Compliance & Responsible Gaming
At NGH, our commitment to compliance and responsible gaming lies at the core of our values and business philosophy. Our approach encompasses adherence to international standards, proactive risk management, and a dedication to fostering a culture of integrity, transparency, and ethical conduct.
We uphold the highest standards in corporate governance, with a zero-tolerance policy towards corruption and regulatory violations, ensuring that every aspect of our operations aligns with both legal requirements and our strong ethical framework.
Regulatory & Corporate Governance
Central to our Environmental, Social, and Governance (ESG) strategy is a robust culture of corporate governance and regulatory compliance. Our operations are monitored and controlled by the collective expertise of our Board of Directors, Advisory Board, management team, internal audit, and compliance teams. This collaboration positions us as a benchmark for best practices within the gaming investment sector.
Our culture of compliance and integrity is underpinned by values of ethics, respect for the law, transparency, and honesty, which are fundamental to our Code of Conduct. We strictly prohibit corruption and unethical behavior, fostering a safe and fair environment for all stakeholders. This approach is reinforced by our Anti-Corruption Policy and is mandatory for every member of our team, ensuring that our activities comply with local and international laws in all the regions where we operate.
Compliance Standards
NGH adheres to rigorous compliance standards, reinforced through collaborations with top global law firms, such as Jones Day. By aligning with leading regulatory and legal experts, we maintain the highest levels of regulatory adherence, transparency, and corporate accountability. Our comprehensive compliance strategy includes:
- Global Regulatory Adherence: We ensure that each portfolio company fully complies with the regulations in every jurisdiction where they operate, upholding consumer protection and fair practices.
- Anti-Corruption Policy: We strictly prohibit any form of bribery or corruption, as outlined in our Anti-Corruption Policy. This includes any offers of payments, gifts, or favors intended to influence business decisions or gain improper advantages.
- Ethical Operations: By embedding ethical standards into every aspect of our business, we promote integrity, transparency, and respect for the law throughout our portfolio.
Responsible Gaming Initiatives
As a socially responsible organization, NGH promotes responsible gaming practices across our investments. We actively implement measures to create safe, enjoyable experiences for all players, ensuring they have access to resources and support for informed decision-making.
- Player Education and Awareness: Through our portfolio companies, we provide accessible resources on responsible gaming, helping players understand the risks and make responsible choices.
- Player Protection Tools: Our partners implement tools such as self-exclusion, spending limits, and time-out options to enable players to manage their gaming behaviors effectively.
- Supportive Partnerships: We work with recognized support organizations to ensure players have access to help and resources when needed, fostering a healthier gaming environment.
Audit & Risk Management
Risk management is central to safeguarding the integrity and transparency of our operations. NGH follows stringent auditing procedures and applies the highest standards in anti-money laundering (AML), cybersecurity, and crime prevention. This proactive approach includes:
- Internal & External Audits: Routine audits, both internal and third-party, ensure compliance and operational integrity across our portfolio, identifying areas for continual improvement.
- Anti-Money Laundering (AML) Standards: We implement robust AML protocols to prevent and detect financial misconduct, maintaining compliance with global regulatory standards.
Cybersecurity & Privacy
Our cybersecurity and privacy program is built to safeguard critical data, prevent fraud, and ensure continuity and resilience across all operations. The program focuses on four main objectives:
- Fraud prevention;
- Protection of data processes;
- Prevention of data leaks;
- Assurance of business continuity and recovery.
To achieve these objectives, we implement a suite of advanced cybersecurity measures complemented by regular drills and exercises, ensuring our team is prepared for any adverse situations. Key elements of our cybersecurity infrastructure include:
- Network Security: We employ state-of-the-art firewalls, an Intrusion Detection System (IDS), and a Zero Trust architecture, securing our most critical operational sectors. Access controls are strictly managed, with a user profile categorization system that follows a “least privilege” model to minimize security risks.
- Endpoint Protection: We leverage leading Endpoint Detection and Response (EDR) solutions to monitor for and respond to anomalous behaviors. These systems automatically execute pre-defined playbooks for each situation, enabling rapid and effective action to contain threats before they spread.
- Proactive Monitoring and Detection: Our security infrastructure includes continuous monitoring systems to detect unusual activities in real-time. These systems are supported by a highly skilled, continuously trained team that stays current with the latest cybersecurity trends and threats.
