Policies & Procedures | versus

A brand by versus Inc. · Operational Policies & Procedures

a brand by versus Inc. Draft for review. To be confirmed by a qualified UK gambling-law adviser before submission. See 00_CHANGELOG_AND_REVIEW_NOTES.md for changes and the items to reconcile in the app/backend before relying on this document.

1. Introduction

This document outlines the policies and procedures that have been adopted by versus Inc. trading as “versus“ (hereafter referred to as “versus“) as per its obligations under the Gambling Act 2005 and the current version of the Gambling Commission’s Licensing Conditions and Codes of Practice (“LCCP”).

These policies and procedures are designed for the requirements of a Remote Betting (with linked software) licence issued by the Gambling Commission for the targeting of those using remote gambling facilities within the United Kingdom. The business plan of versus is to solely target British residents.

versus holds a Remote Betting Operating Licence issued by the Gambling Commission (Operating Licence Number 000-101143-R-342325-001, account 101143). Its status can be verified on the Gambling Commission’s public register at www.gamblingcommission.gov.uk.

Should, in the future, versus desire to target customers from other jurisdictions under its Gambling Commission operating licence, then separate policies and procedures will be developed to reflect the licensing requirements of the additional licensing jurisdiction(s).

2. Responsibility for Policies and Procedures

Responsibility for the design and implementation of the company’s policies and procedures lies with the Director of versus. Responsibility for their implementation lies with every member of staff. Responsibility on a day-to-day basis for their upkeep and supervision will be with David Worldorf (CEO). Dr. Philip Blazdell (Oxford, UK) serves as Head of Regulatory Compliance and MLRO. Emmanuel Onditi (London, UK) serves as Head of Information Technology & Security.

The compliance role includes (but is not limited to) the following functions:

  • Ensuring all key events are reported to the Gambling Commission

  • Ensuring that the company’s financial controls described in the business plan are adhered to

  • Being familiar with the rules regarding anti-money laundering as per the Money Laundering Regulations (as amended), the Proceeds of Crime Act 2002, the Terrorism Act 2000, and all regulations, licensing conditions, codes of practice, and guidance issued by the Gambling Commission

  • Being the company’s nominated officer for the reporting of suspicious activity with regards to anti-money laundering (MLRO)

  • Being the designer of all staff training and ensuring that it reflects all obligations under the LCCP and the company’s policies

  • Recording all training delivered to staff, their success rate in training testing, and ensuring that staff receive annual refresher training

  • Ensuring that all company policies reflect the LCCP and are being adhered to

  • Ensuring that all marketing communications abide by the relevant industry codes

  • Ensuring that every action of the company abides by the relevant legislation, regulations, and LCCP

  • Ensuring that the company is kept aware of and policies are updated to reflect any changes in legislation, regulation, or LCCP

  • Ensuring that all company terms and conditions and game rules reflect any changes in legislation, regulation, or LCCP

It will also be the responsibility of the CEO to keep themselves aware of all updates to regulatory and LCCP changes by monitoring of the Commission website, subscribing to its newsletters, and through updates sent by legal advisors.

Compliance Enforcement:

  • All company activity that involves expenditure will be discussed at monthly management meetings and signed off by the management team including the CEO, whose signature authorising the expenditure will confirm it as being compliant with all company policies, legislation, regulation, and LCCP

  • Day-to-day activity of the company will comply with all company policies and legislation, regulation, and LCCP due to all staff having to contractually abide by such terms and having been regularly trained in them

  • All qualified persons holding a qualifying position will complete compliance training modules provided by GamCare

  • Upon receiving notice of any proposed changes to legislation, regulation, or LCCP, the CEO will take appropriate legal advice and draw up proposals for changing all relevant company policies, terms and conditions, game rules, and training

3. Managerial Procedures

The CEO, MLRO, and Head of IT & Security will hold weekly meetings (physically or remotely) to discuss all issues regarding company operations. These meetings will also discuss any issues regarding the policies in this document, their implementation, and any suspected breaches.

