Dear Dewald,

Please find Super Group’s response to your questions below.

Best regards,
Alan
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Super Group and its global regulatory approach
Super Group (SGHC) Limited is listed on the New York Stock Exchange and
regulated by the Securities and Exchange Commission in the United States of
America, currently employing circa 3500 people worldwide.
Super Group has a proven ability to enter and profitably launch in new markets,
with a vision to provide first-class entertainment to the worldwide betting and
gaming community. More specifically, we offer online sports betting and online
casino products.
Betway, the globally acclaimed premier online sports betting brand, is owned by
Super Group. Alongside Betway, the Group also operates best-in-class online
casino the largest being Jackpot City.
Super Group continuously advocates for in-country online gaming regulation,
and, in particular, supports the primary dual aims of any such regulations:
(a) The payment of local taxes (and related local contributions to socio-
economic advancement and social responsibility related charities);
(b) The protection of customers (by adherence to regulations aimed at
minimising gambling-related harms)
In relation to this, we advocate for ‘responsible’, commercially viable regulatory
regimes, striving to obtain a license in every country where it is commercially
viable to do so.
Indeed, Super Group currently holds multiple licenses throughout Europe, the
Americas and Africa, including South Africa where it is licensed to offer online
sports and casino products.
Partnerships in sport
Globally, Super Group’s Betway brand has over 50 partnerships spanning a range
of sports. This extensive international portfolio includes football teams within
Europe’s top leagues and the Atlassian Williams team in Formula One.
Super Group’s sporting partnerships, and associated commercial relationships,
have allowed it to support communities and causes that are close to us, and the
industry we operate in, in all countries.
With specific regard to South Africa, Super Group, via its flagship brand Betway,
is a prominent contributor to South African sport and is, amongst various other
sponsorships, a major supporter of the Springboks rugby team, title sponsor of

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the Betway SA20 cricket tournament and, in 2024, became the new title sponsor
of the Betway Premier Soccer League. [See below for more details]
Giving back
Super Group strongly believes in the unifying power of sport within the unique
landscape of South Africa and therefore endeavours to assist within this sphere,
wherever possible.
By way of further example, in order to facilitate increased corporate social
responsibility, Super Group has created the ‘BW Cares Foundation’ in South
Africa order to foster more initiatives that benefit those most in need of
assistance. The BW Cares Foundation has assisted various disabled
organizations, the aged, sportsmen and women in disadvantaged communities,
educational facilities, music academies and major hunger relief initiatives.
The Betway Cares Foundation has also undertaken three separate projects to
provide access to water in rural areas as it has identified this as a pressing issue
within South Africa.
The ‘Black Market’ risk
Whilst opponents of the online gambling sector, and related published articles,
tend generally to point fingers at the regulated operators, it is well understood
by the industry and most regulators globally that the real threat is the ‘Black
Market’ - a term referring to operators targeting local customers without a
license, in a market where a legitimate regulatory regime exists.
Current estimates around the size of the global Black Market (driven mainly by
crypto funding) is between USD40bn-USD80bn per annum. In South Africa,
according to the South African Bookmakers Association, the country loses R55
billion in gross gaming revenue to the illegal gambling market per annum (more
below). Market estimates aside, the threat to licensed operations and consumers
cannot be over-stated.
A Black Market is either created, or flourishes, for one or more of the following
reasons:
1. Where there is a non-commercially viable regulatory regime, with the
result that existing license holders leave, or alternatively do not apply for
a license in the first place. A ‘non-commercial’ regime tends to have one
or more of the following facets:

(a) Complex, and unnecessary technical requirements

(b) Impractical hindrances to a customer registration journey
(c) Excessive and disproportionate taxation.

2. The advent and ubiquitous unlawful use of social network platforms, such
as Telegram, and the use of crypto.
The Black Market therefore intentionally:
- does not comply, or even try to comply, with local laws;
- launders criminally sourced funds;

