ADR Annual Report
ADR Internal Statement of Compliance
Annual and Quarterly Reporting
Reporting period – October 1st 2024 – September 30th 2025
Name of ADR Provider – Blexr Ltd
Background:
| Type of ADR offered (e.g. mediation, adjudication, etc). | Adjudication |
|---|---|
| Number of employees as ADR officials. | 1 + 1 in training |
| How are dispute outcomes reached (e.g. panel decision, individual mediator, etc)? | Individual mediator with the option for panel decisions as training progresses |
| If outcome is reached by panel decision, please explain who makes up the panel? | As the team grows, complex cases will be reviewed by the whole team. Final decision will lie with the Head of ADR Services, but consideration will be given to the opinions of all ADR Officials. |
| How is the ADR funded? | Marketing |
As a competent authority for the gambling sector, we approve alternative dispute resolution (ADR) providers that wish to offer services to gambling consumers. Our role as competent authority includes making sure that ADR providers continue to meet the requirements of the ADR Regulations, alongside our role as gambling regulator to make sure that gambling is fair and open. The Gambling Commission expect ADR providers in the gambling industry to meet the requirements of the ADR Regulations and our additional standards.
Internal statement of compliance
Please demonstrate how your organisation and your ADR process complies with the requirements of the ADR Regulations and the Commission’s standards for ADRs in the following areas:
| Statement | Response |
|---|---|
| ADR Services offered by the body Please demonstrate how you meet the requirements of the ADR Regulations Schedule 3, section 1. As part of your answer, explain how you ensure that stakeholders know why the scheme exists, what it does and what to expect from it (Ombudsman Association six principles of good governance, Clarity of Purpose). | Blexr operates their ADR service via CasinoReviews.com, through which any consumer can submit a complaint against any online gambling operator. The service is neither formed for the purpose of dealing with one particular dispute issue. Our ADR Official is not employed or remunerated by any trader. Our marketing activities ensure that consumers are aware of the service and understand its purpose, whilst our ADR Official is widely regarded as an expert in the field of dispute resolution within the gambling sector and frequently participates in interviews and discussion panels relating to complaint management and other key aspects of gambling regulation. This ensures that the industry is aware of our service and what we do. |
| Access to the ADR body Please demonstrate how you meet the requirements of the ADR Regulations Schedule 3, section 2. As part of your answer please explain how you consider the needs of vulnerable consumers (Commission standards, p24), and comply with other legislation such as GDPR. | We maintain an up-to-date website that supports players submitting complaints against any gambling operator. All information relating to the complaints service can be provided on a durable medium if requested. Complaint submissions and supporting documentation can be filed online. We can support physical post submissions where necessary. We support the exchange of information between the parties by electronic means or by physical post where necessary. We provide a complete Service Accessibility Policy to support vulnerable consumers. All data relating to complaints is restricted so that only team member directly involved in the management of complaints have access and the Legal Basis for processing of complainant information is clearly documented in our Privacy Policy. |
| Expertise Please demonstrate how you meet the requirements of the ADR Regulations Schedule 3, section 3(a). As part of your answer, please document any training or qualifications that your ADR officials undertake, the frequency of this, and whether there are refresher sessions for officials, and any experience in dispute resolution that officials have. | Our ADR Official: - has over a decade of experience managing player complaints in the remote gambling sector; - holds qualifications from the Chartered Institute of Arbitrators; - is a member of the International Ombuds Association; - is a member of the International Council for Commercial Arbitration; - is a member of the Chartered Institute of Arbitrators; - is provided with an annual budget to undertake relevant educational courses. Our ADR Official in training is not currently positioned to make independent rulings, and instead works side-by-side with our approved ADR Official to gain experience. |
| Independence Please demonstrate how you meet the requirements of the ADR Regulations Schedule 3, section 3(b), (d), (e), (g) – (h). As part of your answer, please explain how you ensure and evidence the freedom of the office holder from interference in decision making (Ombudsman Association six principles of good governance, Independence), and how you are transparent about the way you are funded (Commission standards, p18). | Our Head of ADR Services is appointed for a 5 year term and cannot be relieved of their duties without just cause. Our ADR Official is remunerated on a flat salary basis. We maintain a detailed Conflict of Interests policy that requires all staff involved in the management to player complaints to disclose any potential conflicts of interest and details the steps to be taken where an issue is identified. Our ADR Official is not employed or remunerated by a professional organization or business association. Our ADR service does not operate on ‘collegial body’ basis. Our internal policies restrict participation in the dispute management process to team members that are included on our Register of Interests. Employment contracts for team members involved in the dispute management process include terms prohibiting discussion of any complaint case with any team member not included on our Register of Interests. |
