CasinoReviews Principals of Good Governance

The CasinoReviews Team takes great pride in our Alternative Dispute Resolution (ADR) service which is approved to act as an Alternative Dispute Resolution (ADR) service for the MGA licensing system. We want to ensure that players have full confidence in the independence and impartiality of the service we offer. To that end, we adhere to the Ombudsman Association’s Principles of Good Governance.

To evidence this, we’re going to expand on the steps we’ve taken to ensure that we meet every aspect of the Principles of Good Governance below:

Ensuring and demonstrating the freedom of the office holder from interference in decision making:

To ensure that our ADR Officials are free from any interference in the complaint management process, we operate a multi-layered system.

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 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 commercial interests of the business, and the individuals involved in the complaint management process, cannot unduly influence the outcome of any complaint.

CasinoReviews.com has taken a number of steps to ensure that our ADR service has an appropriate and proportionate structure and that our financial structure ensures the independence of the system from any commercial considerations.

We have appointed a Head of ADR Services with over a decade of dispute management experience within the iGaming sector, who has acted as an ADR Official within both the MGA and UKGC licensing schemes and who is a member of the Chartered Institute of Arbitrators, to oversee the management of our ADR service.

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.

All team members who have any influence over our dispute management process 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.

Our employment contracts for all team members involved in the dispute management process 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 or disciplined 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.

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.

To ensure consistency in our service 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.

All team members who have any influence over our dispute management process 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.

Our employment contracts for all team members involved in the dispute management process 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 or disciplined 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.

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.

Ensuring openness and transparency in order that stakeholders can have confidence in the decision-making and management processes of the scheme:

CasinoReviews.com is empowered to act as an ADR for the Malta Gaming Authority license by the Malta Competition and Consumer Affairs Authority. This body oversees the function of ADR’s in all business sectors in Malta. We are required to produce both annual and biennial reports for the MCCAA publish these reports for public consumption.

Our ADR service is funded via affiliate marketing. We do not charge either players or operators for the management of complaints.

Funding our ADR service in this manner minimises the potential for traders to inappropriate financially influence the outcome of any dispute. Where an ADR service charges the trader to fund the service, if the trader opts to switch to an alternative ADR provider, the revenue streams of the original ADR service provider are immediately reduced.

Conversely, where the service is funded via marketing, if a trader opts to switch to an alternative ADR provider, the ADR service can simply replace any advertising for the trader with an alternative marketing partner, offsetting or entirely mitigating any potential financial loss for the ADR service.

The ADR service also provides our team with invaluable insight into the business practices of our ADR clients, allowing us to provide informed opinions based on documented experience that is unavailable to any other party in the industry, improving the quality of our content and recommendations.

CasinoReviews.com clearly lays out its policies and procedure via our terms of use and complaint system documentation.

The criteria upon which decisions are made are clearly outlined in our terms and conditions document – 4.13 Principles of Service. These principles are used in conjunction with relevant consumer laws and appropriate regulatory licensing standards.

Every complaint managed by CasinoReviews.com receives a published complaint report, allowing other consumers to see how the complaint dialogue is managed and ensuring robust recording of both the decisions on each can and the evidence upon which those decisions were based.

Every complaint managed by CasinoReviews.com receives a published complaint report, allowing other consumers to see how the complaint dialogue is managed and ensuring robust recording of both the decisions on each can and the evidence upon which those decisions were based.

Upon receive of a complaint, our system automatically assigned the case to one of our Dispute Resolution Officials (DRO). The DRO will then review the complaint to determine whether any factors pertinent to the claim exist that would require management under our Conflict of Interest policy.

Cases of a complex nature, or those where one or both of the parties acts in a disputatious manner will be escalated to our Head of ADR Services.

Individual DROs have the authority to make rulings on individual cases, however the Head of ADR Services has the authority to overrule DRO rulings, or require that a complaint be reviewed by a panel of the Complaint Management Team to reach a ruling.

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.

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 or disciplined for refusal to discuss complaints with any individual not included on the Register of Interests.

Ensuring that all members of the scheme, including the office holder staff members and members of any governing body are seen to be responsible and accountable for their decisions and actions, including the stewardship of funds (with due regard to the independence of the office holder)

CasinoReviews.com is subject to the oversight of the Malta Competition and Consumer Affairs Authority. This body oversees the function of ADR’s in all business sectors in Malta. We are required to produce both annual and biennial reports for the MCCAA publish these reports for public consumption.

Alongside this, every complaint that we review receives a published complaint report. While there are some aspects of these reports that we have to redact for privacy, security or legal reasons, our complaint reports ensure that players can gain valuable insight into the volume and type of complaints being submitted against various gambling operators, alongside gaining a clear overview of how our service interacts with complainants to explore and resolve claims.

