Rules for non-disclosure

Since April 1, 2002 all companies listed in the first and second trading segment of the Vienna Stock Exchange have been subject to the legal provisions of the Issuers Compliance Regulation. bwin Interactive Entertainment AG has developed jointly with the legal department a compliance organization in line with the guidelines of the financial market supervisory authorities in order to prevent the misuse or distribution of insider information.

26 classified units have been defined within bwin Interactive Entertainment AG. Employees working in permanent or project-related classified units or with access to insider information are required to comply with the legal provisions of the compliance guidelines. Regular workshops for managers and employees working in the classified units are held to promote a strong understanding of compliance in order to guarantee the conscious and responsible distribution of sensitive data.

Moreover, a compliance officer has been appointed and specific blocking periods with regard to trading as well as compliance guidelines have been designed to regulate the management of sensitive data. In order to prevent the misuse and distribution of insider information, a set of legal provisions in the area of documentation and distribution of sensitive data both to internal and external persons has also been developed.

Trading of bwin shares by the members of the Management Board and Supervisory Board is reported to financial market supervisory authorities and also published on the website of the financial market supervisory authorities.

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