| Impartiality Please demonstrate how you meet the requirements of the ADR Regulations Schedule 3, section 3(c), (e), (f), and section 4. As part of your answer, please explain how you ensure straightforward dealing and completeness, based on honesty, selflessness and objectivity and ensuring high standards of probity and propriety (Ombudsman Association six principles of good governance, Integrity). Please also explain how your conflicts of interest procedure meets the requirements of the ADR Regulations, Schedule 3, section 4. This should include how you ensure that parties to a dispute fully understand the process where a conflict arises, and how you ensure that any ADR officials who work part-time in another capacity are not conflicted by their non-ADR duties (Commission standards p19). | Our internal policies preclude any involvement in the review or decision making process on any complaint from any team member that is not part of the complaint management team. This includes our Senior Leadership Team. All team members involved in the management of player disputes are required to sign our Register of Interests, ensuring that they have no personal financial holdings that could influence the partiality of their decision making. Where any holdings were entered into the Register of Interests that could potentially influence, or appear to influence, the outcome of any complaint, responsibility for the complaint in question would be reassigned to another team member. All team members involved in the management of player disputes are required to adhere to our Conflicts of Interests policy. All team members involved in the management of player disputes are required to sign an addendum to their contract agreeing to abide by the 7 Principles of Public Life. Our employment contracts for ADR team members include explicitly defined requirements disallowing the discussion of any complaint with any employee or Director not included on the Register of Interests and prevents any employee being dismissed for refusal to discuss complaints with any individual not included on the Register of Interests. All of our ADR team are remunerated on a fixed rate salary. No rewards or incentives are offered that are in any way associated with the outcome of any complaint/s. Our Head of ADR Services is appointed for a period of 5 years to ensure consistency of service, with renegotiation occurring on the 4th year of the term, to ensure that this negotiation cannot impact any ongoing case. The above measures ensures that the all team members who hold responsibility for the management and rulings on any player complaint are appropriately vetted and protected from any factors that could adversely impact the impartiality of their verdicts. Our Conflicts of Interest policy is publicly available and clearly defines the processes in place to identify and address Conflicts of Interest. We do not have any Part-Time ADR Officials, but where we were to employ someone in this capacity, they would be subject to the same policies that have already been detailed in this document. |
| Transparency The ADR Regulations require you to publish information on your website (ADR Regulations Schedule 3, section 5), and we will check your website for this information. We also expect you to publish performance data and specific information on your methods and timescales as part of our standards. Explain how in general you ensure openness and transparency in your scheme in order that stakeholders can have confidence in the decision making and management processes of the scheme (Ombudsman Association six principles of good governance, Openness and transparency), and how all members of the scheme are seen to be accountable and responsible for their decisions and actions (Ombudsman Association six principles of good governance, Accountability). | All the information detailed in Schedule 3, section 5 can be found in our terms of use, or in the activity reports that we publish on an annual/biannual bases as required by the regulator. Every complaint that we receive concludes with a published complaint report detailing the outcome of the complaint and the communication record between our service and the complainant. Our Principals of Good Governance, which are publicly available, clearly detail how our scheme is funded and commits our organization to the transparent and open standards required by the Ombudsman Association. |
| Effectiveness Please demonstrate how you meet the requirements of the ADR Regulations Schedule 3, section 6. As part of your answer, please explain how you ensure that the scheme achieves its outcomes efficiently and represents good value for money (Ombudsman Association six principles of good governance, Effectiveness). You should also demonstrate how you meet the decision/outcome quality standards (Commission standards, p19), and the process you have put in place for an audit/review of dispute outcomes, service standards and service quality (Commission standards, p18). | Our website, and complaint systems are available to anyone anywhere in the world. We make no requirement that any party to a complaint engage independent legal advice. Our service is free of charge to all parties using it. We provide weekly updates on every complaint we receive, and deliver rulings within one week of receipt of the complete complaint package. We are exceptionally thorough in our inquisitorial approach, working with both complainants and traders to identify all relevant information and help lead the relevant party to provide the information needed where they are unsure. We engage robust auditing and reporting on complaints (where we have processed complaints) via published individual complaint reports and published assessments of the overall performance of the service. This allows for appropriate comparisons can be made over time to ensure that complaints are managed in a consistent fashion. |
