Affiliate Site

SEGA Partners ("SEGA Partners") as the Affiliate Program of SEGA Games, is compelled to seek the highest ethical standards in operating its affiliate marketing network (the "Affiliate Network"), any fraudulent act will not be tolerated. SEGA Partners is committed to take control of any malpractice and it is the personal responsibility of every affiliate to take part in the Affiliate Network (each an "Affiliate") in managing and reducing the risk of malpractice of any sort by our staff, players and other Affiliates.

SEGA Partners encourages Affiliates to make a protected disclosure to SEGA Partners, if any possible malpractice has taken or is taking place. Affiliates will be protected if they genuinely believe that one of their players, our staff or another third party has committed serious malpractice and make a disclosure in good faith.

This policy sets out the type of disclosure which is protected by SEGA Partners and also specifies to whom disclosures should be made and the process that will be followed. In order to be protected from disciplinary action for breach of confidence, you should use the Whistleblowing Procedure set out below.

WHAT IS NOT COVERED BY THIS POLICY?

This policy is not intended for personal or individual accusation relating to your participation in the Affiliate Network. In such cases you should contact your Affiliate Manager at first instance.

WHAT CONCERNS SHOULD BE RAISED?

You should raise a concern immediately if there is a situation or matter which you reasonably believe might involve any of the following malpractices;

• A criminal offence, such as theft, fraud, bribery or collusion
• Danger to the health and safety of any individual
• Failure to comply with applicable legal and contractual obligations
• A miscarriage of justice
• The deliberate concealment of information about any of the above
• Wherever possible the Affiliates identity will not be disclosed without their permission or unless there are grounds to believe that they have acted maliciously. However, should the disclosure result in court proceedings your identity may need to be revealed to a Court of competent jurisdiction.
• An Affiliate who makes a protected disclosure will not suffer harassment, retaliation or any adverse consequences.
• Any disclosure that is not substantiated yet made in good faith will not be cause for action against the affiliate.
• Any abuse on giving false information, or intentionally makes a false report or unfounded and malicious allegations or by making an external disclosure in breach of this policy without reasonable grounds or otherwise than to an appropriate authority, may result in the termination of your affiliate agreement
• At any time during the process you may seek support and advice from your Affiliate Manager by emailing affiliatemanager@segapartners.com

PROCEDURE TO RAISE A CONCERN

1. Informing SEGA Partners

   
   Send an email to our secure and confidential mail box: disclosure@segapartners.com; the mailbox is directed independently of the SEGA Partners team to a senior member of the SEGA Games who will investigate the disclosure. On the other hand, should you wish to speak with someone directly, you may call your Affiliate Manager.
   
   You have the option to make the disclosure anonymously; however, you are encouraged not to do this as it may restrain any proper investigation.

2. The first meeting

   
   You will be contacted to arrange a meeting which will usually be by telephone and held within 5 business days. The meeting will be held with a senior member of the investigation team.
   
   The objective for doing this is for you to provide further details and prove you have reasonable grounds for believing serious malpractice has taken place.
   
   A written summary of the meeting will be prepared and sent to you via email and should be signed by you and the investigating officer/s. This document will be treated as strictly confidential.

3. The investigation
   

   All the information received under this policy will be thoroughly and promptly investigated. Where appropriate, further investigation will then be carried out by the investigating officers. You will be kept informed of progress and may be required to attend additional investigatory meetings by telephone or provide further information by email.

4. Reporting the outcome
   

   Following investigation, a report will be prepared for the SEGA Games Executive Management team detailing the findings and immediate steps will be taken to bring the company into compliance with the applicable law, regulation or policy
   
   You will be notified in writing of the outcome of the investigation and the resulting action that has been taken.

5. Disclosure to an external body

   
   If you believe the malpractice has not been adequately dealt with, you should inform your Affiliate Manager in writing that you intend to make a disclosure to an external body.
   
   Provided you are acting in good faith and you have evidence to support your concerns, you can also contact:
   
   

   • The Alderney Regulatory Authority
   • The Alderney Gambling Control Commission