Our ADR team is headed-up by our Head of ADR Services, who has over a decade of experience managing disputes in the remote gambling sector. All our ADR Officials are directly answerable to the Head of ADR Services, who consults on complex cases/regulatory issues and provides regulator one-to-one training to the team.

Our Head of ADR Services is answerable to the CasinoReviews.com Senior Leadership Team, about matters relating to the function of our complaint management service generally, but not about the management or outcome of any individual complaint. This ensures that the Senior Leadership Team can raise appropriate questions about the function of the service – for instance, if the average complaint management times increase, or there is a substantial shift in the proportion of complaints ruled in favour of the consumer – whilst protecting the integrity of the complaint decision making process.

We operate a multi-layer system to ensure that our ADR service – which is free to use for both parties – and our revenue generation systems (affiliate marketing) are isolated from each other.

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 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 commercial interests of the business, and the individuals involved in the complaint management process, cannot unduly influence the outcome of any complaint.

Every year, our service has to produce an annual report for the MCCAA, detailing various performance stats for the service. This includes the ruling rates (which party we rule for, business or player), the average length of time that the complaint management process takes, the number of complaints declined and the reason for declination, funds recovered and compliance rates. These reports are used to inform our team of any changes in the quality of service to allow us to investigate any reason for shifting patterns of success.

Alongside this, our internal reporting systems allows for continuous tracking of these criteria, both on a whole service level and on an agent by agent level, to allow changes in performance to be identified quickly and ensure that we provide a high quality of service and appropriate support and training to all our ADR Officials to ensure consistency across the system.

CasinoReviews.com maintains a clear whistle-blowing policy for all team members, which can be located here.

Ensuring straightforward dealing and completeness, based on honesty, selflessness and objectivity, and ensuring high standards of probity and propriety in the conduct of the scheme’s affairs and complaint decision making.

We operate a multi-layer system to ensure that our ADR service – which is free to use for both parties – is entirely impartial and protected from undue influence.

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.

All team members involved in any part of the complaint management process are required to sign our Register of Interests declaring any personal holdings that may, or may be seen to, represent a conflict of interests.

CasinoReviews.com has a clear Conflict of Interest policy requiring any team member involved in any part of the complaint management process to declare any information that may, or may be seen to, impact their ability to provide an impartial ruling on any case.

Where a conflict of interests is identified, responsibility for the management of the claim will be reassigned to another team member. If no team member can be provided that is entirely clear of any conflict of interests, in the first instance both parties to the complaint will be informed of the conflict of interests. If the parties agree to move ahead despite the conflict of interests, the claim will proceed as normal. If either party feels that the conflict represents a serious impediment to an impartial ruling a 4th party ADR will be contacted and engaged to manage the claim in question.

All team members involved in any aspect of the complaint management process are required to sign an addendum to their contract agreeing to abide by the 7 Principles of Public Life.

CasinoReviews.com ensures that we maintain robust and detailed internal policies, including our Conflicts of Interest ADR policy, Whistleblowing policy, and Grievance policy, that clearly outline the standards by which any governance issue will be managed.  

Ensuring that stakeholders know why the scheme exists, what it does, and what to expect from it

The purpose of this service is to provide gambling consumers a more easily accessed alternative to the court system when seeking redress due to a dispute between themselves and an online gambling operator.

We are an ADR service, approved by the MCCAA, to manage disputes between consumers and Malta Gambling Authority (MGA) licensees.

Our service is registered with the EU ODR under the name Blexr Ltd.

While we will make efforts to assist any player with a complaint against any gambling operator informally, we can only act in the official capacity as an ADR against MGA licensed gambling operators who have chosen to engage our ADR service.

Consumers can confirm the ADR service that any MGA licensed gambling operator uses by checking the gambling operator’s terms and conditions page.

When acting as an ADR, this service is empowered to act as an alternative to the small claims courts and provide legally binding rulings on consumer complaints up to €5000. In some cases, we may be able to deliver legally binding rulings on higher claim values, but this will be contingent on the specifics of our service agreement with the client. For clarity, please ask when you submit your complaint.

Regardless of the nature of the rulings that we provide, they do not impair the consumer’s right to escalate their claim via the relevant court systems.

Where we are acting informally (outwith our role as an ADR), we do so without any of the legal authority that the ADR system provides.

CasinoReviews.com engages multiple strategies to ensure that all team members that are involved in the complaint management process can clearly understand their ongoing responsibilities as relates to the execution of their role in the dispute management process.

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.

All employees involved in any aspect of the complaint management process are required to sign our Register of Interests, ensuring that they declare any holdings that could impact, or be seen to impact, their ability to provide an impartial ruling on any case.

