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Company Registration Number: C 44319 
Gentoo Media p.l.c. (formerly known as Gaming Innovation Group p.l.c.) 
Annual Report and Consolidated 
Financial Statements 
31 December 2024

===== SIDA 2 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
1 
 
 
 
 
 
 
 
 
      Pages 
 
Directors’ report     2 - 13  
 
Sustainability report      14 - 54 
 
Statements of financial position      55 - 57  
 
Income statements     58 
 
Statements of comprehensive income     59  
 
Statements of changes in equity     60 - 65  
 
Statements of cash flows     66 - 67  
 
Notes to the financial statements       68 - 128 
 
Independent auditor’s report     129 - 140 
 
 
 
 
 
 
Readers are reminded that the official statutory Annual Report and Consolidated Financial Statements 2024, 
authorised for issue by the Board of Directors, is in European Single Electronic Format (ESEF) and is 
published on the Swedish Securities Market. A copy of the Independent auditor’s report issued on the official 
statutory Annual Report and Consolidated Financial Statements 2024, is included within this printed 
document and comprises the auditor’s report on compliance with the requirements of the Europe an Single 
Electronic Format Regulatory Technical Standard (the ESEF RTS), by reference to Chapter 16 Section 4a of 
the Swedish Securities Market Act.

===== SIDA 3 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
2 
 
 
Directors’ report 
The directors present their annual report (including the ‘Sustainability report’) and the audited consolidated 
financial statements of Gentoo Media p.l.c. (the ‘Group’, ‘Company’, ‘Gentoo’ or ‘Gentoo Media’) for the year 
ended 31 December 2024. 
 
During an extraordinary general meeting held on 23 September 2024, a decision was taken to change the 
name of the company from Gaming Innovation Group p.l.c. to Gentoo Media p.l.c. (the ‘Group’, ‘Company’, 
‘Gentoo’ or ‘Gentoo Media’). Reference to Group, Company or Gentoo going forward throughout the directors' 
report and Sustainability report refers to Gentoo Media p.l.c. (formerly known as Gaming Innovation Group 
p.l.c.). 
Principal activities 
The Group’s principal activities during 2024 were the provision of online gaming services, primarily casino 
and sports, provision of a remote gaming platform, and affiliate marketing operations.  
Strategic review 
The Board of the Company’s Parent initiated a strategic review in February 2023 with the intention of splitting 
the previous Group into two separate Groups, forming two industry -leading businesses with the potential to 
grow faster than in the current corpo rate structure. The purpose of the split was to optimise growth 
opportunities and ensure each business could benefit from the strategic and financial flexibility of its distinctive 
business models. 
 
Following shareholder approval at an extraordinary general meeting on 23 September 2024, the split was 
executed on 30 September 2024, dividing the Company into two independently listed companies and thereby 
completing the strategic review. The extraordinar y general meeting also approved the name change from 
Gaming Innovation Group p.l.c. to Gentoo Media p.l.c. 
 
During 2024, the assets and liabilities included within specific subsidiaries of the platform business were 
transferred to an intermediary holding company within Gentoo Media. This company was subsequently 
distributed to the Company’s immediate parent company, subsequently distributed to the Company’s ultimate 
parent company and ultimately was distributed to the shareholders. The platform business continued as an 
independent B2B company named GiG Software PLC, providing its proprietary platform and sportsbo ok 
technology across the global iGaming sector. In the third quarter of 2024, the listing of GiG Software PLC on 
the Nasdaq First North Premier Growth Market in Stockholm was completed.  
 
The distribution of the platform business to the shareholders was in the form of Norwegian or Swedish 
depository receipts, depending on if shares in Gentoo Media were held in Norway or Sweden.  
 
Due to the above events, as a result of the strategic review and the distribution of Platform & Sportsbook to 
the Parent’s shareholders, Platform & Sportsbook is reported as discontinued operations under IFRS 5 in the 
financial statements. See Note 7, Discontinued operations and disposal groups held for distribution for more 
information.

===== SIDA 4 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
3 
 
 
Directors’ report - continued 
Group strategy 
Since 2019, Gentoo Media has experienced strong growth, evolving from a Nordic -focused affiliate into a 
leading global player in the iGaming industry. Through our business model and our strategy pillars, we help 
players make informed decisions about online gambling by connecting them with the right online bookmakers 
and casinos. Gentoo Media's strategic framework is built on six interdependent pillars, each designed to drive 
sustainable growth and strengthen market leadership: 
● Diversification – Ensuring sustainable long -term growth through market, website, and partner 
expansion. 
● Technology – Ensuring industry-leading products and operational efficiency. 
● Organic Growth – Strengthening profitability through in-house optimisations. 
● Mergers & Acquisitions – Scaling operations and accelerating top-line revenue growth. 
● Partnerships – Expanding global reach and enhancing brand visibility. 
● Recurring Revenue – Building long-term value through predictable and sustainable revenue streams. 
Our journey ahead after split 
The restructuring strengthens Gentoo Media, enabling expansion into new markets, investment in 
technology, and strategic acquisitions. With greater financial flexibility and streamlined operations, the Group 
is well-positioned to capitalise on new opportunities and scale effectively. 
Our 2024 financials naturally reflect certain one-time factors associated with the Company’s split. As we move 
beyond this transition, these costs will diminish, allowing Gentoo Media’s management to present a much 
clearer picture of the business in 2025.

===== SIDA 5 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
4 
 
 
Directors’ report - continued 
2024 Acquisitions 
Titan Inc. Limited (Titan) 
In August 2024, the Group completed the purchase of 100% of the shares and voting rights in Titan. The 
acquisition is structured with a total price of EUR 3.1 million, comprising an initial payment of EUR 1.0 million 
that was paid on closing, followed by t wo yearly instalments of EUR 1.0 million to be paid after twelve and 
twenty-four months, respectively. 
 
The Group acquired effective control over Titan from 31 May 2024, which is the date on which the Group 
became exposed to variable returns from its involvement with the entity and gained the ability to affect those 
returns through its power to direct the activities of the entity via its majority voting rights. 
 
Titan is based in the UK offering bespoke link building, multimedia content production etc. and employed 
around 40 people at takeover. The acquisition is in line with the strategy to create sustainable long -term 
growth. The Group expects to obtain signific ant cost synergies following the transactions from the internal 
purchase of SEO and marketing content services that Titan provides. Previously the Group made use of the  
services from Titan. Moreover, the ultimate goal with the acquisition is also to expand Titan’s customer base 
outside of the collaboration with the Group. This is expected to go proportionally faster given the synergies 
provided from the rest of the Group post-acquisition. 
 
For further information on the Titan acquisition, see Note 6, Business combinations.  
 
Other acquisitions 
 
In June 2024, the Group acquired the casino affiliate website Casinomeister.com effective from 1 June 2024. 
The transaction was structured as an asset purchase with a total consideration of EUR 3 million, that was 
paid in cash in July 2024. 
 
In September 2024, the Group acquired two minor casino affiliate websites effective from 30 September 
2024. The transaction was structured as an asset purchase with a total consideration of EUR 2.7 million 
(including transaction related costs). The consideration was fully paid before year end. 
 
The Group acquired two minor affiliate websites on 26 December 2024. The transaction was structured as 
an asset purchase with a total consideration of EUR 3.2 million to be paid by 2025, with an initial payment of 
EUR 1.4 million, and the remaining balance is paid in instalments from January through April 2025.

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Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
5 
 
 
Directors’ report - continued 
Update on 2023 acquisitions 
AskGamblers 
Since acquiring AskGamblers in January 2023, the business has experienced strong traffic growth, 
culminating in an all -time high number of registrations, first -time depositors, revenue and EBITDA. During 
2024, AskGamblers benefited positively from Google’s  core update in March which improved rankings and 
player intake. Furthermore, in the first half of 2024, the first initial sports sections were added and 
AskGamblers continued its growth, setting new records with ongoing development in sports content and 
product enhancements. The fourth quarter for AskGamblers.com also marked a significant milestone for the 
site as it officially launched in the regulated US market. During the year, the Group paid EUR 10 million and 
subsequent to year end EUR 15 million were paid in line with the contractual obligations. No further payments 
are expected on this acquisition. 
KaFe Rocks and its subsidiaries 
Since acquisition in December 2023 KaFe Rocks Ltd. and its subsidiaries have contributed to significant 
revenue growth, operational synergies, and improvements in EBITDA margins. KaFe Rocks’ different sites 
experienced a mixed impact by the Google Core Upd ates during the year, however, KaFe Rocks quickly 
responded by implementing targeted initiatives to recover lost ranking. Throughout the year, the integration 
of KaFe Rocks to the business progressed steadily during the year and unlocked technological and 
commercial synergies, and several KaFe Rocks websites were successfully migrated onto Gentoo Media’s 
main platform at the end of the year.  
 
During 2024, the Group paid EUR 6.1 million in cash, and an additional EUR 2.5 million in issued shares to 
the sellers due to specific operational cost savings targets being met by year -end 2023, where the number 
of shares issued is based on a 30-day VWAP of the Gentoo Media share at the time of closing (NOK 30.11), 
which was according to the contractual terms and obligations. In relation to the deferred consideration, in 
January 2025 the earnout in relation to the second half of 2024 was crystallised and t his amounted to EUR 
0.3 million, such amount was not part of management’s estimate of the total deferred consideration. In 
January 2025, the total amount paid was EUR 5.6 million. During 2025, EUR 15.8 million are contracted 
payments to previous shareholders. 
Activities and development 
The Group achieved all-time high in annual revenue and player intake. Revenue achieved during 2024 was 
EUR 122.8 million (2023: EUR 88.6 million) whilst player intake (FTDs: First Time Depositors) was 471,470 
(2023: 471,440). While player intake was in lin e with last year, the value of deposits for the player base 
increased by 39% from EUR 554 million in 2023 to EUR 768 million in 2024.

===== SIDA 7 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
6 
 
 
Directors’ report - continued 
Events after the reporting date 
No subsequent events of material significance have occurred. 
Overall performance 
Revenues amounted to EUR 122.8 million (2023: EUR 88.6 million) during 2024, an increase of 39% is 
primarily driven by the effect of 2023 acquisitions AskGamblers and KaFe Rocks. On an organic basis, 
revenues increased by 15% year over year. 
 
EBITDA increased from EUR 40.7 million in 2023 to EUR 57.1 million in 2024. Operating profit pre-transaction 
costs for the Group increased from EUR 30.2 million in 2023 to EUR 39.5 million in 2024.  
 
EBITDA is equivalent to operating profit before depreciation, amortisation and impairment.  
Marketing expenses 
Marketing expenses were EUR 32 million in the year 2024 (2023: EUR 26.8 million), an increase of 20%. 
The increase is related to optimisation and improving efficiency in Paid as the Company introduced new 
marketing technologies. 
Total operating expenses 
Personnel expenses amounted to EUR 15.6 million during 2024 (2023: EUR 10.2 million), an increase of 
53%. Capitalised expenses relating to the Group’s development of technology amounted to EUR 5.6 million 
in 2024 (2023: EUR 4.4 million). Personnel expenses  increased due to the number of new employees 
employed subsequent to the spin-off. 
 
Depreciation and amortisation amounted to EUR 17.6 million (2023: EUR 12.5 million), an increase of 41%, 
where the increase is mainly derived from amortisation of development assets.  
 
Other operating expenses amounted to EUR 18.7 million in 2024 (2023: EUR 9.7 million), an increase of 
92%. The main increase is due to consultants, and a general increase in expenses due to increased activity. 
Profit/loss 
The Group’s profit before tax for 2024 was EUR 26 million (2023: EUR 18.7 million), an increase of 39%.  
 
The Company’s loss before tax for 2024 was EUR 69.2 million (2023: EUR 55.4 million). The main 
contributions to the results in 2024 arose from impairment losses of EUR 60 million (2023: EUR 55.6 million) 
from the distribution of Platform & Sportsbook.