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 - does not pay taxes (and therefore does not contribute to local economies
or harm prevention initiatives);
- does not comply with responsible gambling requirements and do not apply
social responsibility tools to minimise customer addictions, unaffordability,
or establish age verification.
Super Group and its local subsidiaries actively work with regulators worldwide to
assist in the combat the expansion of the Black Market, for example in Germany
and Great Britain, and, by extension, would gladly assist South African regulators
in understanding, and tackling, this pervasive issue. It also works directly with its
competitive industry operators either directly, or via industry associations such
as the Betting & Gaming Council (UK), Deutsche Sportswetteen Verband, and the
Canadian Gaming Association.
South Africa’s licensing regime
Super Group’s subsidiaries, Raging River Trading (Pty) Ltd and Eastern Dawn
Sports (Pty) Ltd are licensed by the Western Cape Gambling & Racing Board and
the Mpumalanga Economic Regulator respectively, to offer sports betting and
fixed odds casino-style products.
At the core of this licensing regime is an understanding of the hierarchy of
national versus provincial laws in South Africa in the context of provincial
licensees offering fixed odds casino-style games, as authorised by Provincial
Licensing Authorities (PLAs).
Online gambling falls within the purview of PLAs and accordingly, the provinces,
in accordance with Section 146 of the Constitution, have independence and
priority over matters relating to casinos, racing, gambling and wagering.
Accordingly, the provincial licensing authorities are authorised to determine the
games offered by licensed bookmakers to whom they have issued licenses,
including, for completeness, fixed odds casino-style contingency games. In
addition, there is no preclusion on citizens within one province participating in
such games in another province.
Each of the games offered by Super Group’s licensed South African entities,
including fixed odds casino-style games based on PLA-approved contingencies,
are fully compliant with the policies of the National Gambling Board (NGB).
In summary, it is incorrect to say ‘online gambling is technically illegal in South
Africa…’. Our operations are guided by leading South African gaming regulatory
counsel, and the legal framework supporting our activities has been clearly
affirmed.
Super Group’s relevant subsidiaries have been licensed in South Africa since
August 2015, some 16 months after the Remote Gambling Bill was tabled by the
Democratic Alliance.
The Remote Gambling Bill, introduced in April 2014, is almost identical to the
current bill. We understand that the paragraph that you reference in your
questions appears in the original draft of the bill of 2014. Therefore, in any event
Raging River did not exist at that time, so your reference to interference in the
bill cannot be, and is not, correct. Super Group also did not exist at that time.

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The business has grown substantially within the context of the current regulatory
regime over the past decade.
With regard to your question as to if we commented on the 2024 Bill, we did
indeed submit (publicly available) comprehensive comments on the Bill. An
opportunity that was afforded to and consequently taken up by numerous
industry operators.
We don’t agree that it’s outdated and believe that the current provincial, national
system works. We are, however, happy to collaborate with all current regulatory
bodies to create efficiencies, via new regulations, and to better protect
customers whilst combatting the rise in Black Market operations. Super Group
has proactively engaged with both Provincial and National stakeholders to
provide practical input and insights aimed at strengthening the overall
framework.
Responsible and safer gambling
Super Group operates in a manner consistent with all laws and regulations, both
national and provincial, at all times; and is categorically committed to ensuring
that our customers use our services responsibly.
All customers are different. When they first sign up to our platforms, each
customer is assessed by our proprietary systems and our highly trained staff, as
individuals. These processes - which occur in real time and throughout their
lifetime as a customer - follow established regulatory provisions for assessing,
among other things, identity, age of customers, affordability and problem
gambling. [See below for more detail]
With respect to the Claude Gouws case, it is important to note that Raging River
and Osiris Trading were the applicants, not the respondents in this matter which
dealt with prevention of defamatory statements against them. This is a without
prejudice, confidential matter. We do not, as a matter of policy, comment publicly
on individual cases.
At Super Group, responsible gambling is at the core of our operations. We are
committed to ensuring that gaming remains a safe, controlled, and enjoyable
form of entertainment within a regulated framework. As a licensed operator, we
strictly adhere to all industry regulations and work closely with regulatory bodies
to uphold the highest standards of accountability.
To protect our customers, we have implemented robust safeguards. Customers
have access to comprehensive resources on responsible play, along with a suite
of management tools designed to ensure our customers use our services
responsibly. This includes self-exclusion options, and access to professional
support services. All our customers can access comprehensive information about
how to gamble responsibly and where to obtain appropriate help for gambling
related problems.
Super Group is a committed funder of the South African Responsible Gambling
Foundation (SARGF), which provides free, confidential treatment and counselling
to those affected by problem gambling, as well as their immediate family
members. In addition to supporting this national programme, Super Group has
independently contracted an accredited private organisation to expand access to

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counselling services for its customers, ensuring greater reach and more
immediate support for those in need.
Super Group works closely with regulators, industry stakeholders, and
government bodies to promote fair and transparent gambling practices.
Marketing bans and ‘sin taxes’
Super Group believes in socially responsible marketing.
When it comes to advertising, Super Group’s brands adhere strictly to all
relevant local marketing and advertising regulations, ensuring that promotions
are ethical, legal, and incorporate responsible gambling messaging. All
advertisements are approved by the Provincial boards before publication. Our
campaigns span both social media and mainstream platforms such as television,
with a strong emphasis on education and harm minimisation. We support
continued efforts to enhance responsible gambling awareness and regulation.
In addition, Super Group and its local subsidiaries invest a material amount of its
marketing and social media spend on promoting responsible gambling, standing
us apart from most other operators.
Significantly, a marketing presence of licensed operators, and their brands, is
known to prevent customers moving to Black Market sites.
Licensed and regulated gambling operators like Super Group already make
substantial fiscal contributions to the South African economy, including VAT at
15%, corporate tax, and an 6.5% tax on gross gaming revenue across all forms of
gambling.
Taxation increases and advertising restrictions need to be considered with care.
International experience, such as in Germany, has shown that excessive taxation
and advertising bans can unintentionally expand the illegal gambling market,
undermining consumer protection and reducing tax revenue.
A similar example is Italy, which in 2018 enacted legislation that completely
banned the advertising of gambling products in sport. The unintended
consequence was a significant expansion of the country’s black market. In March
this year, the Italian government reversed the ban, acknowledging the need for a
more balanced and effective approach.
Similarly, a recent article on the Spanish market reports that the country’s
advertising restrictions have resulted in a 55% decrease in new account
registrations with licensed operators, thus driving more customers towards
unregulated, unprotected gambling platforms.
It is also relevant to note that when tax rates exceed commercially viable
thresholds, it becomes increasingly difficult for licensed operators to sustain
profitable operations. This creates a vacuum in the market, one that is readily
exploited by unregulated and unscrupulous Black Market operators.
Again, this risk is particularly relevant in South Africa, where the illegal gambling
market is estimated to cost the country R55 billion in lost gross gaming revenue
annually. Illegal operators exist outside of the law, evade tax obligations, and