The employment contracts for both our Head of ADR Services and our ADR Officials included job requirements that prohibit the discussion of any ongoing complaint with any team member that is not included on the Register of Interests. Breach of this requirement can result in disciplinary action.

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.

All team members are required to comply with our Conflict of Interests policy, ensuring that any factors that could, or could be seen to, unduly influence their ability to impartially review a claim are reported. Where it is identified that a Conflict of Interests may exist, an alternative ADR Official will be appointed to manage the case.

CasinoReviews.com maintains a clear whistle-blowing policy for all team members, which can be located here.

All ADR Officials receive appropriate training before undertaking any complaint management unsupervised. Ongoing one to one and group meetings are undertaken within the ADR team to ensure that best practice is shared and a consistent approach to the management of complaints is maintained at all times.

All ADR Officials are required to undertake training with the Chartered Institute of Arbitrators to ensure a high level of professional expertise.

Ensuring that the scheme delivers quality outcomes efficiently and represents good value for money.

CasinoReviews.com has hired a Head of ADR Services with over a decade of experience managing disputes in the remote gambling sector and who has been one of the principal parties responsible for the founding of a charity with the core purpose of supporting people experiencing gambling disorder.

Our Head of ADR Services is responsible for training and oversight of all ADR Officials.

We maintain a clear escalation policy to ensure that complex or ambiguous cases are escalated to the Head of ADR Services, and that these cases are discussed in team training sessions to ensure that different opinions on these cases are evaluated and best practice can be collectively assessed.

We ensure that our onsite documentation clearly outlines how our complaint management service works and what players should expect as they move through the process.

While every claim is individual, meaning that player experiences can vary substantial between claims, our team ensures that players are provided regular updated on their claim, even where that is simply an acknowledgement that work is ongoing and we will reach out with an update once we have relevant information to communicate.

With both parties to any claim, we ensure that requests to provide further information are communicated clearly, and where the information is not immediately forthcoming, multiple reminders are provided before the case will be considered abandoned.

Where a claim results in an instruction for the player to be paid, we continue to monitor the claim until such time as the complainant has confirmed receipt of their funds or has failed to respond to multiple requests for updates.

CasinoReviews.com engages regular review of various KPIs that ADRs are assessed by on a regular basis, both over the entire service and for individual ADR Officials to ensure that quality and standard of service is maintained, and any deviations are identified and investigated.

Training is engaged to support and develop any ADR Official that is identified to deviate significantly from our KPI targets.

A cross-team approach is taken to any and all maintenance or upgrades, to ensure that the service experiences minimal downtime.

Risk assessments are undertaken before any work is undertaken on any system that contains user PII.

Every year, our service has to produce an annual report for the MCCAA, detailing various performance stats for the service. This includes the ruling rates (which party we rule for, business or player), the average length of time that the complaint management process takes, the number of complaints declined and the reason for declination, funds recovered and compliance rates. These reports are used to inform our team of any changes in the quality of service to allow us to investigate any reason for shifting patterns of success.

Alongside this, our internal reporting systems allows for continuous tracking of these criteria, both on a whole service level and on an agent by agent level, to allow changes in performance to be identified quickly and ensure that we provide a high quality of service and appropriate support and training to all our ADR Officials to ensure consistency across the system.

Complex cases are also selected for team training and the sharing of best practice amongst all of our ADR Officials. This helps ensure that consistent positions are taken and a collective approach is taken to the review of challenging cases.

CasinoReviews.com monitors the reporting published by other ADRs in the sector to ensure that our service is within a comparative range across various KPIs and ensuring that we are delivering outcomes for complainants that are in line or exceeding those that are provided by comparator services.

We engage with operators directly to ensure that our service provides them the information and structures they need to present complete and accurate defence of every case, and to make the complaint management process as frictionless as possible.

We also publish reports for every complaint managed, ensuring that other consumers can see both the nature and frequency of complaints that are arising against various operators and to give insight into our methodology and approaches to the complaint management process.

CasinoReviews.com engages with relevant regulator bodies in all jurisdictions that we function in on a continuous manner, both for the purposes of reporting and ensuring that we are fully apprised of any regulatory changes, or recommendations of best practice.

All of our policies are designed and implemented to ensure that CasinoReviews.com can execute its responsibilities in as fair and transparent a manner as possible, and to minimise the risk of any undue influence inappropriately impacting the outcome of any case.

These include:
- Requiring all team members involved in the management of player complaints to sign and maintain their entry in the Register of Interests.
- Ensuring that our employment contracts require all employees to disclose any conflicts of interests.
- Maintaining a clearly laid out and robust Conflicts of Interests – ADR policy.
- Maintaining a clear and detailed Whistleblowing policy.
- Requiring all team members involved to enter into an agreement to adhere to the 7 Principles of Public Life.

Our service is free to both consumers and traders, making it the most cost effective system possible.