===== SIDA 8 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
7 
 
 
Directors’ report - continued 
Net finance costs 
Finance costs, in 2024, amounted to EUR 13.9 million (2023: EUR 9.5 million). The increase in borrowing 
costs is a result of the new bond being issued at the end of 2023, including the EUR 15 million subsequent 
issue under the EUR-tranche in June 2024, increasing the EUR tranche to EUR 60 million. 
 
Finance costs also increased as a result of unwinding on deferred considerations amounting to EUR 3.5 
million in 2024 (2023: EUR 2.2 million). 
Financial position 
The largest asset on the balance sheet relates to intangible assets of EUR 96.2 million (2023: EUR 93.0 
million). The increase is attributable to goodwill and other intangible assets through primarily the acquisition 
of Titan Inc., Casinomeister and two other assets during the period. Intangible assets at 31 December 2024 
mainly comprise goodwill generated through business combinations (EUR 34 million), affiliate assets 
acquired (EUR 47.2 million), client contracts acquired (EUR 6.6 million) as well as development of technology 
platform (EUR 7.8 million). 
 
Trade and other receivables amounted to EUR 27 million at 31 December 2024, which is a large increase 
from 2023 where the amount was EUR 18.5 million at 31 December 2023. This increase is attributable to the 
general increase in revenue. 
 
The Group closed out the year with a healthy balance of cash and bank deposits amounting to EUR 11.3 
million; the Group’s cash and bank deposits in 2023 amounted to EUR 15.3 million. In June 2024, the 
Company completed a EUR 15 million subsequent issue under its current 2023-2026 Senior Secured Bonds, 
increasing the EUR tranche to EUR 60 million. The proceeds were used towards financing the acquisition of 
CasinoMeister, deferred payments for KaFe Rocks and general corporate purposes. The Group has also 
secured a facility with Citibank of EUR 25 million, EUR 7 million were drawn as at year end.  
 
Significant liabilities in the Group’s balance sheet include deferred consideration and borrowings. Deferred 
considerations have increased, mainly due to the deferred payments associated with the acquisitions from 
2023 and 2024 which amounted to EUR 33.3 m illion as at 31 December 2024, which is included as current 
liabilities. 
 
Group financing and cash flows 
The Group experienced a net cash inflow from operations during the year of EUR 37.1 million (2023: EUR 
44.6 million). Net cash generated from operating activities was mostly utilised to fund investment in non -
current assets, payment of bond interest and le ase payments. The cash generated through financing was 
utilised for the acquisitions of AskGamblers and KaFe Rocks.

===== SIDA 9 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
8 
 
 
Directors’ report - continued 
Performance from discontinued operations 
 
Following shareholder approval at an extraordinary general meeting on 23 September 2024, the split was 
executed on 30 September 2024, dividing the Company into two independently listed companies and thereby 
completing the strategic review. 
 
Revenues from discontinuing operations for 2024 decreased to EUR 29.4 million (2023: EUR 52 million).  
 
The discontinued operations experienced an increase in operating expenses from EUR 53.2 million in 2023 
to EUR 105.8 million in 2024. This is driven mainly by the impairment losses of EUR 51.1 million in 2024.  
 
Financial position 
In accordance with IFRS 5, Platform & Sportsbook financial results are presented as a discontinued 
operation, and the assets and liabilities of this disposal group held for distribution have been separately 
presented in the financial statements for the year ended 31 December 2023 and at distribution date which is 
30 September 2024. The results from Platform & Sportsbook have been reported as a discontinued operation 
in the Group’s consolidated financial statements. 
 
The assets associated with the discontinued Platform & Sportsbook operations had a carrying amount of 
EUR 81.4 million as at 30 September 2024. 
 
The liabilities associated with the discontinued Platform & Sportsbook operations had a carrying amount of 
EUR 25.4 million as at 30 September 2024. 
 
Effect on the Company due to spin-off 
For the Company to prepare for the completion of the spin -off, the share capital had several movements 
during the year.  
● On 26 March 2024, the Company increased the authorised share capital to 149,999,999 Ordinary ‘A’ 
shares and 1 Ordinary ‘B’ share. 
● With effect from 13 June 2024, the issued share capital was increased by 115,000,000 Ordinary ‘A’ 
shares through the capitalization of capital reserves; the transaction did not involve any consideration 
(please refer to note 15). 
● With effect from 18 September 2024, the issued share capital was reduced through the cancellation 
of 100,412,000 Ordinary ‘A’ shares, in consideration of which the Company transferred its investment 
in GiG SpinCo, Inc to the Company’s Parent. 
 
The investments in subsidiaries at a Company level belonging to this segment were impaired by an amount 
of EUR 60 million through which their carrying amount was reduced to be equal to the post -spin-off market 
capitalization of this segment once it started trading as a separate group.

===== SIDA 10 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
9 
 
 
Directors’ report - continued 
Performance from discontinued operations - continued 
 
The disposals through distribution of Platform & Sportsbook amounted to EUR 56 million which was the asset 
value that affected the total market value. 
 
Before the spin-off on 30 September 2024, an investment took place in a new incorporated subsidiary of EUR 
10 million, which was incorporated in preparation for the spin -off of the Group’s Platform & Sportsbook 
segment. The Group had temporary control over this subsidiary which was spun off as part of the new Group. 
 
As part of the spin off, GIG Central was transferred to GIG Software PLC, and the respective company had 
payment plans in relation to VAT and Social Security of previous years, and based on an agreement entered 
into with the Group, Gentoo has to settle 50%  of such dues, which amount to EUR 2.5 million. During 2024, 
Gentoo paid EUR 1 million, with the remainder being payable in 2025. 
 
Going concern 
 
As at 31 December 2024, the Group’s current liabilities exceeded its current assets by EUR 49,725,088.  
 
2024 was a transformative period for the Group and after successfully completing the strategic split 
announced by the Board, the Group is well positioned as a stand -alone business to capitalize on growth 
opportunities and enhance its market presence. In Ma y 2024, the Group completed the acquisition of Titan 
Inc. Limited which in line with the Group’s strategy was acquired with the objective to create long -term 
sustainable growth and from which the Group expects to obtain significant cost synergies. The full  revenue 
and cost savings impacts are therefore expected for 2025. The Group is well -positioned for moving into a 
growth phase to reach its aspirations for the future. 
 
Further, during 2024 the Group also achieved material revenue growth of 39%, both organically and due to 
prior year acquisitions. The Group has therefore proven its ability to integrate acquired businesses enhancing 
the growth potential of the Group. 
 
The Group’s net cash generated from operating activities, which includes the discontinued platform business, 
declined to EUR 37.1 million due to negative net working capital in 2024 compared with EUR 44.6 million in 
2023. The Group expects strong cash gene ration for 2025 in line with the Group’s business plans and track 
record over the years and expects a total outflow of EUR 35 million in payments related to acquisitions made 
in previous years, of which approximately EUR 23 million was settled in Q1 2025.  
 
Further, in December 2024, the Group negotiated a EUR 25 million revolving credit facility with Citibank to 
ensure short term liquidity and long-term strategic partnership on financing. 
 
At year end EUR 7 million was borrowed on the revolving credit facility and subsequent to 31 December 
2024, EUR 16 million was drawn down to pay off current liabilities. Group management assesses that, based 
on the current business performance and the cred it facilities available, the Group has sufficient capital 
resources to continue its operations and to realise its strategic ambitions for the future.  
 
As a result of the above, the board of directors consider the going concern assumption in the preparation of 
the Group’s and Company’s financial statements to be appropriate as at the date of authorization of issuance 
of the 2024 Annual Report and Consolidated Financial Statements.

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Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
10 
 
 
Directors’ report - continued 
Significant risks and uncertainties 
 
General 
Regulatory and compliance risk is by and large one of the biggest external risks faced by the Group as the 
business provides services to regulated entities and operates in an increasingly regulated industry. Over the 
course of 2024, such risk applied to bo th continued and discontinued operations. While the risk from the 
Platform business lasted just prior to the split (i.e. end of September 2024), this business segment subjected 
the Group to an even higher level of regulatory and compliance risk due to its exposure to player funds, 
technical obligations and a higher level of regulatory reporting, stemming directly from B2C license 
requirements held by the business itself, but also indirectly, due to B2B requirements imposed on the 
gambling operators it serviced.  Legislation concerning online gaming is under review in certain jurisdictions, 
and in some circumstances, previous opportunities to offer gaming products to certain customers based in 
some markets on principles of freedom to provide services may be i mpacted by new legal restrictions being 
imposed. In other cases, previously unregulated jurisdictions pass legislation regulating the market and while 
this creates new opportunities to offer products and services to those markets with legal certainty, such  
development also increase costs by fragmenting the international gambling market into national markets with 
a multitude of different requirements in terms of products, advertising and regulatory compliance.  
 
Although gaming laws and regulations of many jurisdictions do not specifically apply to the provision of affiliate 
marketing services, certain countries have also sought to regulate such services.  The Group may therefore 
be subject to such laws, directly or indirectly.  
 
This evolving environment and the Group’s continuing international expansion brings further complexity to its 
multi-jurisdictional regulatory position and its task to fulfil regulatory requirements, predominantly, advertising 
and responsible gaming regulat ion. The risk of non -regulatory compliance, the failure to obtain additional 
licenses if and where required (and the loss thereof), and/or failure of satisfying any conditions/terms under 
any existing licenses create an uncertain business environment and may hinder the Group’s ability to develop 
and grow the business, as changes in legislation or enforcement practices could force the Group to exit 
markets, potentially resulting in direct financial penalties, sanctions or litigation, ultimately having a mate rial 
adverse effect on the Group’s business, financial position, profits and prospects.  
 
The Group mitigates this risk through the monitoring of legal developments and implementation of relevant 
developments on the Group’s own assets, and by seeking external advice to assist with the assessment of 
risk exposures as appropriate. The Group also prioritises continuous education and updates for all staff 
regarding new and applicable regulatory developments, ensuring thorough awareness and alignment with 
any changes implemented. This proactive approach underscores our commitment to operating with in tegrity 
and regulatory adherence in every aspect of our business.

===== SIDA 12 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
11 
 
 
 
Directors’ report - continued 
Significant risks and uncertainties - continued 
 
The Group faces competition from a number of existing competitors, as well as potential new competitors, 
which could result in loss of market share and diminished profits for its operations. In this respect, there is an 
increased risk of competition when e ntering newly regulated markets due to competition faced from 
incumbent affiliates. 
 
The competitive nature of the industry is further characterised by the adoption of technological advances, 
demanding customer requirements and frequent innovative product offerings. Excluding negative external 
factors beyond its control, the Group’s future  success is heavily reliant on its ability to enhance its current 
product portfolio through new product offerings and continuous improvement, create attractive advertising 
campaigns, maintain relations with existing and new partners and suppliers, and havi ng the resources to 
sustain such development and growth. Failure to quickly respond and adapt to market demands and 
competition risk could adversely affect the Group’s financial performance. 
 
In addition to the above, the Group faces other risks that may have a material impact on its financial standing. 
These include, customers that default and are unable to  pay for the services rendered when these fall due, 
operational risks arising from Goog le’s core updates to its search  algorithm which could temporarily 
negatively impact rankings (hence also impacting revenues) and currency fluctuations which could have a 
material impact on cash flow, notwithstanding the risks stemming from internal factor s, including, 
reorganisation risk faced following the spin-off in 2024, the dependency on key management employees and 
partners, difficulty in finding resources, cyber security and acquisition risks.  
 
Financial risk management 
 
Information on the Group’s and Company’s financial risk management is disclosed in Note 3 of the 
consolidated financial statements. 
 
Pledged securities 
 
The entirety of the Company’s issued share capital, comprising of fourteen million, six hundred and thirty -
seven thousand, nine hundred and ninety -nine (14,637,999) Ordinary ‘A’ shares and one (1) Ordinary ‘B’ 
share, all having a nominal value of one Euro (EUR1) each, held by Gentoo Media Inc. and Jonas Warrer 
respectively, has been pledged in favour of Nordic Trustee AS, acting as the agent on behalf of bond holders. 
The bonds are secured by guarantees provided by group operating subsidiaries guaranteeing the discharge 
of the Company’s obligations. 
 
