Disclosure Statement

Please note that, under the licensing conditions of the UK Gambling Commission, we are required to inform players who use Our Facilities in England, Scotland, Wales or Northern Ireland (“UK Customers”) as to the level of protection afforded to UK Customers’ Funds. Customer funds are kept in accounts separate from business accounts; and arrangements have been made to ensure assets in the customer accounts are distributed to customers in the event of insolvency. This meets the Gambling Commission’s requirements for the segregation of customer funds at the level: medium segregation. Click here for more information: http://www.gamblingcommission.gov.uk/Consumers/Protection-of-customer-funds.aspx. Please note that UK Customers will be required to acknowledge receipt of this disclosure statement and We will not permit UK Customers to utilise any funds deposited for gambling until receipt is acknowledged on each of the following occasions: (i) if a UK Customer has not yet deposited funds with Us, on the first occasion on which such UK Customer deposits funds, (ii) if a UK Customer has previously deposited funds with Us, on the next single occasion on which such UK Customer deposits funds with Us; and (iii) on the occasion of any subsequent deposit by a UK Customer, which is the first since a change in Our Disclosure Statement.

Neither ElectraWorks Ltd (“the Operator”) nor any part of the wider GVC Holdings plc (“the Group”) has any history of not meeting liabilities arising on individual gaming transactions or any financial obligations. This includes where the Operator and other companies within the Group run operations within various licensed and regulated countries.

Group Control

As a minimum, the management of the Group perform a monthly review of the performance of the Group’s various operational divisions across the markets where the Group operate and allocate resources towards those businesses that require them. Significant capital investment is provided to new ventures and these are closely monitored whilst in their start-up phase. Concerns about liquidity will be immediately brought to the attention of management.

The Group always ensures that its cash and cash equivalents exceed the Group Customer Funds at all times. As of 30.06.2018, the Group had cash balances amounting to £444.6m and undrawn credit facilities amounting to £495.0m.
Customer funds across the Group amounted to £213.4m at the same date.
The Operator is the main treasury company for holding its UK Customer Funds and the Group’s surplus cash. The Operator invests its surplus cash in high quality money market funds and short term bank deposits with leading European banks.

Operator Control

The UK customer balances of the Operator totalled approximately £10m. To meet the requirements of the LCCP, funds amounting to this amount would be placed in a dedicated bank account. Free cash (the difference between the cash balances and customer funds) would provide the initial operational funding although the UK market (as noted within the financial projections) is intended to be positive for net earnings and cash flow based on the existing player base.
The Operator, as part of the wider Group, operates under a strictly allocated and applied level of financial and management control. Some examples of financial controls in place within the business include:
• The board of the Operator as well as a dedicated management team will assure and review the decision making and financial controls on an ongoing basis.
• The extent to which individual employees can commit the company to any expenditure is clearly set out within a Delegation of Authority document. This document takes into account the company operations and details actions to levels such as (for example) customer service agents can award bonuses through to the level of expenditure for which more senior approval is required.
• The majority of expenditure is routed through procurement and purchase order processes which originate before an order is placed for goods or services and track the flow of expenditure through the business. This is fully integrated into the business accounting.
• Various policies such as treasury and tax management are adopted across the Group to control all Group’s assets.
• The Group has a robust Internal Audit department which reports to the Group’s Audit & Risk Committee. The tasks include oversight over the financial and operational controls in place within the business.

“UK Customer Funds” means the aggregate value of funds held to the credit of UK Customers of the Operator including, without limitation: cleared funds deposited by UK Customers with the Operator to provide stakes in, or to meet participation fees in respect of, future gambling, winnings or prizes which UK Customers have chosen to leave on deposit with the Operator or for which the Operator has yet to account to UK Customers, and any crystallised but as yet unpaid loyalty or other bonuses. Customer funds are kept in bank accounts separate from other business bank accounts and protected by a Segregated Client Account Trust. This meets the Gambling Commission’s requirements for the segregation of customer funds at the level: ‘medium protection’, meaning there are arrangements in place to ensure money is returned to customers in the event the company becomes insolvent.

“Group Customer Funds” means the aggregate value of funds held to the credit of all customers of the Group.