Should breaches of any of the policies be suspected then appropriate action, as detailed in the policies, will be initiated by the CEO immediately. The CEO, MLRO, and Head of IT & Security will be informed of the breach and the actions taken at the weekly meeting.

Should the breach of policy be considered serious (i.e., warranting a key event report to the Gambling Commission), the CEO will be obliged to call an immediate meeting (physical or remote) with the MLRO and Compliance Lead to inform them of the event.

4. Updating of Policies

The responsibility for ensuring that all company policies and procedures are current lies with the CEO.

The CEO is obliged to keep themselves aware of any legal or regulatory changes by monitoring relevant websites, such as the Gambling Commission and legal advisors, and being in receipt of relevant newsletters and periodicals.

Once news of such legal or regulatory changes is received, the CEO will take appropriate legal advice and draw up proposals for the changing of all relevant company policies, terms and conditions, game rules, and training. These proposals will be presented to the Director for approval and, once gained, implemented.

All such changes will be communicated to the players as per the accompanying company policies and to the staff by email and then by updated training.

5. Ensuring the Business is Protected from Crime and Disorder

This policy has been written on the basis of versus offering remote betting in the United Kingdom for British residents only. Should versus target customers from other jurisdictions, appropriate policies and procedures will be developed to satisfy the requirements of those jurisdictions.

Since versus operates only remotely and accepts money electronically, the issue of counterfeit money does not exist.

5.1 Know Your Customer (KYC)

versus has full Know Your Customer (KYC) controls. Identity verification is provided by Sumsub for UK customers (and Trulioo for any future non-UK customers), with a documented manual review fallback. Every customer is subject to age and identity verification prior to account creation and first deposit.

KYC verification includes:

  • Full legal name verification

  • Date of birth confirmation (must be 18+)

  • Residential address verification

  • Government-issued photo ID (passport, driving licence, national ID)

  • Proof of address (utility bill or bank statement dated within 3 months) where required

  • A selfie capture, with document authenticity and a biometric facial match performed by the verification provider on a server side (the customer’s identity document is compared against the live selfie)

  • PEP and sanctions screening

Where automated verification cannot be completed, the case is referred for manual review before the account is permitted to transact.

5.2 Prohibition on Multiple Accounts

Customers will not be allowed to register multiple accounts under any circumstances nor have an account registered to anything other than a verifiable individual (i.e., no company or family accounts).

Customers found to have multiple accounts will have their accounts closed, funds returned, and will be barred from registering or using an account.

5.3 Training

All senior staff upon joining the company and thereafter annually will receive training on Anti-Money Laundering and associated policies. This will be supplied by online training provider GamCare. Staff will be tested as part of their training and those failing will receive one-to-one training. Repeated failure by a member of staff will be considered a reason for dismissal. Records of training delivered shall be kept by the CEO.

5.4 Illegal Activity

Should it come to the attention of any member of staff that another operator, supplier, business partner, or other staff member is operating in an illegal manner, then they will be bound by their terms of employment to report their suspicions to the CEO.

The CEO will log such an event as well as their decision as to what appropriate action to take (e.g., reporting to the Gambling Commission, NCA, or to the police). This will be carried out in full compliance with the LCCP requirement that licensees must as soon as reasonably practicable provide the Commission with any information that they know relates to or suspect may relate to the commission of an offence under the Gambling Act 2005.

5.5 Collusion

We consider it highly improbable for there to be collusion between our staff and customers. The only potential for cheating/collusion would be for either a manual override of the software to redirect winnings and alter records. This would be a major security breach and would require advanced technical knowledge as well as access to the software code.

All access to systems, when and by whom, is logged and access restricted. Staff will be restricted from setting up accounts.