Results and dividends 
 
The income statements are set out on page 58. The directors did not declare a cash dividend during the 
current and preceding financial years. 
This year’s equity has been impacted by a non -cash distribution of EUR 56 million related to the spin -off of 
Platform & Sportsbook.

===== SIDA 13 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
12 
 
 
Directors’ report - continued 
Directors 
 
The directors of the Company who held office during the period were: 
 
● Mr. Justin Psaila (resigned on 2 May 2024) 
● Mr. Richard John Carter (appointed on 27 October 2023 and resigned on 23 September 2024)  
● Mr. Giuseppe Muscat (appointed on 2 May 2024) 
● Mr. Jonas Warrer (appointed on 23 September 2024) 
 
The Company’s Articles of Association do not require the directors to retire.  
 
Statement of directors’ responsibilities for the financial statements 
 
The directors are required by the Maltese Companies Act (Chapter 386 of the Laws of Malta) to prepare 
financial statements that give a true and fair view of the state of affairs of the Group and Company as at the 
end of each reporting period and of the profit or loss for that period. 
 
In preparing the financial statements, the directors are responsible for: 
 
● ensuring that the financial statements have been drawn up in accordance with International Financial 
Reporting Standards as adopted by the EU; 
● selecting and applying appropriate accounting policies; 
● making accounting estimates that are reasonable in the circumstances;  
● ensuring that the financial statements are prepared on the going concern basis unless it is inappropriate 
to presume that the Group and Company will continue in business as a going concern.

===== SIDA 14 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
13 
 
 
Directors’ report - continued 
 
Statement of directors’ responsibilities for the financial statements - continued 
 
The directors are also responsible for designing, implementing, and maintaining internal control as the 
directors determine is necessary to enable the preparation of financial statements that are free from material 
misstatement, whether due to fraud or error, and that comply with the Maltese Companies Act (Chapter 386 
of the Laws of Malta). They are also responsible for safeguarding the assets of the Group and Company and 
hence for taking reasonable steps for the prevention and detection of fraud and other irregularities. 
 
Signed on behalf of the Board of Directors, as per the Directors' Declaration on ESEF Annual Financial Report 
with the Annual Report and Consolidated Financial Statements 31 December 2024  
 
 
 
__________________________________  __________________________________ 
 
Mr. Jonas Warrer     Mr. Giuseppe Muscat 
Director       Director 
 
 
11 April 2025

===== SIDA 15 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
14 
 
 
Sustainability report 
 
1. SCOPE  
2. SUSTAINABILITY GOVERNANCE  
3. NON-FINANCIAL STATEMENT  
3.1 BUSINESS MODEL  
Business Environment  
Organisation and Structure  
Markets and Operations  
Objectives and Strategies  
Factors that affect the Group’s Future Development  
4. ENVIRONMENTAL MATTERS  
4.1 ENVIRONMENTAL IMPACT FROM ENERGY USE  
4.2 DIRECT AND INDIRECT ATMOSPHERIC EMISSIONS  
4.3 WASTE MANAGEMENT  
4.4 ENVIRONMENTAL IMPACTS FROM TRANSPORTATION OR FROM THE USE AND DISPOSAL OF 
PRODUCTS AND SERVICES  
5. SOCIAL AND EMPLOYEE MATTERS  
5.1 BUSINESS INTEGRITY & RESPONSIBLE BUSINESS PRACTICES  
5.2 EMPLOYEE MATTERS  
5.3 COMMUNITY RELATIONS & CSR INITIATIVES  
6. HUMAN RIGHTS MATTERS  
7. ANTI-BRIBERY AND CORRUPTION  
7.1 BUSINESS INTEGRITY  
7.2 WHISTLEBLOWER PROTECTION  
8. OTHER MATTERS  
9. CONSOLIDATED DISCLOSURES PURSUANT TO ARTICLE 8 OF THE TAXONOMY REGULATION  
9.1 OUR ACTIVITIES  
9.1.1 Overview  
9.2 TAXONOMY-ELIGIBLE AND TAXONOMY-ALIGNED ECONOMIC ACTIVITIES  
9.2.1 Identification of Taxonomy-eligibility of Turnover-generating Activities  
9.2.2 Taxonomy eligibility of Investment Activities not directly related to turnover-generating activities  
9.2.3 Taxonomy Alignment  
9.3 OUR KPIs AND ACCOUNTING POLICIES  
9.3.1 Turnover KPI  
9.3.2 CapEx KPI  
9.3.3 OpEx KPI

===== SIDA 16 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
15 
 
 
SUSTAINABILITY REPORT 
FOREWORD 
In today’s rapidly evolving business landscape, climate change impacts and increasing consumer demands, 
the intersection of business, consumer retention, technology and sustainability has never been more critical. 
We recognize our responsibility to not only drive growth and innovation but also to make a positive and lasting 
impact on our employees, the communities and the environments in which we operate and affect through our 
operations. 
This report serves as a transparent account of our commitment to sustainability, in line with the EU’s Non -
Financial Reporting Directive (NFRD) and the EU Taxonomy Regulation. As we build on previous years’ 
efforts, we have made significant strides in alig ning our operations and reporting with these frameworks, 
which guide us toward fostering greater environmental, social, and governance (ESG) accountability. From 
carbon footprint reduction to promoting responsible gaming, we continue to adopt industry best practices that 
contribute to long-term sustainability and will continue to do so in 2025 and beyond as we keep ESG at the 
core of our sustainability strategy and disclosures.  
As we transitioned to a stand-alone affiliate marketing business, our aim was to offer a clear, detailed picture 
of how our current business practices integrate with the EU’s sustainability goals and outline the steps we 
are taking to continue building on this foundation and further enhance our resilience as a business and 
contribution to a more ethical future. By embracing these practices and values, we not only ensure 
compliance with the ever -evolving regulatory landscape, but also underscore our commitme nt to integrity, 
transparency and the well-being of our stakeholders. 
We hope this report provides valuable insights into our sustainability journey and the ongoing efforts we are 
making to positively impact the world around us. Together, as businesses, policy -makers and investors, we 
can shape a future where the online gami ng sector leads by example in terms of technological innovation, 
consumer experience and sustainable long-term growth. 
 
Diane Ellul 
Head of Compliance

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1. SCOPE 
This non -financial disclosure for the fiscal year ending 31 December 2024 has been prepared on a 
consolidated basis, which includes the sustainability statements of the reporting undertaking, Gentoo Media 
p.l.c. (the “Company” or “Gentoo Media”), and its subsidiaries (the “Group”). 
The scope of consolidation is the same as for the financial statements in accordance with the International 
Financial Reporting Standards as well as Article 48i of Directive 2013/34/EU. In this respect, all subsidiary 
undertakings included in the consolida tion are exempted from individual or consolidated sustainability 
reporting pursuant to Articles 19a(9) or 29a(8) of Directive 2013/34/EU. This accounts for Gentoo Media p.l.c. 
and its subsidiaries. 
Discontinued operations (that is, the Platform & Sportsbook business) have been excluded from the scope 
of this non -financial disclosure. Therefore, what follows are non -financial disclosures solely relating to the 
Affiliate Marketing business segment. 
Establishing the business context is key to identifying material non -disclosures relating to environmental, 
social and employee, anti-bribery and corruption, human rights and other matters which we deem significant 
to the Group’s disruption and/or success.  In this respect, a number of factors were taken into account when 
identifying material non-financial disclosures for the Group: 
 
- Our business model, goals, strategies, management approach and systems, values, intangible 
assets, value chain and principal risks; 
- The business’ relationship with key stakeholder groups, specifically those affected stakeholders 
(such as, our shareholders) and users of our non -financial statement (such as, existing and 
prospective investors) as this helped to ensure that the assessment  of non -financial matters is 
relevant and aligned with stakeholder interests and expectations; 
- Main sectoral issues affecting our competitors as well as those affecting our customers or suppliers 
which may also be relevant to us; 
- The actual and potential impact (in terms of likelihood and severity) of our services and business 
relationships; and 
- Public policies and regulations (such as gaming regulation). 
 
Reference was also made to the latest financial results to identify revenue streams and business 
relationships, desk-based research to identify sectoral issues as well as management feedback to arrive at 
a comprehensive assessment of material non-financial disclosures. 
 
In this respect, the table below is intended to provide insight into our development, performance, position and 
impact of our business activities with regards to material non -financial matters, specifically environment, 
social and employee, human rights, a nti-bribery and corruption, and other relevant sectoral matters related 
to our supply chain.

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NON-FINANCIAL MATTERS DISCLOSURES 
Environmental Matters 
 
 
- Environmental impact from energy use; 
- Direct and indirect atmospheric emissions;  
- Waste management; 
- Environmental impact from transportation or from 
the use and disposal of products and services; 
- EU Taxonomy Disclosures (Section 9). 
 
Social and Employee Matters 
 
- Business Integrity & Responsible Business 
Practices; 
- Employee Matters; 
- Community relations & CSR initiatives. 
 
 
Respect for Human Rights Matters 
 
- Human Rights 
Anti-Bribery and Corruption Matters 
 
- Business Conduct/Ethics; 
- Protection of Whistleblowers. 
Other Matters 
 
 
- Supply Chain 
 
 
 
 
2. SUSTAINABILITY GOVERNANCE 
Our sustainability governance framework ensures accountability, oversight, and effective implementation of 
ESG initiatives across the organization. 
Board Oversight:  The Board of Directors provides strategic direction and oversight of our sustainability 
agenda, ensuring alignment with our corporate values and long -term business objectives that drive 
sustainable growth and stakeholder value. 
ESG and Compliance Committee: On 10th March 2025,  an ESG and Compliance Committee was 
established with the scope of providing guidance and advice to the Board on sustainability and compliance 
matters. This Committee comprises of two Board members, the General Counsel and the Head of 
Compliance. It plays a crucial role in: 
● Monitoring regulatory developments and compliance with sustainability-related requirements; 
● Assessing ESG risks and opportunities, ensuring alignment with best practices; and 
● Overseeing stakeholder engagement and sustainability reporting. 
ESG Leadership and Implementation:  Following the split, the Head of Compliance has taken the lead on 
sustainability, including the compilation of a Double Materiality Assessment in Q4 2024 as well as reporting, 
and works closely with internal teams and external stakeholders to understand c urrent impacts, risks and

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opportunities with a view of implementing a sustainability action plan for 2025 and beyond. Key 
responsibilities include: 
● Driving ESG initiatives across business functions; 
● Ensuring compliance with ESG regulations, industry standards, and voluntary frameworks;  
● Monitoring progress and performance through key ESG metrics; and 
● Preparing and presenting sustainability reports to the ESG and Compliance Committee and the 
Board on a quarterly basis. 
Through this governance framework, we are committed to transparency, continuous improvement, and 
meaningful action in our sustainability journey. By embedding ESG principles into our corporate governance, 
we aim to create long -term value for our stakeholde rs and contribute positively to the environment, society 
and our employees. 
3. NON-FINANCIAL STATEMENT 
In accordance with Article 19a of Directive 2013/34/EU which outlines requirements for non -financial 
disclosures, we are hereby providing an overview of our business model with the intent of providing context 
to our non -financial statement. This is followe d by the disclosure of the material non -financial matters that 
affect key stakeholder groups. In this regard, a thorough assessment of key activities, value chain actors and 
material risks arising in the value chain was carried out through discussions with  top management and 
reference to financial results to identify revenue streams and business relationships.  
3.1 BUSINESS MODEL 
Our primary focus is to expand our business year-on-year through organic growth, forging new partnerships 
and exploring strategic acquisitions. As the gambling affiliate industry continues to evolve through significant 
changes in the regulatory landscape, we are committed to staying ahead by identifying and seizing 
opportunities that drive sustainable long-term value. Our team remains dedicated to strengthening our market 
position while ensuring operational excellence across our businesses. 
Business Environment 
As a gambling affiliate marketing company, we advertise and promote our partners with the aim of generating 
traffic to their sites in return for a commission. Fundamentally, the Group’s marketing services are split into 
the following two products - Publishing and Paid Search - which respectively contribute to organic and 
inorganic growth: 
1. Publishing - Through the use of Gentoo assets to promote our partners, this product line 
focuses its efforts to enhance platform performance, improve search visibility, and seize 
growth opportunities across its core assets; and 
2. Paid Search - This product line remains focused on data-driven media buying, ongoing 
optimisation of bidding strategies and further advancements in automation, ensuring that 
Gentoo is well-positioned to deliver strong returns and maintain margin resilience in 2025.  
Compensation models vary from fixed monthly payments, a fixed fee in -line with the amount of traffic 
generated to the operator site (“cost per acquisition”), revenue share (a percentage of the deposits made by 
leads at operator sites) or hybrid models.

