Regulatory Framework for Offenses and Penalties Rev. No. 3

I-Gaming Licensing and Regulation Group Electronic Gaming Licensing Department REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Revision No.: 3 Effectivity: a6 NOV 2025

Page No. Page 1 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity NOV O6 2025 EXECUTIVE SUMMARY This Regulatory Framework for Offenses and Penalties shall govern and administer offenses/violations attributed to the conduct of PAGCOR licensed Operators, accredited Gaming System Administrators (GSA), Business-to-Business (B2B) Providers (i .e. Gaming Affiliates and Support Service Providers), Contractees or Licensees of Integrated Resorts. This Regulatory Framework shall form part of the Gaming License issued by PAGCOR to a qualified Operator for the establishment and operation of a gaming venue and of the terms and conditions governing the accreditation of GSA and B2B Providers for the operation of game offerings duly regulated and sanctioned by PAGCOR, i.e., traditional bingo games, electronic bingo games, electronic casino games, sports betting, specialty games, online Poker games, numeric games or any suite of games that may be allowed by PAGCOR in the future along with the operation of online gaming platforms by Licensees. The provisions of this Regulatory Framework shall apply prospectively and shall repeal previous issuances, memoranda , orders, rules and regulations covering the offenses and penalties for electronic gaming operations. By virtue of the foregoing , the provisions stated herein are laid down as the Regulatory Framework for Offenses and Penalties for Electronic Gaming Operations.

Page No. Page 2 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity L 3 NOV 2J25 TABLE OF CONTENTS PAGE I. GENERAL GUIDELINES 3 II. TABLE OF OFFENSES AND CORRESPONDING PENALTIES 4 Ill. ASSESSMENT OF PENALTIES 10 IV. MISCELLANEOUS PROVISIONS 11

Page No. Page 3 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity I. GENERAL GUIDELINES (a) Based on the nature of the offen~e, each offense will correspond to penalty/fine. Penalties will be collected from the Operator/lR Licensee/GSA/Contractee/B2B Provider (Authorized Entity) or deducted from the Performance Cash Deposit posted by the erring Authorized Entity, as may be determined by PAGCOR. (b) In the event of non-compliance with the guidelines prescribed in the regulatory frameworks and any subsequent amendment/addendum thereto, the EGLD shall issue a "Show Cause" to the concerned Authorized Entity requiring it to provide an explanation and/or comply within fifteen (15) days, unless otherwise stated, from receipt of the same except for cases that cannot be complied with/ addressed, as determined by the EGLD. (c) If the Authorized Entity, is found to be non-compliant or the Authorized Entity fails to comply with Item (b) above, corresponding penalty shall be imposed as outlined under this regulatory framework. The EGLD shall issue an electronic "Notice of Non-compliance" or "Imposition of Penalty" to the said erring entity. (d) The Operator's privilege to operate a gaming venue may be revoked pursuant to the provisions stated in the Regulatory Framework for the Issuance of Gaming License for the Establishment of Gaming Venue. (e) The accreditation or privilege of GSAs and/or B2B Providers to maintain and to provide the Electronic Gaming System (EGS), Online Gaming Platform (OGP) and/or Support Services may be revoked depending on the severity of the infraction and/or the attending circumstances thereof. The revocation of accreditation, which may cause the forfeiture of the

Page No. Page 4 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity CSNOY 225 Performance Cash Deposit (PCD), shall be determined by the EGLD and subject to approval by the PAGCOR's Board of Directors. (f) Suspension of operation of Authorized Entity may be imposed, as determined by the EGLD, subject to the approval of PAGCOR's Chairman and CEO. II. TABLE OF OFFENSES AND CORRESPONDING PENALTIES (a) A written warning shall be issued to the Gaming Venue Operator for the first offense committed for each specific violation. (b) Gaming Venue Operators (for second and subsequent offenses): Item / Description Penalty / Fine Remarks Allowing prohibited individual and Refer to Gaming Licensing and unregistered player to stay and Development Department's play in the gaming venue. Responsible Gaming Code of Practice. Late remittance and/or non- 25% of the total Penalty shall be imposed on a per remittance of amount due to amount due for tra n saction basis (per offense). PAGCOR (i.e., PAGCOR Share remittance Continuous non-remittance of and/or Audit Fee) within the PAGCOR Share as evaluated by prescribed remittance schedule for the EGLD may be subject to accumulated amount of suspension or revocation of PhP10,000.00 and above. License. Non-payment of player's winnings. PhP100,000.00 or Players Winnings shall include amount of the winnings on raffle draws / jackpots. winnings, whichever is lower

