Politically Exposed Persons (PEP) Declaration

This notice explains the politically exposed person ("PEP") declaration that may apply to winners of the "England vs Norway" conditional promotional giveaway operated by Aetheria Media Holdings S.r.l. ("we", "us", "our").

1. What Is a PEP

1.1. A politically exposed person is an individual who holds or has held a prominent public function. This includes, but is not limited to, heads of state or government, senior politicians, senior judicial or military officials, senior executives of state-owned enterprises, and senior officials of political parties.

1.2. "Prominent public function" includes elected and appointed offices at national, regional, and international levels, as well as senior positions in state-owned enterprises, central banks, and international organisations.

1.3. For the purposes of this notice, a PEP also includes family members and close associates of a person who holds or has held a prominent public function.

2. Family Members and Close Associates

2.1. Family members include, without limitation, a PEP's spouse, partner, children, parents, siblings, and in-laws.

2.2. Close associates include:

- a person who is known to have joint beneficial ownership of a legal entity or arrangement with a PEP;

- a person who has sole beneficial ownership of a legal entity or arrangement that is known to have been set up for the benefit of a PEP; and

- any other person with a close business or personal relationship with a PEP.

2.3. Whether a person is a close associate is assessed based on the facts and circumstances known to us or reasonably discoverable through due diligence.

3. Declaration Requirement

3.1. As part of verification, Provisional Winners may be asked to declare whether they are, or are a family member or close associate of, a PEP. You must answer truthfully and completely.

3.2. Providing false, misleading, or incomplete information may result in disqualification, forfeiture of any prize, and, where required by law, reporting to authorities.

3.3. The declaration may be in the form of a questionnaire, written representation, or other verification document as we reasonably require.

4. Effect of PEP Status

4.1. PEP status does not automatically disqualify a winner. However, it may trigger enhanced due-diligence checks before a prize is paid, consistent with applicable law and our risk-based approach.

4.2. Enhanced due diligence may include additional identity verification, source-of-wealth or source-of-eligibility checks, senior-management review, and approval.

4.3. We may require senior-management approval for payment to a PEP or close associate, and we may impose additional conditions or documentation requirements.

5. Data Handling

5.1. Information collected for the PEP declaration is used solely for verification, risk assessment, and lawful reporting purposes.

5.2. PEP-related information is processed and retained in accordance with the Privacy Notice and the Data Retention & Deletion notice.

5.3. We treat PEP-related information as sensitive and limit access to authorised personnel and advisers who have a legitimate need to know.

6. Ongoing Obligation

6.1. If your PEP status changes between the date of entry and the date of prize payment, you must inform us promptly. Failure to do so may result in disqualification.

6.2. If we discover after payment that a winner was a PEP or close associate and failed to disclose that status, we may take appropriate action, including reporting to authorities where required by law.