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The above product lines form part of the same value chain (i.e. the supply chain and the downstream value 
chain are identical for each product line). 
Alongside key supply chain actors (these mainly being search engines and social media channels), the 
Group’s own workforce and assets are at the heart of its operations and product offerings.  
Organisation and Structure 
The Group’s workforce largely consists of direct employees spread across five locations (Malta, Denmark, 
Serbia, Spain and England), as well as freelancers that work remotely and are generally engaged on a project 
basis. Group assets include intangible (di gital) assets (such as, internet domains and social media pages), 
intellectual property, internal IT infrastructure (hardware) and proprietary software (SiteBee (formerly GIG 
Comply)). In turn, these enable the provision of marketing services to customers (and other downstream 
value chain actors) via client -facing entities within the Group, these being Innovation Labs Limited, 
AskGamblers Limited, Kafe Rocks Group, Rebel Penguin ApS and BE Marketing Ltd.  
Markets and Operations 
The Group operates across a number of jurisdictions, globally, in both regulated and unregulated markets. 
The provision of affiliate marketing services is regulated in certain jurisdictions and, in this respect, the Group 
holds affiliate licenses in Romani a, Greece and some US states (Arizona, Colorado, Indiana, New Jersey, 
Massachusetts, Michigan, Virginia, Washington DC, West Virginia and Pennsylvania), which may in turn 
regulate the revenue streams that can be availed of by the Group. Such is the case in  the US, where the 
allowable revenue streams are determined according to the level of authorisation available in a particular 
state and granted to the affiliate applicant. Generally, vendor minor licenses (or “registrations”) permit fixed 
fee payments (on a monthly basis and/or on a cost per acquisition basis) whereas vendor major licenses 
allow both fixed fees and revenue share compensation deals.  
 
Through its own operations (including its workers), the Company services its key stakeholders in the 
downstream value chain, these being the Company’s partners (i.e. online gambling operators) who in turn 
provide the end users in the value chain (i.e. players) access to a gambling platform across several regulated 
and unregulated markets. 
 
Gambling authorities play a key role in the downstream value chain and have a crucial, (in)direct impact on 
our business operations. Excluding the regulators that directly regulate affiliates (thus directly imposing 
regulations and periodic reporting oblig ations), gambling authorities world -wide generally regulate B2C 
licensees (i.e. online casino/sportsbook operators) which hold liable all licensees for any third -parties 
engaged by them for services made on their behalf. As a result, Gentoo and its competitors are also indirectly 
regulated with respect to advertising regulations and obligations to advertise lawful and authorised gambling. 
 
Given the highly dynamic and regulated industry we operate in, where regulation varies world -wide, the 
interplay between regulators, B2C licensees and affiliate marketing companies requires us to adopt efficient 
and effective operational change management procedures to quickly adapt and comply with new regulatory 
developments and requirements.

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Objectives and Strategies 
Our objectives are driven by our diversification strategy and commitment to legal and regulatory compliance, 
which are to consistently drive high -quality traffic to various partners across different gaming verticals and 
jurisdictions and across both high -performing and emerging assets, generate revenue and maximise 
shareholder returns, whilst giving high regard to the risks of gambling and gambling addiction especially to 
minors and vulnerable individuals and ensuring that these are prioritised.  
Here is how we fit these considerations into practice: 
 
● Maintain strong partnerships with responsible operators that are transparent and promote 
trustworthiness; 
● Work towards maintaining revenue share agreements to secure recurring revenue streams;  
● Optimize the performance of advertising campaigns through quality content designed by our team 
(not bots) to contribute to a higher ranking on Google and other search engines;  
● Uphold the highest standard of business conduct through compliance with legal and regulatory 
standards thus avoiding penalties, sanctioning and ensuring long-term business sustainability; 
● Brand awareness and reputation management; 
● Expand market reach; 
● Promote responsible gambling practices, raise awareness of gambling addiction risks and provide 
access to help and support services; 
● Engage in ethical marketing by promoting content that targets individuals of legal gambling age and 
avoiding the use of imagery, characters and text that appeal to minors and vulnerable individuals.  
 
Ultimately, our objective is to create a winning situation for all stakeholders including ourselves, our partners 
and our shareholders and investors through a long-term, sustainable business. 
Factors that affect the Group’s Future Development 
 
Factors Potential Impact 
Geopolitical, societal factors 
Adverse instability and/or uncertainty (e.g., political 
instability, conflicts, trade wars, pandemics or disease 
outbreaks, labor and/or infrastructure-related risks, etc.) 
Negative 
Financial loss, due to a reduction in players’ disposal 
income leading to less demand for online gambling  
Acquisitions 
As part of the Group’s growth strategy, the Group 
continuously considers the acquisition of other 
companies or assets.  
Positive 
Acquisitions may complement or expand the Group’s 
existing business and create economic value to 
shareholders.  
 
Negative 
- Reduction in the general oversight on existing 
business as management diverts attention and 
resources to the integration of the new business. 
- Challenges derived from maintaining 
relationships with employees and customers of 
acquired business which may lead to a loss of 
key employees and customers.

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- Increasing demands on the Group’s operational 
systems. 
- Difficulty in integrating shared services with the 
Group’s existing business, higher than expected 
employee severance or retention costs, 
overhead expenses and delays in anticipated 
timing of activities related to any cost -saving 
plans. 
- High integration costs with potential adverse 
effects on the Group’s reported operating results, 
particularly during the first few reporting periods 
after such acquisitions are completed. 
- The inability to integrate and implement effective 
disclosure controls and procedures for financial 
reporting within allowable time frames. 
- Potential unexpected liabilities that the Group 
failed, or was unable, to identify in the course of 
performing due diligence on historical and/or 
future acquisitions. 
- Challenges associated with building a unified 
corporate image. 
 
Licensing 
Increasing international gambling market fragmentation 
into national markets with a multitude of different 
regulatory requirements. 
Positive 
Positive impact creating new market opportunities, with 
controls that safeguard the business and market 
sustainability. 
 
Negative 
The loss of, or failure to obtain additional licenses 
(including failure to obtain renewal of any licenses), the 
reduction of the addressable market under an existing 
professional license and/or failure of satisfying any 
conditions/terms under any existing licenses could have a 
material adverse effect on the Group’s business, financial 
position, profits and prospects. 
Legal and Regulatory Compliance 
The regulation of online gambling is extensive and varies 
significantly world-wide. Regulation is always subject to 
change, particularly when political factors come into play 
(such as, a change in governance). 
Positive 
Regulation and enforcement create long -term 
opportunities for online gambling operators that operate 
with integrity and the highest standards of business 
conduct, thereby leaving little to no room for those that may 
harm end users (players) and tarnish the  industry’s 
reputation. 
 
 
Negative 
Adverse impact on the Group’s financial performance due 
to potential penalties arising from non -compliance to new 
legislation, especially around social responsibility 
obligations, including more stringent regulatory conditions, 
advertising and responsible gambling regulation.

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Regulatory changes may also have an indirectly adverse 
effect on the Group by restricting customers’ use of 
gambling websites, or by requiring financial institutions to 
prevent transactions between customers and gambling 
operators. This may lead to a compl ete pull-out from the 
markets in which the Group operates today. 
 
Regulatory changes may also involve the complete 
regulation of online gambling in a previously non-regulated 
target market, which would require the Group to meet 
regulatory requirements and to stop servicing 
unauthorised operators. This may have an adverse  effect 
on the Group’s financial position due to new compliance 
costs and loss of business. 
 
Competition 
Competition faced by existing and new competitors, 
which is further characterised by the industry’s adoption 
of technological advances, new product offerings and 
evolving customer requirements. 
 
Increased risk in competition when entering newly 
regulated markets due to competition with incumbent 
affiliates. 
Positive 
Opportunity to continue developing the Group’s service 
offerings to further strengthen its position in the market. 
 
 
Negative 
Lower end customer reach and reception if the Group does 
not remain attractive through new product offerings, 
intriguing advertising campaigns, maintain good 
relationships with its suppliers and customers and having 
the resources in place to sustain its de velopment and 
growth and to remain relevant in the market. 
Talent  
The Group’s success is driven by, and is largely 
dependent on its ability to recruit, train and retain key 
personnel such as the Board of Directors, the CEO, the 
rest of the management team and certain skilled 
specialist employees, particularly operational  and 
technical personnel.  
Positive 
Our employees are the heart of the business. The 
retention of key roles is pivotal to ensure that knowledge 
is retained and further developed within the Group. 
Nonetheless, the integration of new talent may bring in 
fresh perspectives, especially senior ma nagement roles 
who may positively contribute to solving legacy issues and 
new, strategic approaches. 
 
Negative 
Failure to hire and retain key employees or to integrate 
new talent to supplement the existing team could affect the 
Group’s ability to successfully implement its business 
objectives which may adversely affect its financial 
performance.  
 
Third Party Exposure 
The Group holds agreements with external providers, 
including, marketing partners (such as, advertising 
networks and digital tabloids), service providers (such as, 
search engines), customers (online casino / sports 
betting operators) and its development, performance and 
Positive 
Reliable third-parties across the entire value chain provide 
strong business relationships based on mutual trust and 
respect and effective resolutions, thereby fostering long -
term collaboration which supports the Group’s 
sustainability as a business.

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position is largely dependent on the integrity, 
performance and relationships with all third parties. 
 
Negative 
The Group is exposed to risk of financial loss and financial 
crime (ML/FT) risk, specifically, from its customers.  
 
Financial risk is derived from clients that refuse to honour 
payment terms, while ML/FT risk is derived from the 
clients' own corporate structures, operations in 
jurisdictions with weak enforcement and lax controls, 
involvement of politically exposed persons (PEPs), and the 
presence of sanctioned key company individuals. These 
risks, if materialised, can have a detrimental effect on the 
Group's reputation. 
 
International Operations 
The Group operates world -wide in a number of 
jurisdictions.  
Positive 
Market and customer diversification which compensate for 
negative effects, such as reduced business activity in 
some regions (for example, due to seasonal effects, 
regulatory changes) and market pull-out by customers. 
 
Negative 
International operations are subject to a variety of risks, 
including the overlap of different tax regimes, differing 
legal and regulatory requirements, fluctuations in currency 
exchange rates, localisation of service offerings and  
reduced protection for intellectual property rights in some 
jurisdictions. 
Supply Chain  
Dependency on key suppliers, such as search engines. 
Positive 
Search engine updates may improve our rankings on 
search engines, which may result in a greater reach and 
customer conversion.  
 
 
Negative 
Search engine updates may significantly disrupt rankings 
which in turn may significantly result in a loss in revenue. 
Further information is provided in Section 8. 
 
Legal and regulatory compliance, supply chain dependencies, technological advancements, seasonal 
impacts and increasingly demanding consumer expectations remain characteristic of the industry we work 
in. Over and above, specifically during the past year, the Group has also encountered three main challenges 
which have negatively impacted its growth in 2024: 
 
● Strategic Split  - This past year has been largely defined by the execution of a strategic split, 
transitioning to a full affiliate-focused business, following the divestment of our Platform & Sportsbook 
operations at the end of Q3 2024. The Group has worked autonomously from its discontinued 
operations from the start of 2024 and, throughout the year, the business was faced with new 
operational costs and complexity that have inevitably affected revenue and cashflow and distracted 
the full-on focus otherwise given to the normal course of business. At the same time, the split has

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also positioned our business in a favourable position to capitalize on growth opportunities and 
enhance our market presence, both organically and through several acquisitions, resulting in record 
results and significant growth which has reinforced our mark et position, consistently outperforming 
our competitors. 
● Brazilian Market - Market regulation in Brazil negatively affected earnings in the last quarter of 2024 
and this impact is expected to continue into the start of 2025 as we anticipate short -term challenges 
being faced by operators as they adapt to the new regulations. 
● Google Core Updates  - The past year has seen four Google core updates which, despite 
contributing to better rankings for some websites, have predominantly negatively impacted one of 
our flagship brands (Casino Tops Online) in Q1 2024. Further information is provided in Secti on 8. 
 