5.6 Betting Integrity

versus will provide the Gambling Commission with sufficient information to conduct an effective investigation if they suspect that they have any information, from whatever source, that may lead the Gambling Commission to consider making an order to void a bet.

versus will as soon as reasonably practicable provide the Commission with any information from whatever source that they:

  • Know relates to or suspect may relate to the commission of an offence under the Gambling Act 2005, including an offence resulting from a breach of a licence condition or a code provision having the effect of a licence condition

  • Suspect may lead the Commission to consider making an order to void a bet

This applies to all Markets, including non-sporting and novelty event markets. In all cases, this will be done by the CEO filling out and submitting a Key Event notification.

6. Anti-Money Laundering Policy

versus maintains a full Anti-Money Laundering (AML) and Counter-Terrorist Financing policy — including customer due diligence, identity verification, source-of-funds checks, transaction monitoring and suspicious activity reporting — in line with the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002, and the Gambling Commission’s Licensing Conditions and Codes of Practice (LCCP). The full policy and supporting procedures are maintained internally and are made available to the Gambling Commission and relevant authorities on request. Full identity verification (KYC) is required before any betting activity.

7. AML Risk Assessment

versus carries out and maintains a documented AML/CTF risk assessment in line with the LCCP. The detailed risk assessment and supporting risk matrices are maintained internally and made available to the Gambling Commission on request.

8. IT and Physical Security

versus will undergo a third-party annual security audit undertaken by iTech Labs United Kingdom within 6 months of obtaining its operating licence (or within 6 months of commencing operation, subject to agreement from the Commission).

versus will implement an Information Security policy designed to fulfil the requirements of the Remote Technical Standards security requirements, based on the relevant sections of Annex A to the ISO/IEC 27001:2022 standard.

8.1 Personnel Security

All potential employees will be background checked through DBS (Disclosure and Barring Service) and Experian, including:

  • Criminal records check (DBS)

  • Reference verification

  • Identity verification

  • Adverse credit history check

  • Visa status verification (where applicable)

  • Institutional sanctions check

All staff will be trained in the Information Security policy. Any unwanted or faulty equipment must be securely disposed of and have its media wiped or destroyed.

8.2 Digital Security

Key usage policies include:

  • All computer systems will be password protected with logs kept of the identity and timing of any access

  • Access to different systems will be authorised only on a ‘need to use’ basis

  • No removable digital media will be allowed to leave designated areas unless expressly authorised

  • Any alterations to data will only be allowed by designated members of staff

  • All systems data will be encrypted and communications with remote devices encrypted

  • Two-factor authentication required for all administrative access. Account Holder Verification: versus reserves the right to request periodic biometric re-verification (Face ID, Touch ID, fingerprint) to confirm that the individual operating the account is the same person who completed KYC verification. This control mitigates account takeover risk, prevents third-party use of customer accounts, and supports LCCP social responsibility requirements by ensuring only the verified account holder can gamble. Privacy by Design: No biometric data is accessed, transmitted, or stored by versus. Biometric templates remain exclusively on the customer device. versus receives only an approved/rejected outcome from the device operating system. Alternative verification methods are provided for accessibility.

Key Information Security Policies include:

  • IT security policy: Password aging, 2-Factor Authorization, homeworking controls

  • Change management procedures: Separation of development, testing, and deployment

  • Security testing: Regular penetration testing and vulnerability assessments

  • Cryptographic control policies: Cloud computing security measures via AWS

  • IT monitoring policy: Monitoring attacks, excessive usage, and operational workings

  • IT business continuity policy: Data backup, storage procedures, and recovery

8.3 Business Partners & Suppliers

To ensure that all business partners and suppliers are trustworthy and reputable, versus will conduct due diligence on any companies that become suppliers or business partners.

versus will require all suppliers and business partners to give contractual undertakings that:

  • Require them to conduct themselves as if bound by the same licence conditions and codes of practice as versus

  • Oblige them to provide information to versus as reasonably required for Commission compliance

  • Enable versus to terminate the contract promptly if the third party breaches contract or acts inconsistently with the licensing objectives

9. Ensuring Gambling is Conducted in a Fair and Open Way

9.1 Financial Resources

Financial risks to versus are from betting losses and unexpected operating costs. versus has implemented the following controls:

  • Operational reserve and contingency buffer calibrated to small-scale operating profile

  • Real-time liability monitoring with automatic betting restrictions when thresholds approached

  • Per-outcome liability caps (maximum £50,000)

  • Maximum payout limit of £50,000 per bet

  • Maximum stake per bet: £1,000

How versus earns its income: versus offers fixed-odds bets. The odds for every outcome are set by versus and displayed to the customer before every prediction is placed, together with the potential return, in accordance with the Commission’s transparency requirements. versus charges the customer a fee of 1.5% per prediction, capped at a maximum of £20 per prediction, which is disclosed to the customer before each prediction is confirmed. No other charge is applied to placing or settling a prediction.

Customer Fund Protection:

versus holds customer funds in a designated local UK bank account, held separately from operating funds. Funds are classified as Not Protected under the Gambling Commission’s customer fund protection requirements. Customers are clearly informed of the applicable protection level in the Terms and Conditions and on the deposit page.

9.2 Terms & Conditions

versus Terms & Conditions are provided in writing to each customer, in a manner which requires the customer to acknowledge acceptance of the terms and does not permit the customer to place their first deposit or bet until they have accepted the terms.

The Terms & Conditions will be displayed prominently on the versus app on their own clearly labelled page. They include the disclosure of the customer fee (1.5% per prediction, capped at £20), the odds and potential return shown before each prediction, and each Market’s resolution criteria.

The Terms & Conditions have been reviewed internally by versus for compliance with the Consumer Rights Act 2015. A full independent legal review will be completed prior to relying on them.

Any material changes to the Terms & Conditions will be emailed to all customers and highlighted on the app. Customers will be required to acknowledge receipt of revised Terms before continuing to bet.

versus will make available to all customers:

  • A player’s guide to each gambling opportunity made available (the “Game Rules”), including how each Market is resolved

  • Such additional information relating to available gambling as the Commission publishes

9.3 Notice of Licensing

versus will display on every app screen from which customers are able to access gambling facilities a statement that they are licensed and regulated by the Gambling Commission, together with the operating licence number and a link to the Commission’s public register.

9.4 Incentives, Bonuses & Rewards

versus operates a limited set of incentives. Where any incentive, bonus, voucher, referral reward or campaign offer is made, versus ensures that:

  • Circumstances and conditions are clearly set out and readily accessible

  • All marketing communications comply with the CAP and BCAP codes

  • Terms and conditions are available for the full duration of the promotion

  • All marketing is signed off by the CEO to confirm LCCP compliance

The following incentives may operate:

  • Referrals (“Share & Earn”): customers may invite others using a personal referral link. A referral reward (which may include a sign-up bonus and/or an ongoing reward) is credited only after the invited customer places their first qualifying prediction.

  • Vouchers: single-use codes that may grant fee credit (offsetting the customer fee) or wallet credit. Vouchers may expire, require a verified account, and cannot be redeemed during self-exclusion.

  • Loyalty / achievement rewards and gamification: customers may earn badges, experience points and standings on a profit leaderboard. Where any monetary reward is granted, it is treated as promotional credit subject to the terms below unless expressly stated to be withdrawable.

Separation of promotional money (AML and consumer control): all bonus, voucher (wallet-credit), referral, campaign and achievement credits are held in a ledger separate from the customer’s withdrawable cash balance. Promotional money is not cash, cannot be withdrawn, and may only be used to place predictions. Only deposited/withdrawable cash can be withdrawn. Promotional credits may carry qualifying conditions and expiry. This separation prevents promotional value from being used to launder funds and ensures customers are not misled as to which funds are withdrawable.

9.5 Cheating

versus will notify the Gambling Commission of any information which causes it to know or suspect that there has been interference or attempted interference with any event (sporting or non-sporting) they have offered betting propositions on.

10. Complaints Procedure

The versus Complaints Procedure will be published on a specific page on the app and will be referred to in the welcome email sent to new registered customers. The Procedure will also be included in the Terms & Conditions.

