1. Purpose & Scope

Betzy is committed to the integrity of all sports and competitions offered on the Platform. This Sports Integrity & Insider Policy ("Policy") establishes the rules and procedures Betzy uses to prevent, detect, and report:

• The use of material non-public (insider) information in sports wagering.
• Match-fixing, spot-fixing, and other forms of competition manipulation.
• Suspicious betting patterns indicative of integrity violations.

This Policy applies to all Betzy users, employees, contractors, and any third party with access to Betzy's sports wagering systems. It supplements and is incorporated into Betzy's Terms of Service and Sportsbook Terms Addendum.

2. Prohibited Persons

• Athletes (professional or amateur) who are eligible to participate in any event offered on the Platform.
• Coaches, managers, trainers, medical staff, and other team personnel.
• Referees, umpires, officials, judges, or other match officials.
• Team owners, franchise investors, or league/governing-body officers.
• Sports agents and player representatives.
• Immediate family members and household members of any of the above (due to the risk of information sharing).
• Employees, contractors, and data analysts of sports data providers or integrity monitoring organizations who have access to privileged information about events offered on the Platform.
• Betzy employees, officers, contractors, and their immediate family members.

Any wager placed by a Prohibited Person will be voided, any associated winnings will be forfeited, and the account will be immediately and permanently closed. Betzy reserves the right to report such activity to the relevant sports governing body, integrity organization, and/or law enforcement.

3. Prohibition on Use of Insider Information

It is strictly prohibited to place, or attempt to place, any wager on the Betzy Platform using material non-public information ("insider information") relating to the event or any participant in the event. Insider information includes, but is not limited to:

• Non-public information about a player's injury, illness, or absence from training.
• Advance knowledge of team selection or lineup decisions not yet publicly announced.
• Knowledge of referee or official appointments before public disclosure.
• Information about performance-enhancing substance use not yet publicly disclosed.
• Any information obtained in breach of a confidentiality obligation to a sports body.

Wagers placed using insider information are void, winnings are forfeited, and the account is subject to permanent closure. Betzy will refer such cases to the appropriate sporting body and, where applicable, to law enforcement.

4. Prohibition on Match-Fixing & Spot-Fixing

Betzy has a zero-tolerance policy toward any form of competition manipulation, including:

• Match-fixing: influencing the overall outcome of a match or event.
• Spot-fixing: deliberately influencing a specific element or phase of a match (e.g., number of wides in an over, next goal scorer, time of first foul).
• Point-shaving or score manipulation.
• Any arrangement between a bettor and a participant intended to predetermine a wagerable outcome.

Any user found to have participated in, facilitated, or benefited from match-fixing or spot-fixing will have their account immediately closed, all winnings forfeited, and the matter referred to the relevant sports governing body and law enforcement authorities.

5. Suspicious Betting — Detection & Reporting

Betzy employs automated and manual monitoring systems to detect suspicious betting patterns in real time. Betzy is a member of, and shares data with, sports integrity organizations including:

• International Betting Integrity Association (IBIA)
• U.S. Integrity
• Sportradar Integrity Services

Where Betzy identifies a suspicious pattern, it may: suspend or void the relevant wager(s); freeze the account; request additional information from the user; and/or report the activity to the relevant integrity organization, sporting body, or law enforcement agency.

See Annex A for the full list of suspicious betting indicators.

6. Cooperation with Leagues, Integrity Bodies & Law Enforcement

Betzy is committed to full cooperation with all sports governing bodies, integrity organizations, and law enforcement agencies investigating potential integrity violations. Upon receipt of a lawful request, Betzy will:

• Provide betting records, account details, and other relevant information as authorized by applicable law.
• Suspend or freeze accounts under investigation.
• Preserve evidence and records relevant to the investigation.
• Participate in joint investigations and provide witness statements where required.

7. Internal Controls — Employee Betting Restrictions

Betzy employees and contractors are prohibited from:

• Placing any wager on the Betzy Platform (whether for themselves or on behalf of another person).
• Sharing non-public information about Betzy's wagering systems, odds, or risk management with any external party.
• Accepting any gift, payment, or benefit in exchange for providing access to Platform systems or data.

Violations of these restrictions will result in immediate termination and referral to law enforcement where appropriate.

8. Whistleblower Protection

Betzy encourages anyone with knowledge of suspected integrity violations — including match-fixing, insider wagering, or suspicious betting — to report this to our compliance team. Reports may be made confidentially. Betzy will not retaliate against any person who, in good faith, reports a suspected integrity violation.

9. Penalties for Violations

The following actions may be taken against any user found to have violated this Policy:

• Immediate suspension or permanent closure of the account.
• Void and forfeiture of all wagers and associated winnings.
• Recovery of any prizes already paid out, to the extent permitted by law.
• Referral to the relevant sports governing body (e.g., NFL, NBA, MLB, FIFA, ATP, etc.).
• Referral to law enforcement and regulatory agencies.
• Civil legal action to recover losses or enforce forfeiture.

10. Review & Updates

This Policy is reviewed at least annually and updated as needed to reflect changes in applicable law, regulatory guidance, and industry best practices. Material updates are published on the Platform with a revised Effective Date.

Annex A – Suspicious Betting Indicator List

The following indicators may, individually or in combination, suggest integrity violations and will trigger enhanced review:

• Large or unusual bets on obscure markets or events not consistent with the user's prior betting history.
• Bets placed immediately before a significant late change (e.g., player withdrawal, weather event) that was not publicly known.
• Unusual concentration of bets on a specific outcome across multiple accounts with a shared IP, device, or payment method.
• Bets on highly specific in-play markets (e.g., next throw-in, specific minute goals) that are then confirmed within seconds.
• Accounts that receive winnings disproportionate to their deposit history.
• A pattern of winning bets across multiple consecutive matches or events in the same competition.
• Requests to cancel or reverse bets immediately after they are placed and before the event commences.
• Accounts that are otherwise inactive but suddenly place large bets on niche markets.
• Bets placed by accounts known to be associated with athletes, officials, or insiders.
• Any pattern flagged by our integrity monitoring partners (IBIA, U.S. Integrity, Sportradar).