While recognising the strategic split to be a one -time factor, market regulation and dependency on search 
engine algorithms remain inherent challenges faced by the business, thus further emphasizing the 
importance of a diversification strategy (across part ners, jurisdictions and assets), focus on high -value 
markets (Europe and the Americas), high-value players, recurring revenue streams and targeted investments 
in key emerging markets. Despite such great challenges - contributing to a higher EBITDA in 2024 vis-a-vis 
previous years - the affiliate business still yielded a 39% increase in revenue YoY, as reported in the financial 
statements in 2024’s Annual Report. 
 
As we move beyond the operational split, Gentoo can solely focus on its diversification strategy in 2025, 
aimed at driving sustainable long-term growth which, from a non-financial standpoint, is measured against a 
number of key performance indicators relative to Publishing and Paid Search, including, ranking position for 
specific keywords in search engines, traffic volume to our websites, bounce rate, session duration, click -
through rates on “calls-to-action”, new registering customers, first-time depositors, impressions, ad clicks and 
aggregated clicks. 
 
4. ENVIRONMENTAL MATTERS 
4.1 ENVIRONMENTAL IMPACT FROM ENERGY USE 
The business has a negative impact on climate change due to the energy consumption from non-regenerative 
resources within Gentoo’s own operations, that is, purchased electricity and one on -prem server at its Malta 
headquarters. The amount of energy use (and its contribution to climate change) is counteracted by the fact 
that the location of occurrence is concentrated to our physical office locations so the impact is not widespread 
across a significant area which would have otherwise contributed to a larger,  negative impact on the 
environment. 
 
In terms of its upstream and downstream value chain, Gentoo has no visibility into the energy consumption 
methods used by its suppliers and customers.  
 
Gentoo’s supply chain is widespread across several countries, involving multi -national service providers 
(such as Google) with a high energy footprint. The impact from our upstream value chain can be mitigated in 
the future through supplier engagement plan s and codes of conduct that highlight the need of certified 
suppliers with less energy-intensive datacentres.

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With regards to our downstream value chain, all activities are carried out from Gentoo offices, all of which 
currently rely on purchased electricity to power operations, thus all energy is consumed from non -
regenerative sources.  
 
We are aware that positive impacts to the environment can be made through improvements to our entire 
value chain, despite generating a relatively low amount of atmospheric emissions (as outlined in Section 4.2 
below). However, we remain committed to preser ve our environment and community at large, and by 
prioritising our own operations, the Group is considering investing in alternative (and renewable) energy 
sources, such as solar energy, especially in offices located in the Mediterranean (Malta and Spain) where 
solar energy is abundant. 
4.2 DIRECT AND INDIRECT ATMOSPHERIC EMISSIONS 
The generation of Scope 1 & 2 GHG emissions deriving from the Group's own operations is mainly caused 
by purchased electricity in addition to one on-premises server. 
 
Upstream activities that generate Scope 3 GHG emissions include: 
● Sourcing and delivery of IT equipment to the workforce: local suppliers are sourced at each 
respective office location which deliver equipment to individuals that are office -based by land and to 
remote workers using a combination of land/air/sea modes of transportation; 
● Delivery of employee lunches to all offices by local suppliers by land on a daily basis;  
● Delivery of drinking water to all offices by local suppliers by land on a weekly basis and 
● Ad-hoc local and international courier services utilising land transportation and a combination of 
different modes of transportation, respectively. 
 
Downstream activities generating Scope 3 GHG emissions are limited to air travel to other Gentoo office 
locations, conferences, events and client offices, since all Gentoo services are provided online.  
 
All three types of atmospheric emissions are calculated on a yearly basis through a carbon accounting 
platform. The latest consolidated GHG emissions for the year 2023 across Gentoo and the discontinued 
operations were calculated.  
 
The amount of Scope 1 and 2 emissions is not high and does not significantly contribute to damage on safe 
planetary boundaries. Despite the results, the Company still considers investing in renewable energy 
sources, as explained in Section 4.1 above, where by the Company plans on moving its Malta operations to 
another office on the island in the summer of 2025 and is looking into the possibility of installing solar 
photovoltaic panels to minimise its dependency on purchased electricity. 
 
Due to the currently limited amount of data available from our value chain activities, the Scope 3 GHG 
emissions results may not be very accurate, although it is expected that the impact of our upstream value 
chain activities on the planetary boundary of climate change to be medium as the supply chain varies across 
several geographies causing emissions from various transportation modes. In this regard, remediability of 
these emissions is very difficult and requires extensive value chain engagement activitie s.

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4.3 WASTE MANAGEMENT 
At Gentoo, we have implemented a number of initiatives to reduce and responsibly manage the amount of 
waste generated at our offices. 
 
At a high level, we have adopted resource -efficient practices to reduce resource consumption as much as 
possible, such as by avoiding the use of single-use products. In this respect, the following sustainable office 
practices have been implemented across all Gentoo offices: 
● The use of reverse osmosis as a source of filtered, drinking water to reduce the use of single -use 
plastic bottled water. Additionally, when bottled water is required, the company purchases drinking 
water contained in large 20litre containers to reduce the  amount of plastic otherwise used with the 
consumption of small, bottled drinking water. 
● All plastic consumed by all offices is segregated from other waste for recycling purposes.  
● Employee lunches are supplied in recyclable plastic containers. Regard is also given to food waste 
mitigation whereby (i) the number of employee lunches ordered corresponds to the number of office 
desk bookings and (ii) any extra lunches (such as those not  taken by no-shows) are left to be taken 
by staff. 
● Company merchandise has been limited to the necessary items, these being stationery and lanyards. 
Once the design of new merchandise (reflecting the new Company brand) is finalised, the Company 
plans to source suppliers that use recycled material for the production of such items. 
Moreover, all waste generated across all office locations is segregated in separate bins for recycling purposes 
pertaining to plastic, metal, food, general and electronic waste.  
 
When it comes to electronic waste, employees are given the opportunity to buy office equipment that cannot 
be used further at a discount. Once IT equipment (such as laptops) cannot be upgraded to the latest OS 
versions (thereby making them incompatible with certain software applications), the Group tries to reuse and 
allocate such equipment to less demanding roles not requiring the use of such software applications. Should 
that not be possible, this equipment is made available for sale to all employees at a  discount. Electronic 
equipment which cannot or is not sold, is segregated and collected by local government agencies which then 
handle its disposal. 
4.4 ENVIRONMENTAL IMPACTS FROM TRANSPORTATION OR FROM THE USE AND DISPOSAL OF 
PRODUCTS AND SERVICES 
The following are the upstream activities that generate Scope 3 GHG emissions:  
● Sourcing and delivery of IT equipment to the workforce - local suppliers are sourced at each 
respective office location which deliver equipment to individuals that are office -based by land and to 
remote workers using a combination of land/air/sea modes of transportation. 
● Delivery of employee lunches to all offices by local suppliers by land on a daily basis.  
● Delivery of drinking water to all offices by local suppliers by land on a weekly basis and  
● Ad-hoc local and international courier services utilising land transportation and a combination of 
different modes of transportation, respectively. 
 
Downstream activities generating Scope 3 GHG emissions are limited to air travel to Gentoo office locations, 
conferences, events and client offices as all Gentoo services are provided online.

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RISKS AND RISK MANAGEMENT (Environmental Matters) 
 
In preparation for CSRD reporting for FY 2024, a Double Materiality Assessment (DMA) was completed in Q4 2024 and 
an audit review was initiated. Although the audit was stopped and not completed due to the EU’s Omnibus Package 
proposal for CSRD, Corporate S ustainability Due Diligence Directive (CSRDDD), the EU Taxonomy and the Carbon 
Border Adjustment Mechanism (CBAM) simplification which was published on 26th February 2025, the initial assessment  
indicated that Group’s operations do not significantly contr ibute to environmental damage and, therefore, the risks 
emanating from its operations are non-material in this regard. 
 
5. SOCIAL AND EMPLOYEE MATTERS 
5.1 BUSINESS INTEGRITY & RESPONSIBLE BUSINESS PRACTICES  
Gentoo recognises the importance of adopting and applying effective measures for responsible business 
practices to remain attractive and competitive. 
 
Operating in multiple jurisdictions means navigating a complex landscape of varying regulations. Gentoo is 
committed to understanding and adhering to the specific requirements of each market it operates in, and 
therefore, is also committed to promoting com pliant and responsible business practices as mandated by 
gaming authorities and promoted by standard-setting bodies. This includes regulatory compliance, consumer 
protection and responsible gambling, GDPR compliance, respect for intellectual property right s, vetting of 
employees and third -party risk management. By tailoring our approach to the unique demands of each 
jurisdiction, we uphold our commitment to regulatory compliance on a global scale. This dedication is central 
to the Group’s mission of adhering to applicable legislation, codes of best practice and to fostering a safe and 
responsible gambling environment for players while also safeguarding minors and vulnerable individuals.  
 
Ensuring the highest standards of responsible business practices translates into the adoption, application 
and monitoring of policies and improvement thereof through self -assessment and the evaluation of new and 
innovative solutions.  
 
Here is how we commit to responsible business practices: 
 
A. REGULATORY COMPLIANCE 
The gambling industry is dynamic, with regulations frequently evolving to address new challenges. Over 
2024, in preparation for the split from GIG Platform, Gentoo has established its own in -house Compliance 
team which stays ahead of changes by closely mon itoring regulatory updates and ensuring our policies and 
procedures are promptly adjusted to comply with new laws. They disseminate this information across the 
Group, ensuring that all departments are aware of and adhere to the latest regulatory requiremen ts. This 
proactive approach minimizes the risk of non -compliance and reinforces our commitment to being a 
responsible business partner, whilst also safeguarding the long-term sustainability of the business. 
 
Expert Guidance and Advice: Our Compliance team plays a critical role in our operations by providing 
ongoing guidance and advice to the business with respect to regulatory requirements and interpretation. It 
continuously monitors regulatory developments and maps them against internal processes to ensure that our 
practices remain compliant. The team advises other departments, including, product development, design 
and account management on best practices and regulatory requirements. This ensures that every a spect of 
our operations aligns with the latest standards and promotes a safe gambling environment.

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Cross-Departmental Collaboration: Compliance is a collective effort that requires collaboration across all 
departments. The compliance team works closely with other teams to integrate compliant business practices 
into every aspect of our operations. For instance, they collaborate with the content, design and SEO teams 
to ensure that content and promotional materials are not misleading, ethical and do not encourage excessive 
gambling. This collaborative approach ensures a cohesive and comprehensive responsib le gambling 
strategy. 
 
Training Program: Through a “Train the Trainer” approach, we invest heavily in our Legal & Compliance 
team by providing them free access to conferences, seminars and courses that help them develop their 
knowledge and keep them updated with the latest industry regulations wh ich they can then use to provide 
sound advice to management and address queries from different teams.  
 
The current legal and compliance training carried out across the Group is on an ad-hoc basis, depending on 
the need and requirements of different departments. In 2025, we plan on launching an employee compliance 
training program, with the intention of rais ing Group-wide awareness of the legal and regulatory compliance 
function. The program will consist of induction training at employee onboarding and annual refresher training 
for all employees with a simple test to assess understanding. Specialised, departm ental ad-hoc training will 
continue being provided when required with the aim to address queries on a specific focus area.  
 
In addition to the Legal & Compliance team, all other employees have a training budget allocated to them for 
use on their own training and development as they see fit.  
 