Page No. Page 5 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity [ S~GY 2J25 Item / Description Penalty / Fine Remarks Making any unauthorized PhP100,000.00 or deduction from winnings or amount of the redeemed balances of players. winnings, whichever is lower Unauthorized suspension of Penalty is per day of offense. operations without just cause Notwithstanding the penalties (including failure to resume imposed for each day of offense, operations after the continuous unauthorized approved/allowed period of non- suspension of operations, as operation ). PhPS0,000.00 defined under Article XIV (Temporary Suspension and Closure of Gaming Venue) of the Regulatory Framework for Gaming Venue Operations, may cause the revocation of the License. Implementation of brand I suite of games without prior approval from PhPS0,000.00 the EGLD. Failure to restore or update the Penalty is for every month of non- Performance Cash Deposit (PCD) compliance, i.e. 30 days. at its original level within thirty (30) PhPS0,000.00 calendar days from receipt of Pro-rated on a daily basis. notice. Unauthorized operation of the PhP200,000.00 gaming venue. Non-compliance with the manual If documents pertain to gaming PhPB0,000.00 and/or electronic submission of venue, the penalty of PhPB0,000.00

Page No. Page 6 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity [ :; /~Ov 2]25 Item / Description Penalty/ Fine Remarks documentary requirements on shall be imposed on a per gaming time . venue basis. Failure to submit the annual Penalty is per year of offense. PhP100,000.00 Business Permit. Failure to submit on time the PhP30,000.00 renewal application. Failure to notify EGLD within 30 days from the occurrence of the PhP30,000.00 change in composition of Board members. 95% or less operational electronic Penalty is for every month of non- gaming terminals or machines for a compliance, i.e. 30 days. PhP30,000.00 period of seven (7) consecutive days. Pro-rated on a daily basis. Non-compliance with the Penalty is for every month of non- installation of the required compliance, i.e. 30 days. PhP30,000.00 minimum number of electronic gaming terminals or machines Pro-rated on a daily basis. Unauthorized reduction / addition / transfer / movement of terminals PhP50,000.00 without prior approval from PAGCOR. Unauthorized operation of electronic gaming terminals I PhP50,000.00 machines without prior notification to EGLD. Portable gaming terminal/s is/are PhP100,000.00 found outside the gaming venue. '

Page No. Page 7 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity Item / Description Penalty / Fine Remarks Procurement of gaming equipment and paraphernalia without prior PhP200,000 .00 approval from concerned PAGCOR Evaluating Departments. Failure to maintain gaming venue The penalty shall be on a per standards on CCTV requirements PhP20,000.00 offense basis. and guidelines. Implementation of marketing and/or promotions, including any PhP20,000.00 form of advertisements, without prior approval from PAGCOR. Any operational or procedural violation not covered by the above Ph P30, 000. 00 Iis ted offe nse_, c:: as dele rmin b the EGLD. 1 (c) Gaming System Administrators (GSA), IR Licensees, Contractees, and Business-To-Business (B2B) Providers: Violation Penalty Unauthorized operation of electronic gaming system, including online gaming platform websites, online PhP500,000.00 applications, and/or other channels. Failure to integrate with PAGCOR's third party audit PhP500,000.00 platform within the prescribed period. Non-adherence to the prescribed processes and PhP300,000.00 operational standards as provided for in any of the applicable regulatory frameworks.

Page No. Page 8 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity Violation Penalty Implementation of game parameter settings other than PhP300,000.00 the PAGCOR-approved settings, e.g., min/max bet and RTP %. Allowing player registration, accepting bets, or sales PhP1 ,000,000.00 outside the Philippines. Implementation of marketing promotions, including PhP300,000.00 any form of advertisement, without prior approval from PAGCOR. Non-reporting and/or concealment of player transactions from any of the registered online gaming PhP300,000.00 platform websites. Contracting an entity without Gaming License or Ph P300,000.00 EGLD's approval to implement the system and games. PhP300,000.00 Operation of game content/s without prior PAGCOR Note: All income resulting from the approval. operation of unauthorized game content's shall be collected in favoi Penalty is per game content. of PAGCOR. PhPS00,000.00 Note: If a minor has accessed and Access and play in the online gaming platform by played, the penalty imposed shall be banned and unregistered personalities. revocation of accreditation. Non-issuance or delayed issuance of player's winnings and/or account balance or any portion PhP100,000.00 thereof (on behalf of the registered Operator).

