Compliance
Code of Conduct
At Spudo, we want to make sure our core value is represented through the Marketing Agencies and the iGaming Operators we work with. To ensure our values are incorporated directly from the start, we have build af Code of Conduct Procedure to our employees, our Operators and our Marketing agencies.
We take GDPR, KYC, Security and Compliance very seriously. As an affiliate network we sit between the Media Agencies and the iGaming Operators who own multiple products and services around the world. Because of the commission comes from our iGaming Operators through us an transfered to the Media Agencies, it is crucial for us that we are in control with everyone involved and meet all the requirements regarding KYC and compliances.
Thats why we need each partner to go through our KYC procedures, which meet the highest security standards, from authentication to encryption through Penneo.com
Code of Conduct Procedure
We implemented a procedure that gives us full insight in which partners we work with. We use Penneo.com as a third party company who stores all from authentication to encryption, everything they provide is following the highest security standards.

Know Your Customer (KYC)
We need to know who the owner(s) of the Company
Identification document can be one of the following: ID card, passport or driving license.
Document should include full name, date of birth and a picture of yourself
Proof of address document can be one of the following: bank/credit card statement or a utility bill.
Identify if any employees should work on behalf of your company
New company structure will be notified to our compliance officer

Risk Management
Entering a new agreement with a new Media Agency or iGaming Operator, we will have to go through the following process
Online Reputation: If we find any bad reviews, lack of licenses or other information we find troubling, we will be in a situation where we will have to decline a cooperation
Recommendation: In some cases, we will ask for recommendation from other trusted partners you have worked with in the past. This is to avoid working with partners who dont hold a high degree of ethic and business moral.
Gaming License: A new iGaming Operator will need to hold a gaming licenses for the specific countries, before we can start a cooperation. This need to be visible on the company website.
Foreign transfers: In order to prevent starting a cooperation with a partner who use this business for economic crime, we have limited the number of countries to which we will make – or receive payments towards.

Insertion Order
An Insertion Order (IO) is a document that depicts the agreement between the Marketing Agency or iGaming Operator and us, making sure the KYC, the Risk Mangement and the Agreement of the cooperation is clear for all parties.
Transferring or receiving money too or from our partners is all about trust, transparency and reliable banking system. Thats why we work very close with our brank to make sure we uphold the highest degree of fraud detection. The Insertion Order will in this case be used to prove the cooperation between our Marketing Agency or iGaming Operator.
To ensure this, an Insertion order will need to be signed, continuously updated, and is an integrated part of operations with our bank.
Have questions to our Code of Conduct Procedures? Contact us today
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Most asked questions related to Code of Conduct
Do we make transfers in Crypto Currencies?
Working from Gibraltar, Seychelles or British Virgin Islands
We will in some cases have to decline working with you based on our Code of Conduct procedures.
What currency will your pay my commission in?
We pay all our partners in either Euro (€) or USD ($) through a bank wiretransfer.
In what cases will you decline our cooperation
What does an Insertion Order contain?
An Insertion Order (IO) is a document that depicts the agreement between the Marketing Agency or the iGaming Operator and Spudo Aos to run a campaign.
The insertion can cover:
- Starting date
- Potentiale Ending date
- Company name & address
- Bank information
- Pricing Structure
- Terms and Conditions
In some cases other information might be needed.
Can you cancel our Cooperation?
An Insertion Order is a legal document that binds at least two parties to one another and requires them to meet certain obligations detailed in the contract. In some instances, contract termination can occur that will make the contract void of legal binding. Only the parties involved in the agreement may terminate a contract.
Terminating a contract means legally ending the contract before both parties have fulfilled their obligations under the terms of the contract. There are a variety of reasons why a party can terminate a contract. We uphold or right to terminate a cooperation within 48 hours.