Quality Mark Responsible Affiliates (QMRA): To further demonstrate its commitment to regulatory 
compliance, the Group has also obtained several QMRA marks on its websites targeting regulated markets.  
 
Sitebee: We have also developed a proprietary software compliance tool (Sitebee) which we provide as a 
service to our customers to monitor their own marketing regulatory compliance, including responsible 
gambling advertising.  
 
 
B. CONSUMER PROTECTION & RESPONSIBLE GAMBLING 
 
 
Truthful and Transparent Advertising: As an advertising company, we have a fundamental obligation and 
responsibility to ensure that our advertising is truthful, transparent and not misleading to our visitors. We 
strive to partner with responsible operators and make sure our content is not mis leading or deceptive which 
could misinform potential players about the odds, deposit and wagering requirements, and potential rewards 
associated with a specific game or promotion. The most significant terms and conditions are always disclosed 
on our adverts and banners, as well as, a link leading to all terms and conditions associated with a specific 
game or promotion. 
In this regard, reference is made to various advertising standards and codes of conduct, including those 
issued by the Advertising Standards Authority (UK), the International Chamber of Commerce and the 
European Gaming and Betting Association, together wit h jurisdictional -specific marketing regulations 
published by gambling authorities in the various regulated markets we operate in. Adherence to these 
standards and regulations help protect consumers and maintain the integrity of the industry.

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Awareness of responsible gambling is raised through: 
 
Dedicated Responsible Gambling Page: Each of our websites includes links to a dedicated Responsible 
Gambling page . This page provides comprehensive information and resources on responsible gambling, 
including tips for maintaining control, recognizing signs of problem gambling, and links to gambling addiction 
support organizations. We believe in providing our users with the tools and information they need to gamble 
responsibly. 
 
Promotions and Bonuses: When advertising promotions and bonuses, we take responsible gambling 
measures into account to ensure our marketing practices do not encourage irresponsible behaviour. Our 
advertisements are crafted to provide clear and transparent information, emphasizing  the fun and 
entertainment aspect of gambling rather than promoting it as a financial solution. We avoid any language or 
imagery that might instill a sense of urgency and those that may suggest gambling is a way to achieve 
financial success. 
 
Dissemination of Responsible Gambling Messages: To continuously educate and remind our players 
about the importance of responsible gambling, we disseminate responsible gambling messages across all 
our advertising channels. Whether it is through our websites, social media pages, or emails, we ensure that  
our communications include reminders that gambling should be seen as a form of entertainment, not a 
financial means. Our messages are designed to encourage players to gamble responsibly and seek help if 
needed. 
 
Regard to Minors: We are particularly mindful of our responsibility to prevent gambling content from 
appealing to minors and individuals under 25 years old. Our marketing materials are carefully reviewed to 
ensure they do not feature themes, images, or language that might attract younger audiences. This is part of 
our commitment to creating a safe environment where only those who are legally allowed to gamble can 
access our content. 
 
Additionally, to prevent access to minors, our social media channels are equipped with age-gating tools and 
our websites feature an age declaration, where required . These tools are part of our broader strategy to 
ensure that our gambling content is only accessible to those who are of legal gambling age and, in this regard, 
we continuously monitor and update our social media practices to align with the best standards in the industry 
and keep abreast of industry trends and innovative solutions. 
 
C. GDPR COMPLIANCE AND DATA PRIVACY 
Observing GDPR and data privacy is a fundamental part of our operations. We always request explicit 
consent from all users before sending any advertising material and ensure that their personal data is never 
shared with third parties without permission. Ou r commitment to GDPR compliance reflects our respect for 
our users' privacy and our dedication to maintaining their trust. 
 
D. INTELLECTUAL PROPERTY 
As content creators, we deeply respect the intellectual property rights of others. We always credit sources 
and seek permission when necessary, before publishing editorial content. Gentoo’s websites will never host 
illegal content or engage in unethical pr actices, such as file-sharing, directing users to pirated content sites, 
or any other forms of intellectual property infringement. Our Legal team has dedicated resources to provide 
guidance and advice on intellectual property management practices and, in addition to responding to ad-hoc 
related queries, it has organised a company -wide workshop by collaborating with an external consultant to 
provide training on relevant IP matters. It is the Group’s intention to increase the level of training and 
development of its employees by organising similar workshops in the future.

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E. VETTING OF STAFF 
Prior to employment, all prospective employees are requested to provide a copy of their identification 
document and to attest that they have read and understood the Group’s policies in relation to work ethics, 
code of conduct, information security, IT equipment, data handling, DEI, global environment, whistleblowing, 
and AML & CFT. Additionally, all prospective top management employees are requested to provide two 
referees at application stage, who are then contacted to provide their views on the applicant’s past behaviour, 
integrity and performance, with the aim of identifying any characteristics and/or behaviour that may be 
detrimental to the Group should the prospect be offered the role. 
Gentoo considers the above risk management processes to be crucial in order to be able to comply with its 
own strategies, internal controls and procedures diligently. Working with reliable personnel also helps ensure 
timely notifications, including notific ations relating to suspicious activities (such as bribery and corruption), 
and avoid active or passive complicity in suspicious transactions or business relationships by employees.  
Upon recruitment, after the initial screening, all employees are obliged to adhere to their job expectations, 
which are measured through bi -annual performance reviews. Disciplinary policies are in place to sanction 
non-compliance to internal company polici es and the Group will go as far as terminating an employment 
relationship should it have serious grounds to doubt an employee’s reliability following internal investigations. 
Going forward, the Group plans on setting up a periodic screening process on all employees as well as Board 
members, the frequency varying according to seniority levels and nature of roles. This will be carried out to 
ascertain good conduct thus safeguarding the Group, the brand and its livelihood. 
 
G. THIRD-PARTY RISK MANAGEMENT 
 
The Company has identified the below measures to formulate its Customer Due Diligence (CDD) policy and 
procedure: 
 
● To identify and verify a prospective customer - and, if onboarded, thereafter throughout the duration 
of the business relationship - on the basis of documents, data or information obtained from a reliable 
and independent source; 
● To exclude establishing a business relationship with a sanctioned person and/or company, in line 
with the international sanctions regimes outlined in the Sanctions Policy; 
● To determine whether the customer is a politically exposed person (PEP), a family member or a 
person known to be a close associate of a PEP; 
● To verify that a customer operating in a regulated market is duly licensed;  
● To ascertain that payments in return for services are received from a bank account held in the 
customer’s entity name in a low - or medium-risk jurisdiction and not in a high -risk or non-reputable 
jurisdiction, as listed in Gentoo’s Jurisdictional Risk Policy (i.e. jurisdictions identified as such by the 
FATF, EU Commission and others that do not fall within the Group’s risk appetite);  
● To continuously monitor the business relationship on a daily basis in terms of data, information and 
documentation obtained (to ensure that these remain up -to-date and relevant to any specific risks), 
PEP and sanctions status, and customer behaviour & tran sactions carried out during the business 
relationship to ensure that such are consistent with the customer risk profile. Ongoing monitoring 
also requires a customer risk re-assessment on a periodic basis and/or based on trigger events that 
change the previously known customer risk profile, whichever comes first. 
 
Gentoo is in the process of applying the above safeguards by following a clear and strict customer onboarding 
process and takes into account the risk factors outlined in the EU’s AML directives (customer, interface,

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geographical, transaction, product) in order to apply a level of CDD (simplified or enhanced) proportionate to 
the risk emanating from a specific customer (i.e. gambling operator), whilst also taking into account the size 
and nature and the Group’s operations. 
 
Once this process is rolled out on its customers, Gentoo also intends to roll -out a similar vetting process on 
its suppliers. 
 
5.2 EMPLOYEE MATTERS 
Workforce Diversity, Equity and Inclusion 
At Gentoo Media, our success is driven by the expertise and dedication of our people. Whether in content 
creation, marketing, analytics or tech, every team member plays a vital role in pushing our business forward 
and keeping us at the forefront of the iGa ming affiliate space. By the end of 2024, Gentoo Media had 387 
full-time employees with 47 nationalities and an impressive gender representation of 49 % female to 51 % 
male (despite operating in a male-dominant industry).  
 
Going forward, we acknowledge and respect that individuals may identify with different genders. In this 
respect, we are committed to fostering an inclusive environment where all employees throughout their entire 
employment with us (starting as early as the  pre-boarding process) have the opportunity to actively choose 
“non-binary or other” if they do not identify as male or female. 
 
We aim to raise more awareness around this matter and, therefore, as part of our 2025 goals, we intend to 
explore opportunities around displaying employees' preferred pronouns alongside their names in our internal 
communication channel. 
 
In 2025, one of our biggest projects will be to take active steps to align with the EU Pay Transparency 
Directive, which will come into effect in June 2026. As part of this, we will evaluate all positions across all our 
entities, define clear roles and res ponsibilities against clear and objective criteria, outline required seniority 
levels and corresponding pay structures, and align accordingly. This supports fair and transparent pay 
structures in line with the EU Pay Transparency Directive, helping to eli minate unjustified pay gaps and 
ensure equal pay for equal work. We will also improve how we track and analyze pay equity, create 
transparency with employees and managers about pay structures and make sure our policies meet legal 
requirements ahead of the deadline in June 2026. This will build a more structured and fair compensation 
system that recognizes and rewards every employee equitably. It will help us identify and close any potential 
pay gaps, reinforcing our commitment to fairness and transparency in salaries. 
 
People Processes 
2024 has been a year of major shifts and changes. The acquisition of KaFe Rocks and the operational 
separation from GIG Platform have shaped a period of transition. As we moved towards the final strategic 
split on 1st October 2024, one key focus has been e stablishing the People team to support a strong and 
independent foundation for our workforce in Gentoo Media. We recognize that the rapid growth of the Group 
last year, as well as the spin-off, have had an impact on some teams, and we are committed to ensu ring we 
have the right structure and support in place to move forward with a solid and strong setup.  
 
With Gentoo Media now operating as a fully standalone business, the Group’s People Strategy is evolving to 
support the Group’s next chapter. Starting from 2024, we worked towards optimising our people processes

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by integrating our Human Resources Information System (HRIS) as much as possible, which has helped 
strengthen our support to our people. 
 
Employee Training and Development 
Our online training & development platform provides several courses available to all employees, covering 
professional development, skill -building courses and industry -specific courses. Employees are also 
encouraged to use their annual conference budget to attend conferences and any other courses not available 
on the Group’s platform. 
 
The Group also enforces mandatory courses to employees in leadership positions, to equip them with the 
necessary skills, knowledge and feedback to effectively lead, support employee development, and drive team 
performance. In 2024, 36 leaders completed lea dership training to build the skills they need to support and 
guide their teams. We will continue offering leadership development in 2025 to ensure that our leaders have 
the right tools to lead with confidence and contribute to meaningful impact.  
 
Moving forward, in 2025, our People team will focus on improving our approach to training and development, 
through a more structured, data -driven, long-term solution. We plan on implementing a training system that 
will allow us to track our employees’ training, assign learning tied to career growth and pathways, and ensure 
that essential regulatory compliance training is part of our onboarding program. This will help us equip our 
people with the right skills at the right time, supporting both their personal  development and the Group’s 
continuing success. 
 
Employee Wellbeing 
As a Group, we take a holistic approach to employee wellbeing, understanding that everyone’s needs are 
different. Every employee is provided with a wellbeing budget, commensurate with inflation rates and which 
is renewed on an annual basis, with the aim of providing employees the opportunity and flexibility to invest in 
what personally contributes to their health and happiness. We also provide health insurance to all employees 
covering physical and mental health, and dental coverage. While we feel that we a lready offer a strong 
benefits framework, we continue to explore ways to enhance it and ensure a consistent standard across all 
our locations. 
 