Definitions:

  • A ‘complaint’ means a complaint about any aspect of the licensee’s conduct of the licensed activities

  • A ‘dispute’ is any complaint which relates to the outcome of the complainant’s gambling transaction and is not resolved at the first stage of the complaints procedure

versus is registered with Independent Betting Adjudication Service Ltd (IBAS), who provide third-party arbitration for any unresolved complaints or disputes.

In all instances, it will be made clear to the customer the contact details of both versus and IBAS and that the service is free and without restriction.

Any outcome of a complaint/dispute which is referred to IBAS will be reported to the Gambling Commission as a key event within 5 working days.

10.1 Complaints Process

  • If you wish to make a complaint, contact customer support by email at support@versusapp.com

  • If your complaint is not resolved by Customer Support, you can ask for it to be escalated to the CEO

  • You will be given the name and status of the person to whom the complaint has been referred

  • The CEO will contact you with a response and proposed solution within 72 hours

  • If you are still unhappy, you may refer your complaint to IBAS, whose decision versus agrees to be bound by

  • You can register with IBAS and submit a complaint at: https://www.ibas-uk.com/consumers/how-to-raise-a-dispute/

  • IBAS provides a free-of-charge service and rules on complaints about betting and gaming transactions

Records of all complaints and their resolution will be kept in a Complaints Register.

Contact Details:

Contact

Details

Customer Support

support@versusapp.com or In-App Support

Complaints

complaints@versusapp.com

MLRO

mlro@versusapp.com

ADR Provider

IBAS — www.ibas-uk.com

11. Protecting Children and Vulnerable Persons

11.1 Preventing Under-Age Play

versus will have in place systems to ensure that no one underage is able to gamble on its app. versus will use the KYC and age verification services of Sumsub (and Trulioo for any future non-UK customers). When customers register to join the site, before gambling or depositing funds, the system will verify a customer’s age through interrogation of third-party databases.

Upon registering, customers must declare by ticking a box that they are 18+ and agree to never divulge their passwords to under-aged people, agree to the Game Rules and Terms & Conditions, and understand the self-exclusion procedures.

The app will clearly state:

  • Gambling by anyone under 18 is illegal

  • Applications for accounts by under 18-year-olds will be prohibited and any predictions struck by them will be voided

  • Any customer who allows their account to be used by an underage player will be permanently barred

Should a customer be found to be under-aged at any time, all monies in their account minus winnings will be returned. No winnings will be paid to any under-aged customers.

11.2 Marketing

All marketing material produced by versus will abide by CAP and BCAP Codes and will not include any person below the age of 25 or have any marketing directed at those who are under-aged.

versus will follow the Gambling Industry Code for Socially Responsible Advertising (IGRG Code) and have regard to CAP and BCAP guidance on gambling advertisements.

  • No marketing communications will include a child or young person

  • No-one who is or seems to be under 25 years old will be featured in gambling advertisements

  • All marketing will be signed off by the CEO

11.3 Preventing Play by Vulnerable People

Being a remote operator, we have no knowledge of the mental state of our customers. Should staff suspect from either account activity or communication that a customer’s judgement is impaired, they shall inform the customer and temporarily (24 hours) freeze their account, then re-contact them to discuss the future of their account.

The versus app will have a page entitled ‘Responsible Gambling’ / ‘Safety Play’ which will detail:

  • Symptoms of problem gambling

  • Contact details for GAMSTOP, GamCare and BeGambleAware

  • National Gambling Helpline number (0808 8020 133)

  • Information on deposit limits and self-exclusion options

  • BetBlocker signposting

11.4 Deposit and Loss Limits

Upon registering, customers will be presented with deposit, spend, and loss limits as the default option during the first deposit process, in compliance with RTS 12E. Customers must actively choose to either set a limit or confirm they do not wish to set one at this time. Limits can be set for 24 hours, 7 days, or one month. Customers will be prompted annually to review their limits.

If a customer-led limit is increased at the customer’s request, this will only be applied after an automated 24-hour cooling-off period has elapsed and once the customer has confirmed their request at the end of this period. Where a customer raises a limit repeatedly within a short period, a short additional cool-off may be applied.

