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17 February
2010 eCOGRA Report
On Grand Privé Investigation Following a
number of internet-based allegations concerning the
closure of the Grand Privé Affiliate
Program, eCOGRA's (e-Commerce Online Gaming
Regulation and Assurance) Compliance and Advisory
Services department was engaged by the management
of the company on 17 November 2009. eCOGRA was tasked
with independently investigating the manner in
which the Program was terminated and the reasons
therefore carrying out a full and independent
review of the program software and data to confirm
amounts owed to claimants, determining a fair
settlement for claimants, taking into consideration
the potential lifetime earnings of each affiliate's
respective players and compiling a full and
transparent report which will be publicly released
on conclusion of the investigation. According to
eCOGRA's mandate, the following actions were taken
in order to ensure the maximum number of affiliates
were afforded the opportunity to submit legitimate
and verifiable claims. On 7 December
2009 both eCOGRA and Grand Privé issued
widely distributed press releases advising
affiliates of the opportunity to submit claims and
also urging affiliate watchdog organisations to
assist in ensuring their respective affiliate
members were informed of this
opportunity. After noting
affiliate concerns regarding the limited reach of
affiliate representative bodies and webmasters,
Grand Privé management expanded the
communications exercise by emailing every affiliate
who had active players on the Program's records
during the 3 months prior to 1 December 2008 when
the Program closed and an online claim submission
form for affiliates was made available from 7 to 31
December 2009 and claims were collated by
eCOGRA. Following various
meetings with management and an onsite
investigation at the Grand Privé operational
base during the months of January and February
2010, an inspection of supporting evidence allowed
eCOGRA to substantiate that for commercial reasons,
in August 2008 a decision to close the Program
effective 1 December 2008 was taken. System problems
were being experienced on an ongoing basis due to
the program using software in Beta testing. In
order to maintain the integrity of the data three
permanent employees were required to manage the
Program software. In addition the software provider
was required to spend an extensive amount of time
assisting and troubleshooting ongoing system
problems. This resulted in escalating costs,
deteriorating service levels and reputational
damage. Due to the high
operational overheads and the relatively small
portion of income being derived from the affiliate
business associated with the Program, losses were
incurred by the Program over a period of more than
12 months. After carefully
considering alternative courses of action,
management decided to close the Program in order to
protect other areas of the organisation from
further losses. All affiliates
were informed of the intended closure by email on 7
November 2008 and encouraged to move their accounts
and players to the Villa Fortuna Affiliate Program,
which used improved affiliate program software. A
follow up email with the same message was sent
again on 21 November 2008. Termination was
conducted according to the termination clauses
stipulated in the affiliate contracts. During November
2008 management entered into mutually agreed
compensation arrangements for related future player
activity with the majority of affiliates who at
that time had players considered to be reasonably
active. We have however confirmed that certain
affiliates were overlooked in this
process. On 1 December
2008 all affiliates were paid November commissions
and the program was officially closed. 58 claims were
submitted to eCOGRA, of which 7 were found to be
invalid and 26 earned commissions during the period
1 December 2008 to 31 December 2009. Spin
Palace Casino
and Golden
Reef Casino
are both approved by eCOGRA. |
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