Working Conditions 
We uphold fair and ethical working conditions and have clear procedures in place to address any concerns 
related to workplace rights, privacy, and health and safety. Every employee has a dedicated People Partner 
to whom they can always raise concerns or is sues in confidence. Besides this, as we transition from the 
strategic split from GIG to a stand -alone Group, we have initiated work on the implementation of a new 
whistleblower management system (further information is provided in Section 7). Our ongoing c ommitment 
to fostering an environment where employees feel supported, valued and empowered to do their best work 
is also shown through our  Diversity, Equity, and Inclusion, Grievance, and Harassment and Bullying policies 
to ensure a fair and supportive wo rkplace where everyone feels valued and heard and safe to raise their 
voice.

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5.3 COMMUNITY RELATIONS & CSR INITIATIVES 
AskGamblers Awards 
Each year, just before the AskGamblers Awards in mid -June, we hold the AskGamblers Charity Night. This 
night is dedicated to giving back to those in need, and it has become a sought -after yearly tradition. The 
highlight of this evening is an auction featuring the top placements on our website (www.askgamblers.com). 
All proceeds from the auction are donated to charity, supporting various causes around the world.  
During the month of September, we showcase and highlight the casinos that won auction spots on our site 
to ensure that the charitable donations made by the participating casinos are celebrated and recognized.  
Each year, we select a specific charity or organization to receive the funds raised from the auction. The 
amount raised and the cause it supports vary each year, but the goal remains the same: to make a positive 
impact. Here is a breakdown of some of the incredible initiatives we have supported: 
● 2024: A record €106,500 was donated to HISBAS (Hydrocephalus and Spina Bifida Association of 
Serbia) to aid in their ongoing efforts to improve the lives of children affected by hydrocephalus and 
spina bifida in Serbia. 
● 2023: A total of €75,000 was raised, with €40,000 going to the Danish Refugee Council for their 
initiatives to enhance child-friendly spaces in Tanzania’s Nduta and Nyarugusu refugee camps. 
The remaining €35,000 was donated to UNICEF to help strengthen core resources for children in 
Serbia. 
Through these charitable initiatives, AskGamblers continues to use its platform to bring about meaningful 
change, and we are grateful to the casinos and individuals who contribute to making these donations possible. 
Each year, we are proud to see the impact of our efforts and to know that the funds raised are helping those 
who need it most. 
AskGamblers’ Commitment to Responsible Gambling 
Since its inception, AskGamblers has been built with the mission of fostering a community where players can 
share their honest opinions and experiences about online casinos. From the very beginning, the core goal 
has been to create a space where players ca n learn from each other and access reliable, user -generated 
content to make informed decisions. 
Over time, this vision has evolved into our guiding slogan: "Get the Truth. Then Play." This phrase perfectly 
encapsulates everything we stand for. It highlights our commitment to transparency and honesty in all the 
information we provide. At AskGamblers, we believe that knowing the full story about a casino—whether it is 
about trustworthine ss, customer service, bonuses, or payment methods —is crucial before making any 
commitment to play. 
Our aim is simple yet powerful: we want to arm players with all the necessary information they need before 
they choose to play at a particular casino. By providing detailed reviews, ratings, and user feedback, we help 
players navigate the often -overwhelming world of online gambling, ensuring they can make choices based 
on facts, not just promotions or advertisements. 
In short, AskGamblers is not just a platform for information; it is a community -driven resource built on the 
foundation of honesty, transparency, and trust. "Get the Truth. Then Play." is not just a slogan —it is the 
standard we hold ourselves to every day.

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To further enhance the player experience and uphold our duty of care towards our players, we have rolled 
out the following three significant initiatives: 
1. Educational Blog : As part of our commitment to responsible gambling, we have developed a 
comprehensive blog. This blog aims to educate players on the rules and strategies for various casino 
games. 
2. AskGamblers’ Education Corner : A recently launched initiative, this project is dedicated to 
discussing responsible gambling, addressing problem gambling, and providing strategies to combat 
these issues. The Education Corner will host articles, news, and blogs focused on these topics, 
creating a space for vital information. This is an ongoing project, and we continue to add valuable 
content to promote awareness and healthier gambling habits. 
3. Little Mic News : Another new project aimed at keeping players informed is our Little Mic News 
initiative, available on LinkedIn and Instagram. This project focuses on summarizing the most 
significant gambling news from the previous week, with an emphasis on developments related to 
responsible gambling and legal changes across the global gambling landscape. By highlighting these 
updates, we ensure our community stays up to date with the latest trends and legal shifts.  
Through these initiatives, AskGamblers strives to be more than just a casino review site - we are a resource 
committed to educating and supporting our community in making responsible gambling choices. Whether 
through providing transparency on casinos, prom oting responsible gambling practices, or keeping players 
informed about the latest industry developments, we aim to create a well-rounded experience that empowers 
players to make informed, responsible decisions. 
Successful Earth Day 2024 
‘Protecting our Planet’ event was held on 22nd April 2024. Gentoo hosted guest speaker Alexis Normand, 
CEO and co-founder of Greenly, to share his expert knowledge on defining ‘emissions’ and their causes, how 
we can all make a positive difference to our p lanet and to raise overall awareness of climate change across 
the organisation. 
 
World Ocean’s Day 2024 Beach Clean-up 
In June 2024, three members of our team in Malta joined forces with local beach cleanups to help clear 
rubbish from several beaches across the island and the sea in support of the United Nation’s World Oceans 
Day. 
 
Greenly Environmental Survey 
We asked our teams to participate in an Environmental Survey to help the Group understand the amount and 
sources of emissions generated by every individual in association with their employment with Gentoo, through 
asking questions regarding the source of transport and distance of commuting  to and from the office and the 
sources of energy used when working from home, amongst others. The results were incorporated in the 
workings used to calculate GHG emissions, as outlined in Section 4.2.  
 
Offsetting emissions and reforesting the world with TreeNation 
All new joiners get a welcome gift from the Company to reward participation in sustainability events, this being 
the planting of trees in TreeNation projects. In 2024, Gentoo Media alone planted 1955 trees in the 
#GentooForest offsetting 199.12 tCO2.

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Host the vendor 
The Gentoo Media team from Serbia supported the street magazine LICEULICE (meaning "Face of the 
Street") through the ‘Host the Vendor’ initiative, providing shelter to street vendors during the heatwave in 
Belgrade. LICEULICE is distributed by members of marginalized groups, who earn 50% of the revenue from 
each copy sold. However, it is more than just a magazine; it’s a lifeline for many, promoting the inclusion of 
socially disadvantaged and vulnerable people through various community programs. The goal of the initiative 
was to provide shelter to street vendors from the heatwave and spend some time to get to know them and 
buy magazines. Our office gathered 30 employees that day and spent a wonderful 2 hours with lovely sellers. 
On top of this, they managed to reach record sales in one day of 92 copies of the magazine, which we are 
mostly proud of!  
 
Company volunteer days given to our employees  
As part of our commitment to giving back, every employee in the Group has the opportunity to dedicate one 
workday to making a meaningful impact, whether that is supporting a cause close to their heart, contributing 
to society, or helping the local communit y. We want to increase awareness of this initiative so more of our 
people take advantage of their volunteer day. In 2024, 52 employees used their day for a variety of causes, 
including volunteering at animal shelters, donating blood, and participating in t he beach cleanup in Malta. 
Our goal for 2025 is to double that number by actively promoting the program throughout the year and making 
it easier for employees to get involved. 
 
KEY PERFORMANCE INDICATORS (for Social & Employee Matters) 
 
KPI Description Target Actual (for 2024) Comments 
Adherence to 
response 
timeframe 
allowed by 
Authorities 
Meeting deadlines 100% 100% N/A 
License 
Compliance 
Rate 
Percentage of 
gaming licenses in 
good standing and 
renewed on time 
100% 100% N/A 
Regulatory 
Reporting 
Timeliness 
Percentage of 
reports submitted to 
regulators on time 
100% 100% N/A 
Diversity in 
Management 
Percentage of men 
and women in 
management 
positions   
50/50 37.8% women to 
62.2% men  
+2.9 percentage points 
in women 
representation from 
2023. 
 
Continue efforts to 
improve gender balance 
in leadership. 
 
 
RISKS AND RISK MANAGEMENT (for Social & Employee Matters)

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Principal Risk Description Potential Impact Key Controls & 
Mitigations 
Missed regulatory updates  
& mis-identification of 
applicable regulatory 
updates 
 
Due to the business’ 
operations in several 
jurisdictions with different 
legislation and regulations, 
the business risks 
responding too late to 
regulatory changes and 
implements changes 
beyond the effective date. 
Non-compliance to 
regulations risking getting 
flagged by Authorities 
potentially leading to 
warnings, fines and/or 
sanctions. 
As the Compliance 
function develops, we 
plan to move from ad-
hoc monitoring to 
planned, periodic 
monitoring of our assets. 
Gap analysis will be 
shared with relevant 
teams along with 
suggested 
improvements. It is also 
the plan to implement a  
standardised and 
efficient change 
management process. 
Lack of company-wide 
awareness of Gentoo's 
regulatory requirements 
Lack of company-wide 
awareness of Gentoo's 
regulatory requirements. 
Non-compliance to 
regulations potentially 
leading to warnings, 
financial penalties and 
sanctions imposed by 
regulators. 
Enrolment of a 
company-wide 
compliance training 
program. 
Third-party risk Risk emanating from 
entertaining relations with 
our partners. 
The Company may be 
subject to different risks 
emanating from its 
partners, with the business 
and brand at stake. 
Risk appetite level to be 
set by the Board and 
followed by 
management. 
 
Due diligence procedure 
is to be rolled out in Q1 
2025. 
Diversity, Equity & 
Inclusion (DEI) 
development opportunities 
A lack of diversity and 
inclusive culture can lead to 
discrimination, reputational 
damage, and 
disengagement with our 
people. 
A lack of diversity and 
inclusion can weaken 
collaboration, hinder 
innovation, and damage 
the Group’s reputation, 
potentially leading to lost 
investor confidence and 
legal exposure. 
Diversity targets in 
promotions and policies 
for internal promotions. 
 
Regular unconscious 
bias training and DEI 
programs for 
management. 
Equal treatment and 
opportunities for all 
Gender equality and equal 
pay for work of equal value. 
Discriminatory pay 
practices can have a 
severe reputational 
damage to the operations 
of the Group, especially if 
they are seen to favour one 
gender over another. 
We are aware there 
might be a risk and how 
this can impact our 
people; we have begun 
the assessment in 
accordance with the EU 
Pay Transparency 
Directive, which comes 
into effect in June 2026,

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6. HUMAN RIGHTS MATTERS 
As a starting point, every employee at Gentoo Media has joined voluntarily and no one has been forced into 
employment. During our hiring process, we ensure that all candidates meet the legal working age 
requirements in every location where we operate. Our hiring process is structured and fair, and in this respect, 
all suitable candidates are treated equally and given the same opportunity for an initial interview.  
 
At Gentoo Media, we are committed to upholding and protecting the rights of our employees and partners 
through clear policies and responsible practices. Our People team conducts an annual review of all policies 
to ensure they remain relevant, effective, an d aligned with best practices, such as our Diversity, Equity and 
Inclusion Policy, Harassment & Bullying Policy and Grievance policy.  
 
We prioritize Diversity, Equity, and Inclusion, Health and Well-being, the Right to Disconnect, and protections 
against Harassment and Bullying, Grievance procedures among others, to ensure a safe, inclusive, and 
ethical workplace. Across all our offices, we have safety measures in place (such as fire extinguishers, water 
sprinklers, smoke alarms) and additionally, in 2025, we aim to have designated officers also certified in first 
aid who would provide first-hand assistance if and when needed. 
 
The above is our commitment to continuously improve our approach to human rights, ensuring that everyone 
who works with us is safe and treated with dignity and respect. 
 
7. ANTI-BRIBERY AND CORRUPTION 
Our business and reputation are built upon fair, lawful, responsible and ethical conduct and, therefore, we 
are committed to continue working towards achieving the highest standards of ethical conduct and integrity 
to identify and address 
any potential pay gaps. 
Workplace culture and 
employee engagement 
Poor workplace culture and 
lack of communication 
leading to high turnover 
and disengagement. 
 
Reduced productivity and 
employee retention. 
Regular engagement 
surveys. 
 