| Fairness Please demonstrate how you meet the requirements of the ADR Regulations Schedule 3, sections 7-10. As part of your answer, explain how you ensure that your dispute process takes account of the balance of power within a dispute, particularly around sharing evidence with parties to a dispute (Commission standards p18). | All parties are allowed 3 full weeks to respond to any update or requests for information, including reminders where there are outstanding requests. Complainants are informed of their right to take independent legal advice. The outcome of all complaints are published in our complaint reports and can be provided on a durable medium where required. Where a compromise position is proposed rather than a ruling in favour of one party or the other, the complainant is notified that they are not legally obligated to accept this proposal and they can withdraw from the dispute management process at any time, that their participation with our service does not prevent them from taking their complaint to the relevant court systems for redress, that any solution that we may have presented may differ from the solution of a court, and of the legal outcome of accepting our proposed solution. The parties are notified at the beginning of the complaint management process that they have the right to withdraw at any stage. Our service is consciously aware that there is an clear imbalance of power between consumers and traders, with the trader ordinarily having in-house legal counsel and far more substantive familiarity with the terms and conditions and laws relevant to the service. As such we understand that the consumer will frequently require more substantive scaffolding to present their most effective case and seek to accommodate this need. |
| Legality Please demonstrate how your process meets the requirements of the ADR Regulations, Schedule 3, section 11. | Where we seek to impose a ruling on the consumer (this only happens where we are suggesting a compromise solution that would be binding on the consumer) we ensure that the consumer can opt out before any action is taken that could detract from their legal rights and that this right alongside any potential consequences to the consumer’s rights are clearly communicated to the consumer before any action is taken. Given that the UKGC license is only applicable to individuals within the UK at the time of play, cross-boarder disputes with conflicting legal standards are highly unusual. Our service has never encountered one. |
| Legality Please demonstrate how your process meets the requirements of the ADR Regulations, Schedule 3, section 11. General Please tell us about any changes you have made to the delivery of your dispute resolution process since your last report. What has been the impact of the changes? If you would like to share any additional information or comments (beyond that required by your ADR Regulations-specified annual report) then please comment below. | There have been no changes to our service since our last communication with the Gambling Commission. |
Quarterly/Annual reports
Quarterly reporting periods end 31 December, 31 March, 30 June, and 30 September.
Annual reporting periods end 30 September.
Please submit your reports to [email protected] by the end of the calendar month which follows the end of the reporting period.
Annual report information must be displayed on your website by 1 November each year, as per the ADR Regulations.
ADR provider quarterly / annual reporting
| ADR provider | Blexr Ltd | |||
|---|---|---|---|---|
| Reporting Period | 1st October 2024 – 30th September 2025 | |||
| Quarterly return only* *if Nil Return, then please submit your quarterly return now. | No | |||
| a) No. of domestic & cross border disputes received | Domestic | 0 | ||
| Cross Border | 0 | |||
| Please indicate how you deal domestic and cross-border disputes brought by consumers against a trader | ||||
| b) No. of each type of complaint Please list the actual number of each type of complaint you received. | 0 | |||
| c) Total number of disputes the provider refused to deal with % share of the grounds set out in para 13 Schedule 3 of the ADR Regulations | 0 | Total in A and percentage in B | A | B |
| The consumer has not contacted trader first | ||||
| Dispute is frivolous/vexatious | ||||
| Dispute is being/has been considered by another ADR provider/court | ||||
| Value is outside the provider's monetary thresholds | ||||
| complaint not submitted within time period | ||||
| dealing with the dispute would impair the effective operation of the body | ||||
| not the relevant gambling sector | ||||
| GC regulatory matter only (not a dispute) | ||||
| Discontinued for non-operational reasons (e.g., party withdrew) | ||||
| d) % of ADR procedures discontinued for operations reasons | 0% | reasons for discontinuation if known | ||
| e) Average time taken to resolve disputes in days | Domestic | 0 | ||
| Cross Border | 0 | |||
| f) No. of disputes completed in period | 0 | |||
| g) % completed disputes ruled in operator's favour | 0 | |||
| h) % completed disputes ruled in favour of the consumer | 0 | |||
| i) % completed disputes settled by the operator during the ADR process | 0 | |||
| j) average length of time taken to receive complaint file from operator (days) | 0 | |||
| k) Gambling Sectors Please indicate the gambling sectors for which you accept disputes | Adult Gaming Centre [ ] | Betting [ ] | Bingo [ ] | |
| Casino [ ] | Family Entertainment Centre [ ] | Lotteries [ ] | ||
| Remote - Casino [ ] | Remote - All Sectors [ X ] | Remote – Other please specify [ ] | ||
| Remote Betting [ ] | Remote - Bingo [ ] | |||
Items (f) to (k) are part of the Commission's additional standards and not a requirement of the ADR Regulations.
For annual report only - note that all fields relating to the annual report must be displayed on your website by 1 November each year.
| i) l) a description of any systematic or significant problems that occur frequently and lead to disputes between consumers and traders of which the ADR entity has become aware due to its operations as an ADR entity. | [ NA ] |
|---|---|
| m) any recommendations the ADR entity may have as to how the problems referred to in paragraph (c) could be avoided or resolved in future, in order to raise traders’ standards and to facilitate the exchange of information and best practices | [ NA ] |
| n) the rate of compliance, if known, with the outcomes of the alternative dispute resolution procedures. | [ 0 ] |
| o) the co-operation, if any, of the ADR entity within any network of ADR entities which facilitates the resolution of cross-border disputes. | [ NA ] |
| p) please list all operators where you currently provide dispute resolution services. | [ 0 ] |