The customer accounts section of the app will show a betting history and provide running totals of stakes and winnings/losses.

11.5 Time-Out Facility

Customers will have the option of initiating a ‘time out’ facility where they can block themselves from the app. The app offers preset time-outs of:

  • 1 day

  • 3 days

  • 7 days

Such other period as the customer may reasonably request, up to 6 weeks, can be arranged via customer support.

11.6 Customer Interaction Strategy

versus follows the UKGC Identify–Act–Evaluate framework for customer interaction:

Identify:

All customer accounts are monitored using automated and manual systems for indicators of harm including: significant increases in deposit frequency or amounts; chasing losses (increasing stakes after losing periods); erratic betting patterns or sudden changes in gambling activity; extended session durations or gambling at unusual hours; use of multiple payment methods in quick succession; frequent changes to deposit limits (especially increases); customer communications expressing distress or financial difficulty; patterns suggesting third-party use of the account. Significant changes trigger the stepped customer intervention process below.

Act:

Stepped Action — Level 1 (Early indicators): Automated responsible gambling messaging and signposting to deposit limits and reality checks. Level 2 (Moderate concern): Direct customer contact by trained staff, completion of a customer interaction report, provision of GamCare (0808 8020 133), GAMSTOP, and National Problem Gambling Helpline information. Level 3 (Significant concern): Account restrictions applied (reduced deposit limits, cooling-off period imposed), MLRO review, formal welfare assessment. Level 4 (Acute concern): Immediate account suspension, mandatory self-exclusion recommendation, referral to support services.

Evaluate:

versus will review each interaction and its impact on the customer, assessing the effectiveness of the approach taken. Outcomes are reviewed quarterly by the CEO and MLRO and used to refine monitoring triggers and intervention procedures, in accordance with the Commission’s Customer Interaction Guidance for Remote Gambling Licensees.

11.7 Self-Exclusion and GAMSTOP

versus will offer its own self-exclusion facility enabling customers to restrict access to their account for a period from 6 months up to 5 years, as well as a permanent self-exclusion option. Any exclusion may be extended by contacting customer services.

Customers can self-exclude using the self-exclusion section under “Settings, Safety Play” or by emailing support@versusapp.com or by starting an In-App Support chat.

Upon self-exclusion, versus will:

  • Close the customer’s account after confirmation

  • Return any monies in the account to the customer

  • Encourage the customer to extend their self-exclusion via GAMSTOP

  • Remove the customer from all marketing mailing lists within 2 days

  • Send confirmation email with contact details of problem gambling help centres

During any period of self-exclusion, it will not be possible for accounts to be re-opened. versus will take all possible steps to prevent new accounts being opened by the customer.

If the customer has not sought to reactivate their account after the self-exclusion period expires, the self-exclusion will stay in place for a minimum of another 7 years.

GAMSTOP:

versus is part of the multi-operator self-exclusion scheme GAMSTOP. The customer’s GAMSTOP registration status is checked at login and customers are blocked where registered. Customers can register at: https://www.gamstop.co.uk

11.8 Contribution to Research & Education

versus will pay mandatory levy contributions at a rate of 1.1% of its Gross Gambling Yield (GGY), in line with the statutory gambling levy introduced under the Gambling Levy Regulations 2025 (or any successor legislation).

11.9 Employment Policy

Nobody (incl. Interns) under the age of 18 shall be employed by versus.

Declaration

I confirm that these Policies and Procedures have been approved and that versus Inc. (trading as versus) is committed to full compliance with all applicable legislation, regulations, and the Gambling Commission’s Licence Conditions and Codes of Practice.

Field

Details

Name

Dr. Philip Blazdell (Head of Regulatory Compliance and MLRO)

Position

Head of Regulatory Compliance & MLRO

Date

June 2026

Signature

David Calvin Worldorf

— End of Document —

— End of Policies & Procedures — · versus Inc.

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