- Regular Audits and Assessments: To maintain robust security, we conduct ongoing audits of servers, applications, and any new additions to our technology ecosystem. We also engage third-party auditors to review critical projects, with consistently positive results confirming our adherence to the highest standards.
Crime Prevention Model (CPM)
We have developed a robust Crime Prevention Model (CPM) based on best practices and high-level national and international standards. Regularly analyzed by external auditors, our CPM has been validated for its adequacy and operational effectiveness, confirming our ability to prevent and detect potential criminal activity across all business units and corporate departments. Our CPM is specifically designed to identify and mitigate the primary criminal risks facing our organization, with a strong focus on preventing corruption. The model is structured to address the following key risk areas:
- Corruption in business affairs;
- Illegal funding of political parties;
- Bribery;
- Influence peddling;
- Money laundering;
- Terrorism financing.
To manage these risks, we have developed a comprehensive Criminal Risks and Controls Matrix, which provides a framework for assessing, monitoring, and controlling these risks across the organization. The matrix includes operational controls specifically aligned with each identified risk, ensuring the CPM’s effectiveness in preventing and detecting criminal acts in line with our risk tolerance and aversion limits.
Our Crime Prevention Model is supported by an Assessment Model, which classifies and evaluates criminal risks based on their likelihood and potential impact. This allows us to focus control measures on the most critical areas, maintaining our commitment to transparency, compliance, and integrity.
By implementing these rigorous standards, we maintain a proactive stance on crime prevention, ensuring that our operations are secure, transparent, and in full alignment with our ethical principles and legal obligations.
Anti-Corruption Policy
At NGH, we recognize that fraud and corruption severely hinder the fair development of society. In alignment with this view, our Anti-Corruption Policy enforces a strict prohibition on all forms of corruption and bribery, which we define as any tangible or intangible value offered, promised, paid, authorized, or given to a third party to unlawfully influence a business decision or gain improper advantage in our operations. Bribes may include, but are not limited to, payments, gifts, travel, entertainment, job offers, valuable contacts, and forgiveness of debts or donations. Our Code of Conduct outlines key principles that reinforce our anti-corruption stance and ensure ethical conduct at all levels:
- Promoting integrity;
- Business courtesies;
- Conflicts of interest;
- Facilitation payments;
- Fair competition;
- Relationships with third parties and intermediaries;
- Money laundering prevention;
- Transparency assurance;
- Bribery prohibition;
- Contributions to NGOs;
- Confidential information handling;
- Accurate transaction records;
- Corruption between individuals;
- Disclosure obligations.
We foster a culture of integrity across our organization, working closely with our suppliers and partners to uphold high ethical standards. Through continuous training and reinforcement of our Code of Conduct, we actively work to prevent unlawful conduct and promote ethical decision-making.
Business Courtesies and Gifts
Our policy on business courtesies, including gifts, invitations, and events, adheres strictly to internal guidelines. These courtesies are never intended to influence the objectivity of external parties nor to secure any improper business benefit. We ensure that all gifts and hospitality are appropriate and aligned with our policy, safeguarding the transparency and integrity of our relationships.
Employee Conduct and External Activities
We respect employees’ participation in external activities as long as these are within legal bounds and do not conflict with their responsibilities to our organization. All external engagements must comply with applicable laws and cannot be used to facilitate corrupt practices.
Zero Tolerance for Unofficial Payments
We strictly prohibit unofficial or improper payments to public officials for the purpose of obtaining licenses, certifications, or other services to which we are legitimately entitled through regular procedures. Our policy ensures a transparent and ethical approach to all interactions with government entities and public servants.
Commitment to Fair Competition and Social Responsibility
We are fully committed to competing fairly, upholding free market principles that benefit consumers, users, and society at large. Our partnerships with non-profit organizations are conducted with mutual benefit and transparency.
Professional Ethics and Anti-Corruption Standards in Partnerships
Our employees and managers maintain ethical and professional relationships with customers, partners, and suppliers. We incorporate strict anti-corruption clauses in our contracts, ensuring that all parties uphold these standards.
At NGH, our commitment to compliance, responsible gaming, and ethical business practices is foundational to our success. By integrating rigorous governance standards, responsible gaming measures, and a proactive approach to risk management, we maintain a secure, transparent, and ethical environment that benefits all our stakeholders. Through these practices, we continue to lead in the gaming sector with a commitment to accountability and integrity.