Roobet on behalf of Raw Entertainment B.V, Reg No157205, having its registered address at Fransche Bloemweg 4, Curacao, licensed to conduct online gaming operations by the Government of Curacao under license 8048/JAZ (“Roobet”) mandates strict adherence by its marketing and affiliated partners (the “Affiliate”) to the requirements outlined hereunder. Irrespective of the cause leading to any breaches including negligence or human errors will result in termination of business relationship at the sole discretion of Roobet. When promoting Roobet, the Affiliate shall at all times follow:

• any established guidance issued by CEG (Curacao e-gaming) regarding responsible gambling and code of conduct;
• the international standards of good industry practice applicable to advertising and marketing of gambling products and services;
• the applicable terms and conditions set out by Roobet at the onboarding stage and any updates forthwith; and
• the marketing age restriction guidelines, social responsibility and responsible gambling guidelines provided by Roobet. 

1.    Any marketing material used must be provided by, or approved by, Roobet in advance of distribution or publication. Non adherence shall constitute grounds for termination and will be required to be taken down at the earliest available opportunity. Roobet reserves the right to fully pursue removal of unapproved material. 

2.     Roobet must be notified in advance of the media channels, social platforms, locations, where such material will be distributed or published including web addresses, landing pages, content or media exposure, brand displays, player destinations and social media).

3.     Customers must be able to refer to the relevant terms and conditions governing that promotion.  

4.     Any marketing conducted on behalf of Roobet, must make clear that the Affiliate works independently of Roobet. 

5.     Marketing material promoted must not represent gambling as anything other than entertainment and at no point should it be misconstrued as a means of income. 

6.    Any wagers made must never be represented as generating guaranteed winnings, condoning or encouraging gambling behaviour that is socially irresponsible or could lead to financial, social or emotional harm. 

7.     Marketing communications must be socially responsible, with special regard being given to the need to protect children, young persons and other vulnerable persons from being harmed or exploited.  

8.     Social media marketing (Twitter, Instagram or other) must include 18+ on the bio page (19+ for profiles specifically targeting Ontario users).

9.     Marketing material featuring the Roobet brand must not be placed on any website providing unauthorised access to copyrighted content. 

10.   Any breach of these marketing and advertising code of conduct shall be deemed as a material breach which may result in immediate termination of our business relationship. Nevertheless, if the breach can be rectified, Roobet will provide the Affiliate with a notice period of 48 hours to rectify any breach or potential breach before terminating the relationship. 

Marketing Age Restriction Guidelines

Underage protection and targeted marketing 

1.     Marketing material must not feature any person or figure under the age of 18 in any circumstances.

2.     Marketing material must not promote influencers,  sports players, and celebrities who are under the age of 18.

3.     No material should be redirected to customers under the age of 18 by being placed in media for that group or any underage category (e.g. younger children or teenagers). 

4.     The content of marketing material: 

• must not use themes or content associated with particular appeal to children; such as nursery rhymes, children’s characters or stories; 
• should avoid the use of colourful and exaggerated animated characters; and 
•  should avoid styles or approaches likely to have particular salience for people under the age of 18. 

5.     Caution should be exercised should there be any ambiguity regarding the audience composition where marketing or promotional material will appear. For the avoidance of any doubt, in such cases clarity shall be obtained from Roobet. 

6.     Under no circumstances should direct marketing be conducted to individuals who are under the legal age in targeted jurisdiction. 

7.     The appropriate age banner of 18+ is located on every material used. 

8.    Use of social responsibility messages such as “When the fun stops, stop” and/or  “www.begambleaware.org” to be made visible to potential customers.

Social Responsibility Guidelines

1.     Marketing material should take into consideration any local cultural and religious sensitivities that may cause offence to the targeted audience. 

2.     Roobet will under no circumstance condone any form of discrimination, including that based upon race, national origin, religion, gender, age, disability, or sexual orientation. 

3.     Marketing communications should not appear to promote, incite violent, unlawful or antisocial behaviour. Roobet will endeavour to ensure that it continuously disassociates itself with any illegal activity of any kind. 

4.     Marketing communications should not misrepresent the entertainment obtained from gambling as a professional career, an alternative to employment, as a financial investment or as a means to make a regular income.

5.     Gambling must never be portrayed as a means to solve personal or financial problems by means of guaranteed wins or manipulating the outcome in any way.

6.     Advertising on pornographic sites, sexualised or otherwise indecent images, together with images objectifying women will not be approved by Roobet.

7.     Influencers, ambassadors or celebrities should not suggest that betting has contributed to their success, chiefly if these fall outside of the coverage of existing license. 

Responsible Gambling

1.     Marketing should not portray excessive or socially irresponsible participation by individuals of legal age or which could lead to financial, social or emotional harm. 

2.     Marketing and affiliated partners shall ensure that known self excluded customers are not directly targeted.

3.     Marketing communications must not suggest that gambling  should take precedence over one’s own priority in life such as children, family, friends, financial commitments, etc.

These Guidelines were last amended on the 11th of October 2022.