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offer no consumer safeguards, creating significant risks including fraud,
exploitation, and money laundering.
Super Group supports a balanced regulatory approach, one that promotes
responsible gambling and protects consumers while preserving the viability of
the licensed market and the vital contributions it makes to the country.
Finally, and importantly, the commercial operating models of a licensed online
gambling business cannot be compared to that of tobacco.
Online gambling being more harmful than other forms of gambling
This is neither correct nor has this been proven to be correct. What we do know
is that gambling, as a leisure pursuit, has existed throughout human history.
Humans have consistently found ways to gamble. The responsible way of
approaching it, therefore, is through responsible regulatory/licensing regimes.
The fact that gambling is now also being facilitated by technological
advancement is a logical by-product of an increasing generational reliance on
such technology.
One of the benefits of online gambling is that we get real time feedback and data
on customer behaviour, allowing us to immediately intervene when we see
markers of harm.
In any event, if these arguments are utilised to constrict or ban the online
regulated market, the Black Market will simply replace it, leading to enhanced
negative economic and social harms.
Super Group’s role in the South African market
As a NYSE listed business, Super Group fully complies with all the relevant
regulators’ requirements around disclosure of financial information. However, to
protect the commercial viability of the Group, we do not release sensitive
financial, operational or performance data that goes beyond those mandated
regulatory requirements.
We should note that the figures you reference re: revenue and market share in
SA are a misinterpretation of publicly available data. As you will have seen, we
report financial performance per region, not per market. So, the figures that we
think that you may have extrapolated are from all the markets we operate across
the continent, not only SA. We do not break down the figures further.
Consequently, we can categorically say that your figures are incorrect.
Super Group’s contribution to South Africa

We fundamentally, though respectfully, disagree with your assessment of the

‘extractive’ nature of our business.
Whilst we cannot comment on what other operators do, or don’t do, we can
explain the considerable fiscal and socio-economic contribution that our business
makes to SA.
We believe this stands us apart from many other gambling operators in the
country.

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Super Group’s plays a significant role in South Africa’s economy through its
substantial fiscal contributions, community investment and job creation. As a
licensed and regulated operator, Super Group contributes to the South African
economy, including VAT at 15%, corporate tax, and a tax on gross gaming
revenue.
Sport has a unique way of bringing people together, and Super Group is
committed to backing athletes, teams, and communities, helping to grow the
game at every level.
Super Group champions and supports some of South Africa’s biggest teams and
tournaments.
The company is a sponsor of the Springboks, the title sponsor of the Betway
SA20 cricket tournament, and the Betway Premier Soccer League, amongst
others. Its sponsorship and partnership philosophy is rooted in strong ethics and
a commitment to shared values (i.e. integrity training programs for all PSL
players). Betway has also contributed (without seeking recognition) to the
upliftment of sports teams - for example, Betway was instrumental in funding the
medal winning relay sprint team at the past Olympic Games.
Super Group is an active participant in building stronger communities across
South Africa. Aware of the country’s social and economic challenges, Super
Group invests in initiatives that create real and meaningful change, promote
inclusivity, and uplift those in need.
Through the Betway Cares Foundation, the company tackles critical issues like
water access in KwaZulu-Natal and Mpumalanga, education and literacy
programmes, skills development, food security and investing in local creative
talent.
Super Group invests heavily in South Africa and provides multiple international
services from South Africa and as such:
- Employs more than 2500 people in South Africa, contributing payroll taxes
- Contributes significant Gaming Taxes to South Africa
- Pays VAT on every Rand of Gross Gaming Revenue earned
- Contributes to the SARGF (South African Responsible Gaming Foundation)
- Pays significant corporate tax on South African profits
- Spends large sums on economic and social development to uplift South
Africans in terms of supply chain and procurement investments

Martin Moshal
Mr Moshal is not a shareholder of Super Group (SGHC) Ltd (Super Group) but is a
beneficiary of a trust which ultimately holds an ownership interest in Super
Group. Mr Moshal has no voting rights, whether directly or indirectly, in Super
Group or in any other entity within its group of companies and Mr Moshal is not,
and has never been, a director or employee of Super Group or any other entity
within its group of companies.

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