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Advertising prohibited: Direct or indirect marketing communication regarding betting on radio and television, newspapers, magazines, outdoor media, streaming services, podcasts, social networks, video platforms, apps, websites, blogs, forums, search engines and other internet environments is prohibited.

Messaging and targeted advertising: The restriction also extends to instant messaging, SMS, email, notifications, advertising automatically targeted by algorithms, telemarketing – which shows ads again to people who have already been exposed to certain content – and profiling based on user behaviour.

Other means of dissemination: The prohibition includes advertising in electronic games and esports, sports uniforms and equipment, public transport and affiliate content, tipsters, comparison sites and other paid intermediaries.

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“Our investigation revealed certain clients had allowed for Evolution’s game content to be provided on their online gaming websites in clear violation of their contracts, which expressly prohibited such game play in specified regions,” the report states.

Spectrum blames Evolution’s “ineffective complaince procedures”, noting these activities appeared to go undetected by the supplier.

“In our judgment, Evolution’s ineffective compliance procesures have allowed these situations to develop and therefore need prompt reevaluation and enhancement in order to comply fully with the terms of the contracts,” the report reads.

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“People look primarily at the instances where things go wrong for players; of course, every single one of those is one too many. But they don’t tend to look at the large number of people enjoying gambling.”

Holland Casino was one of the first operators out of the gate when the newly-minted market opened in 2021, and while they don’t have the position they occupied in those early days, the company’s online offering is healthy. When they launched online, Petra says “we were very well known for – and are very well known for – responsible gaming.

“That was the reason why we joined [online as well as land-based]. But we were a full brick-and-mortar company so it took us some time to prepare for that market. In the beginning, the market share was of course higher because you only had 10 operators and we had a very well-known brand name, but now the market is much bigger and you have operators more specialised in sports betting and things like that. We have dropped down a bit.”