Business conduct

We do not pay bribes, facilitation payments or kickbacks, and we do not accept them. That includes a payment to speed up something we are entitled to anyway, which is the form this takes in practice and the one people talk themselves into.

A gift or hospitality is acceptable where it is open, proportionate, infrequent, not cash or a cash equivalent, and not offered or received around a decision it could influence. The test we use is whether we would be comfortable with the other side's compliance team reading about it, which is a better instrument than a number. An industry conference stand dinner passes; anything that would need explaining does not.

This matters more in gaming than the generic version of this paragraph suggests. A supplier sits next to decisions about which games get promoted, which rungs an operator runs and which integration is prioritised. Those are exactly the decisions an inducement would be aimed at. A commercial arrangement with an operator belongs in the contract, at a price, in writing.

We will not supply, license or contract with a party, or into a market, where doing so breaches EU restrictive measures, United Nations sanctions, or the sanctions regimes of the jurisdictions we operate under. Ownership and control are part of that check, as well as the name on the contract.

Where a market is served, it is served because somebody read the instrument that permits it and wrote the citation down. A market we have not read is marked as not permitted, and every launch into it is refused by the server, not by a policy.

A holder of a critical gaming supply authorisation alone is not a subject person under Malta's Prevention of Money Laundering and Funding of Terrorism Regulations. The customer due diligence regime that binds a casino does not bind us, and we are not going to publish a customer due diligence programme we are not required to run and do not run.

What does reach us is the ordinary duty to satisfy ourselves that a counterparty is who they say they are and is authorised for what they are asking for. So before a game goes live for an operator we check their licence in the issuing regulator's own public register, check that it covers the market and the product, and record the check. The server then enforces it independently of anybody's diligence: a launch is refused unless the operator is active, the entitlement exists, the market is contracted and there is an unexpired certificate for that exact combination of build, maths and market.

We never hold player funds, never take a deposit, never pay a withdrawal and never touch a payment instrument. The wallet is the operator's, and the money never passes through here.

The studio is small enough that every conflict of interest is visible to everybody in it, and that is the control today rather than a register. What we commit to: a personal interest in an operator, a competitor, a supplier or an affiliate is declared before it touches a decision, and the person with the interest does not take the decision.

Two specific ones, because they are the real ones for a game studio. Nobody here plays for real money at an operator we supply. And no commercial arrangement exists, or will exist, that pays us more when a player loses more than the certified maths says they should. The return is a certified artefact chosen per licence against the market's own minimum, and it is not a lever anybody here can pull for revenue.

We expect of anybody we buy from or contract with what is on this page: no bribery, sanctions compliance, lawful employment, and no forced or child labour anywhere in their own chain. Where we commission creative work, the people doing it are paid at an agreed rate on agreed terms and the rights they grant us are written down.

This is an expectation stated in a contract, and it is not an audit programme. We do not inspect a supplier's premises and we do not run a third-party risk platform. A studio this size has a handful of suppliers (hosting, a database, two font foundries, a sound library, some contracted art), and the control is that we know who all of them are.

There is no forced labour, no bonded labour and no child labour in this studio or in anything we commission, and our supply chain is short enough to say that about rather than to estimate it: infrastructure vendors, software licences and individually contracted creative work.

This is not a statement under section 54 of the UK's Modern Slavery Act 2015, which applies to organisations with a UK turnover above thirty-six million pounds, and it is not one under the EU's forced labour or due diligence instruments. It is a statement of fact that costs us nothing to make and that a procurement questionnaire will ask for anyway. When a threshold does reach us, this section becomes the document that satisfies it and will say so.

A supplier's responsible-gaming position shows up in what its games refuse to do, not in a policy. Ours is enforced in the maths and in the server rather than in the client: a celebration is refused for a win that does not exceed the stake, the substitution that manufactures a near miss has no code path, a market that prohibits a bought feature has it removed rather than greyed out, and the minimum interval between paid rounds is enforced where the bet is taken.

The reasoning and the citations are on the responsible-play page. Each refusal is a check that fails the build.

If you work here, work with us, or are anybody at all who believes something here is unlawful, unsafe, dishonest or a breach of this page: say so. The route is the inbox below with "CONCERN" in the subject line, and it reaches the studio's founders.

What we commit to: an acknowledgement within seven days, the concern looked into by somebody who is not the subject of it, no retaliation of any kind for raising it in good faith, and confidentiality as far as looking into it allows. You can ask for anonymity, understanding that it limits what we can come back to you with.

The limitation: in a studio this small the founders are the channel, so a concern about one of them has nowhere independent to go internally. Malta's Protection of the Whistleblower Act provides external reporting channels that do not depend on us at all, and that is the right route for that case. When we reach the fifty-employee threshold the Act obliges a designated impartial officer, and the channel becomes that rather than this paragraph.