws and principles of natural justice.

This Policy applies to complaints related to:

• Account issues (e.g., verification delays, access restrictions);
• Financial matters (e.g., withdrawals, payment errors, bonus disputes);
• Game outcomes or technical malfunctions;
• Alleged breaches of terms and conditions;
• Conduct of customer service or support representatives;
• Allegations of unfair treatment, fraud, or regulatory non-compliance.

The procedures described herein are applicable to all registered players and users of our platform. Complaints submitted by third parties, agents, or on behalf of anonymous individuals may not be processed unless supported by written authorisation or legal requirements.

This Policy sets out:

• How players may file a complaint and what information is required;
• Our internal process for investigating and responding to complaints;
• Expected timeframes for resolution;
• Escalation procedures, including referral to external regulatory bodies where applicable.

We treat all complaints as opportunities to improve our service, identify systemic issues, and maintain accountability in accordance with our licensing obligations.

For the purposes of this Policy, the following definitions apply:

“Complaint” means any written or recorded expression of dissatisfaction made by a player regarding our products, services, platform, decisions, staff conduct, or handling of account-related matters, including disputes concerning game outcomes, payments, or bonus entitlements.

“Player” refers to any individual who holds a registered account on our platform and uses our gaming services, subject to the applicable Terms and Conditions.

“Escalation” refers to the formal process by which a complaint, if unresolved at the initial level of review, is transferred to a higher level of authority within our organization for further assessment and decision.

“Resolution” means the final decision or action taken by the operator in response to a complaint, whether it results in corrective action, a denial of the claim, or another form of closure.

“Regulatory Authority” refers to the Tobique Gaming Commission or any other competent licensing body responsible for overseeing compliance, licensing, and dispute resolution in connection with our operations.

“Alternative Dispute Resolution” or “ADR” means any independent third-party body designated by the regulatory authority to mediate unresolved disputes between players and licensed operators.

Players who wish to raise a complaint are encouraged to do so through the official communication channels designated for handling such matters. All complaints must be submitted in a clear and structured manner, allowing us to record, investigate, and resolve them efficiently and fairly.

3.1 Submission Channels

Complaints may be submitted through the communication methods provided on our platform, including secure account interfaces or by contacting our customer support team via the methods specified in the “Contact” section of our website. All complaints must be submitted in writing and must originate from the account holder.

Informal messages or feedback provided via third-party platforms (e.g., social media) will not be processed as formal complaints unless submitted through the proper channels.

You may also submit a complaint by email to complaints@afrislots.com.

3.2 Information Required

To ensure an effective review, complaints should include the following:

• The player's full name and registered account username;
• A clear description of the issue being raised, including the date and nature of the incident;
• Any transaction references, game IDs, or other identifiers relevant to the complaint;
• Supporting documentation or screenshots, where applicable;
• A statement of the desired outcome or resolution, if known.

If necessary, we may contact the player to request additional information or clarification to assist in the investigation.

3.3 Timeframe for Submission

Players are encouraged to submit complaints promptly following the occurrence of the issue. Unless otherwise permitted by applicable regulations, complaints should generally be submitted within six (6) months of the relevant event. Delays in reporting may impact our ability to investigate and resolve the matter effectively.

We follow a structured internal procedure to ensure that all complaints are treated fairly, confidentially, and in line with applicable licensing requirements.

4.1 Acknowledgment

Upon receiving a properly submitted complaint, we will issue an acknowledgement to the player confirming receipt. This will generally occur within seventy-two (72) hours unless otherwise required by applicable regulations. If additional details are needed to initiate a review, we will request them at this stage.

4.2 Initial Assessment

Complaints are initially reviewed by trained support personnel or designated complaint handlers. Where the matter is straightforward and can be resolved immediately, a response may be provided without further escalation.

If the matter is complex or relates to regulatory, technical, or financial aspects of the platform, it will be formally escalated for internal investigation.

4.3 Internal Investigation

A designated compliance representative or member of our dispute resolution team will conduct a thorough review of the complaint. This process may include:

• Examining transaction and game records, logs, or system data;
• Consulting internal departments (e.g., payments, security, or responsible gambling teams);
• Reviewing any correspondence or support interactions related to the complaint;
• Assessing whether the issue relates to regulatory or contractual obligations.

All investigations are conducted objectively, without bias, and in accordance with internal guidelines and applicable law.

4.4 Formal Response

We aim to issue a formal written response to the complaint within fourteen (14) calendar days of receiving all necessary information. The response will include:

• A summary of the issue as understood;
• The outcome of the investigation;
• Any corrective measures or explanations;
• The player's right to escalate the matter if dissatisfied.

Where more time is required to complete the investigation, we will inform the player of the expected timeline and the reason for the delay.

We are committed to resolving complaints at the first level of review whenever possible. However, if a player is dissatisfied with the outcome of our initial response, they have the right to request an internal escalation.

5.1 Requesting Escalation

To initiate escalation, the player must submit a written request outlining:

• The reason they disagree with the outcome;
• Any new or additional information not previously considered;
• Their preferred resolution, if applicable.

This request should be submitted through the same channel used for the original complaint or through any escalation mechanism provided within the platform.

5.2 Internal Re-Evaluation

Upon receiving a valid escalation request, the complaint will be reviewed by a senior staff member, such as a compliance officer or departmental head who was not involved in the original decision.

The re-evaluation may include a review of the entire case file, as well as any new arguments or evidence presented. We aim to issue a final internal decision within seven (7) calendar days of receiving the escalation request unless circumstances require more time.

5.3 Referral to Regulatory Authority or ADR

If the matter remains unresolved after internal escalation, or if the player is not satisfied with the final response, they may refer the complaint to the Tobique Gaming Commission or, where applicable, to an authorized Alternative Dispute Resolution (ADR) provider as permitted under the governing licensing framework.

Players will be informed of their right to escalate externally and provided with instructions on how to initiate that process, in line with regulatory requirements.

Where required under the applicable laws, we maintain detailed records of all complaints submitted by players, including associated correspondence, investigation materials, internal decisions, and final outcomes.

6.1 Retention Period

Complaint records are retained for a minimum of two (2) years from the date of final resolution, or for a longer period if required by applicable law, regulation, or licensing conditions imposed by the Tobique Gaming Commission.

6.2 Accessibility and Confidentiality

All complaint records are stored securely and made accessible only to authorized personnel involved in compliance, auditing, or dispute resolution functions. These records are kept strictly confidential and may only be disclosed:

• To the player, upon verified request;
• To regulators or authorized authorities upon lawful request;
• In accordance with applicable legal obligations.

We may also use anonymized or aggregated data from complaint records to improve internal procedures, identify recurring issues, and support risk mitigation efforts.

We are committed to ensuring that all players who submit complaints are treated fairly, respectfully, and without prejudice.

7.1 Fair and Impartial Handling

All complaints are handled objectively and in accordance with the principles of procedural fairness. Players will not be subject to biased treatment or assumptions based on the nature of their complaint. Each case is assessed based on its individual merits, supporting evidence, and applicable rules.

7.2 Non-Retaliation Guarantee

Players will not be penalized, discriminated against, or otherwise disadvantaged for submitting a complaint in good faith. Access to the platform and related services will not be restricted solely on the basis of having filed a complaint.

We consider complaints to be a legitimate form of feedback and an opportunity to identify operational gaps, improve service quality, and strengthen regulatory compliance.