Wednesday, August 09, 2006

On 28 July 2006 the Compliance Committee of eCommerce and Online Gaming
Regulation and Assurance, made up of Mr. W. Galston OBE (Chairman) , Mr. F.
Catania and Mr. M.Hirst OBE, all independent directors of the organization,
considered all the facts regarding an incident in which complaints were
received concerning search engine optimisation practices being conducted by
the Jackpot Factory group. The Committee received a report of an independent
and on-site investigation which had been carried out by external auditors.
This covered the circumstances surrounding the issue, its causes and effects
and the remedial actions taken by the company.
The Committee findings are that:

1) The nature and tenor of the Jackpot Factory search engine optimisation
project was totally unacceptable because of the fictitious and misleading
scenarios it portrayed. This had resulted in widespread public disapproval
of the campaign.

2) However, there was no evidence to show that any individual or group of
individuals were harmed or persuaded to indulge in potentially harmful
behaviour by the campaign, which represented an important mitigating factor.

3) Similarly, there is no evidence to suggest that Jackpot Factory
management had any deliberate intention to encourage vulnerable persons to
participate in gambling activities at group casinos

4) The investigating team report indicates that it is satisfied that the
Jackpot Factory claim to have outsourced the project initially is correct.
However, the report finds, and Jackpot Factory management conceded that the
company's supervision of the project was inadequate.

5) The report confirms that internal disciplinary action taken by the
company against those responsible was appropriate.

6) The Committee also considered the more positive aspects of the case and
in particular the actions of Jackpot Factory in the immediate aftermath of
the issue coming to public attention. On two occasions the company admitted
fault in the matter and offered public apologies.

Management backed this up by re-directing company resources and mounting a
committed and energetic exercise to track down every element of the campaign
that could be found in order to remove it, at the same time urging the
public to report any elements discovered so that these could be addressed.

7) Jackpot Factory management cooperated fully with the independent
investigation team, presenting verbal and documentary evidence without
reserve to assist in its investigations.

8) Jackpot Factory management has since deployed control improvements in its
systems as suggested by the investigation team, which will guard against any
repetition of this unfortunate incident. Processes are now in place to
ensure that any further material that may surface as a result of this
campaign is dealt with on a timely basis.

9) Evidence was produced showing that the damage to business and reputation
suffered by Jackpot Factory was substantial, as a consequence of public
disapproval and the suspension of the Play It Safe seal.

10) Before the incident, Jackpot Factory had a solid reputation for
compliance with all eCOGRA standards and requirements.

Having considered all of the above, the Compliance Committee has made the
following ruling:

The suspension of the "Play It Safe" seal is lifted, but Jackpot Factory
will be subjected to increased eCOGRA monitoring to ensure compliance with
the new content code of practice. This is to ensure that all remaining
traces of the campaign are removed wherever this is possible. The Compliance
Committee is aware of the existence of inactive search engine links, but is
satisfied that these do not provide access to any offensive material. The
removal of this type of link is solely under the control of the search
engines.

The Committee wishes to thank all those representing players' interests for
their comments during the initial complaints and throughout the
investigation. It also notes that the investigation team received the full
cooperation of the Jackpot Factory management and is satisfied that they
have shown their determination that this should not happen again.

The goal of eCOGRA in incidents such as this is to remove the immediate
cause and potential for harm as quickly as possible, and then through fair
and factual investigation isolate the reasons and ensure that systems are in
place to guard against any repetition. These objectives have, in the opinion
of this Committee, been met.