Page No. Page 9 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity c D,~uv· Zi25 Violation Penalty Noncompliance with the submission of documentary PhP300,000.00 requirements on time. Suspension of electronic gaming system, registered remote gaming platform website, without prior notice PhP100,000.00 to PAGCOR. PhP300,000.00 Failure to restore or update the Performance Cash The penalty is for every month of non- Deposit at its original level within thirty (30) calendar compliance, i.e. 30 days. days from receipt of notice. Pro-rated on a daily basis. Offering products and/or services to unauthorized PhPS00,000.00 gaming entities. Modifying or permitting the modification of any gaming PhP300,000.00 system or game without prior approval from the EGLD Any operational or procedural violation not covered by the above listed offenses, as determined by the PhP100,000.00 EGLD. (d) For succeeding offenses, the appropriate penalty may be increased as determined by the Board of Directors, upon the recommendation of the EGLD. (e) A succeeding offense refer to instances where the Authorized Entity has been previously found liable and penalized for the same offense on five

Page No. Page 10 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity C 0 l~Gv 2~25 (5) or more instances of violation, including cases where a written warning was previously issued. Such offenses shall be considered habitual or repetitive in nature. This applies to offenses bearing the same nomenclature or identical classification committed on separate occasions. The first confirmed violation shall constitute the first offense, the second shall be deemed the second offense, and so on. (f) Suspension of gaming operation or revocation of accreditation may be imposed based on severity of the offense or violation , as determined by the EGLD subject to approval to the suspension by the Chairman and CEO and approval to the revocation by the Board of Directors. (g) Acts or offenses not covered by the existing regulatory frameworks that substantially undermines PAGCOR's regulatory authority, or any violation of PAGCOR's issuances, laws, rules or regulations issued by the national or local government or by a competent authority shall be subject to the authority and determination of the PAGCOR's Board of Directors. (h) The Board of Directors may impose a penalty in the form of a fine, suspension of gaming operations and/or revocation of license depending on the severity of the offense or violation, on a case by case basis. Ill. ASSESSMENT OF PENALTIES Section 1. General guidelines (a) PAGCOR may issue additional list of offenses with corresponding penalties, as deemed necessary.

Page No. Page 11 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming Licensing Department Effectivity (b) Upon termination of gaming venue operations, voluntary or otherwise, the total amount of unpaid imposed penalties will be deducted from the Performance Cash Deposit (PCD). (c) Upon termination of accreditation of GSA or B2B Provider, voluntary or otherwise, the total amount of unpaid imposed penalties will be deducted from the PCD. (d) The Authorized Entities must pay to PAGCOR the corresponding regulatory sanction or penalty within a period of fifteen (15) days from the receipt of the notice of imposition of penalty, unless otherwise stated. Interest amounting to twelve percent (12%) per annum shall be imposed on any amount which remains unpaid after fifteen (15) days from receipt of the notice, pro-rated on a daily basis. IV. MISCELLANEOUS PROVISIONS 1. Penalties paid to PAGCOR must be submitted to PAGCOR-Fund Management Department (FMD), copy furnish the EGLD, together with the duly accomplished Payment Processing Request Form (EG Form No. 2) for issuance of Official Receipt (O.R.) and proper recording. 2. The Authorized Entities must secure an O.R. from PAGCOR-FMD, as proof of its payment of the penalties. A copy of which shall be submitted to the EGLD as proof of payment. 3. PAGCOR may increase or decrease the penalties, as deemed necessary. 4. This Regulatory Framework is in consonance and shall be interpreted together with all Regulatory Frameworks covering the GSAs, IR Licensees, Operators and B2B Providers.

Page No. Page 12 of 12 REGULATORY FRAMEWORK FOR OFFENSES AND PENALTIES Rev. No. 3 Electronic Gaming licensing Department Effectivity ( u l~Gv 2J25 5. All previous PAGCOR issuances, memoranda, orders, rules, and regulations covering the offenses and penalties for electronic gaming operations are hereby superseded by this regulatory framework.