Transparent 
communication having 
Group-wide “all hands” 
and implementation of 
an intranet.  
 
Ensuring employees feel 
connected to company 
values by involving them 
in defining who we are 
and what we stand for 
making our people feel a 
sense of belonging.

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across our operations on a day-to-day basis and in all dealings, both internally and externally, with colleagues, 
customers, suppliers and regulators.  
 
Maintaining our reputation for business integrity and excellence requires careful observance of all applicable 
laws and regulations which also extends to having regard for the highest standards of personal integrity.  
 
Our Code of Conduct sets out the standards that form the honest, ethical foundations for the way that Gentoo 
does and operates its business covering issues such as market operations, countering bribery, corruption, 
harassment and fraud. Compliance with our Code of Conduct is non-negotiable, and alongside this 
document, all stakeholders are expected to exercise good judgment, based on high ethical principles, for 
guidance as to what is acceptable conduct and what is not. 
 
7.1 BUSINESS INTEGRITY 
The Group operates in several jurisdictions world -wide, with differing levels of regulation, enforcement and 
control, which expose the business to different types and varying levels of risk, specifically emanating from:  
● Financial systems; 
● Gaming regulation; and 
● Suppliers and partners (online casino/sports betting operator) requirements and compliance thereof. 
Developed countries having established financial systems with robust enforcement and supervisory 
frameworks may indicate that any of our transacting parties (suppliers and customers) that operate in such 
markets, have been vetted by licensed financial inst itutions, which in turn are subject to stringent regulation 
and enforcement, thus providing a higher level of comfort that our contracting parties are of good standing 
and, specifically, that funds received from our customers are derived from legitimate sources, as opposed to 
jurisdictions with lax financial crime controls. 
Another factor that highly impacts the Group’s business integrity is the appetite and level of gaming regulation 
across different jurisdictions. Highly regulated markets with high levels of monitoring and enforcement 
translate to reputable customers that comply with the respective laws and regulations, which in turn, expose 
the Group to a lower risk of non -compliance which may ultimately lead to financial penalties and sanctions. 
Unregulated markets and/or those with less stringent gaming regulations may at tract operators with 
insufficient resources to be able to enter regulated markets and/or operators looking to disguise illicit business 
operations as gambling operations, in turn subjecting the Group to a risk of financial loss (should a customer 
fails to honour payment terms) and/or reputational damage (should ML/FT risk materialise).  
In an attempt to continuously maintain a high standard of business integrity, Gentoo refers to a number of 
standard-setting bodies and EU documents, including the Financial Action Task Force “Grey” and “Black” 
lists, EU Commission List of High-Risk Third Countries and the EU’s AML/CFT Directives and applies a risk-
based approach to managing and treating risk emanating from financial crime including corruption, bribery 
and the resultant money-laundering and/or terrorist financing. The Group follows the risk appetite proposed 
by the Board’s Legal and Compliance function when evaluating new target markets and the impact of changes 
(such as geopolitical, regulatory) in existing markets. The Group may completely disregard a market should 
the level of risk be unacceptable to the Group or otherwise apply a level of due diligence proportionate to the 
level of risk posed by a market and corresponding customer operating in that specific market.

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Reference is to be made to Section 5.1 ‘Third -Party Risk Management’ for further information on the scope 
of CDD. 
 
7.2 WHISTLEBLOWER PROTECTION 
The prevention, detection and reporting of bribery and corruption is the responsibility and duty of all Group 
stakeholders, including employees, Board members and shareholders. It is mandatory for all new employees 
to attest to have read and understood the contents of our Code of Conduct prior to their employment starting 
date and all employees are expected to report any wrongdoings throughout the course of their employment. 
In this respect, protection of all whistleblowers against retaliation is our top pr iority in order to ensure a safe 
environment where anyone is encouraged to report, while ultimately safeguarding the business from existing 
and potential wrongdoings and their adverse impacts, which help towards business longevity.  
 
Following the spin -off, the Group is in the process of setting up a whistleblowing management system - a 
reporting channel which facilitates anonymous reporting and, thereafter, anonymous dialogue between the 
whistleblower and our Whistleblowing Officer to share progress on the investigation and resolution. While the 
system is being set up across all Group entities, the Group encourages all individuals to come forward and 
raise concerns of suspected or actual cases of bribery and corruption to the Whistlebl owing Officer, in 
confidence.  
 
While no incidents of bribery and corruption were reported in 2024, we envisage that the whistleblowing 
management system to be rolled out in 2025, will raise further awareness of the importance of reporting such 
wrong-doings and encourage employees to disclose any suspected or knowledge of such behaviour. 
 
RISKS AND RISK MANAGEMENT (Anti-Bribery and Corruption) 
 
Bribery and corruption pose significant risks to Gentoo, impacting legal, financial, operational, and 
reputational aspects. Legal risks include potential fines, criminal prosecution, and civil liability, while 
reputational risks involve a loss of public tr ust and negative media coverage. Financial risks can arise from 
penalties, higher operational costs, and the loss of business opportunities. Operationally, corruption can lead 
to inefficiency, favoritism, and internal conflicts.  
 
To manage these risks, Gentoo expects all its employees and Board of Directors to abide by its Code of 
Conduct, which explicitly highlights its zero-tolerance stance on bribery and corruption. In this regard, all new 
hires need to attest to having read Gentoo’s Code of Conduct prior to their starting date. Additionally, Gentoo 
expects top management to lead by example and demonstrate a commitment to anti -corruption efforts, 
ensuring transparency in decision-making and independent oversight.  
 
When it comes to bribery and corruption risks emanating from its partners, as specified earlier, Gentoo is 
also working on a robust vetting process as highlighted in Section 5.1. Internal controls, such as internal 
audits and the implementation of the four -eye principle in day -to-day operations help detect unethical 
practices prior to the risk materialising.

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8. OTHER MATTERS 
As an affiliate marketing company, the Group is largely dependent on certain business relationships along its 
value chain. 
 
From a supply chain perspective, the Group's product offerings rely heavily on search engine optimization 
(SEO), making third-party search engines—particularly Google's—critical to its operations. While changes to 
search engine algorithms can positively im pact the business with higher website rankings, these may also 
significantly disrupt website rankings in search results, which in turn reduces traffic to the Group’s websites.  
 
Search engines use complex algorithms to rank their search results, taking several different factors into 
account. Google adjusts these factors and its search engine multiple times a year. Such ongoing adjustments 
are minor changes that, although impacting the presentation of search results, ranking factors and recognition 
of search intent (amongst others), do not have any noticeable impact on the overall search engine result 
page. However, Google also releases updates to its core algorithm (“Google Core Updates”) several times a 
year, which are significant changes made to its core algorithm (not to ranking factors) and often have a 
considerable impact on search results, and therefore, the visibility and ranking of our websites.  
 
While other updates often have a clearly defined target (e.g. the introduction of a new ranking factor or new 
technology), Google Core Updates are focused on improving the overall quality of results users get from the 
Google search engine. These are part o f Google’s efforts to present relevant and authoritative content to 
searchers. 
 
Google always officially announces its core updates prior to the release of the updates, however, the negative 
impact of any update cannot be mitigated beforehand and is only realised once the update is fully released 
(which may take a couple of days or extend to several weeks).  
 
In the course of 2024, Google released four core updates, with the most significant one being the “March 
2024 Core Update & Spam Update”. With this update, Google aimed to remove any content from search 
results that was created to manipulate rankings and aimed to deliver unique, high-quality results that may be 
more useful to users. This update was a much more complex Core Update than usual, as several ranking 
systems were being updated. Additionally, Google also rolled out a Spam Update with new and improv ed 
spam policies to keep low-quality content out of search results. 
 
Our flagship site, Casinotopsonline.com was particularly hit in Q1 2024 following the roll-out of Google’s core 
update in March although it has since then been slowly recovering losses and continues on a positive 
trajectory. Nonetheless, the business has y et to realise a turn -around for Casinotopsonline.com, which was 
a strong revenue and player intake driver in 2023 and earlier years. It remains a focal point in the organisation 
to realise said turn -around and a dedicated team has worked throughout 2024 to  make this a reality. This 
work will also continue in 2025 until success is achieved. 
 
With the diversification strategy in place in Q4 2024, we have also focused on other, smaller assets and 
although the fourth quarter was impacted by two Google core updates, no material impact was reported on 
Gentoo’s portfolio of websites. This is because  one of the larger sites in our portfolio, targeting a specific 
market, saw a notable positive spike in rankings while two smaller websites in the portfolio were hit negatively. 
Combined the impact was neutral.

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9. CONSOLIDATED DISCLOSURES PURSUANT TO ARTICLE 8 OF THE TAXONOMY 
REGULATION 
In order to achieve the targets established by the European Union (‘EU’) of reaching net zero greenhouse 
gas (‘GHG’) emissions by 2050, with an interim target of reducing GHG emissions by 55%, compared to 1990 
levels, by 2030, the EU has developed a classi fication system, by virtue of the EU Taxonomy Regulation 1, 
(‘the EU Taxonomy’) which establishes the criteria for determining whether an economic activity qualifies as 
environmentally sustainable. 
  
The EU Taxonomy establishes criteria in terms of six environmental objectives, against which entities will be 
able to assess whether economic activities qualify as environmentally sustainable.  
  
In order to qualify as such, an economic activity must be assessed to substantially contribute to at least one 
of these environmental objectives, whilst doing no significant harm (‘DNSH’) to the remaining objectives. This 
is achieved by reference to techni cal screening criteria established in delegated acts to the EU Taxonomy. 
The economic activity is also required to meet minimum safeguards established in the EU Taxonomy.  
  
The six environmental objectives considered by the EU Taxonomy are the following, where climate -related 
environmental objectives (i-ii below) are established in the Climate Delegated Act2 (‘CDA’), whilst non-climate 
environmental objectives (iii -vi below) are established in the Environmental Delegated Act 3 (‘EDA’). This 
financial year is the third reporting period where the Group is reporting in the context of the EDA, which was 
formally adopted in 2023. 
  
                 i.             Climate change mitigation (‘CCM’); 
                 ii.            Climate change adaptation (‘CCA’); 
                 iii.           Sustainable use and protection of water and marine resources (‘WTR’);  
                 iv.           Transition to a circular economy (‘CE’); 
                 v.            Pollution prevention and control (‘PPC’); and 
                 vi.           Protection and restoration of biodiversity and ecosystems (‘BIO’).  
  
A Delegated Act to the EU Taxonomy was issued in 2021, supplementing Article 8 of the EU Taxonomy (‘the 
Disclosures Delegated Act 4’), which establishes the disclosure requirements of entities within the scope of 
the EU Taxonomy. 
  
This currently comprises entities subject to an obligation to publish non -financial information pursuant to the 
Non-Financial Reporting Directive5, (‘NFRD’), emanating from Article 19a or 29a of the Accounting Directive6. 
The Disclosures Delegated Act was further updated in 2023 by the Complementary Climate Delegated Act 
to include certain energy activities relating to fossil gas and nuclear energy.  
 
1 EU Regulation 2020/852 
2 Commission Delegated Regulation 2021/2139 
3 Commission Delegated Regulation 2023/2486 
4 Commission Delegated Regulation 2021/2178 
5 EU Directive 2014/95/EU. NFRD entities are public interest entities exceeding an average of 500 employees during the reporting 
period. The introduction of EU Directive 2022/2464/EU (the Corporate Sustainability Reporting Directive, ‘CSRD’, which will replace 
the NFRD) will significantly extend the scope of EU Taxonomy reporting. 
6 EU Directive 2013/34/EU

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In the following section, the Group, as a non-financial parent undertaking, presents the share of its turnover, 
capital expenditure (CapEx) and operating expenditure (OpEx) for the reporting period ended 31 December 
2024, which are associated with the following, in accordance with the Disclosures Delegated Act; 
 
● Taxonomy-eligible and Taxonomy -aligned economic activities in respect of climate -related 
environmental objectives; and 
● Taxonomy-eligible economic activities in respect of non-climate environmental objectives. 
  
This does not include subsidiary level Taxonomy KPIs in the contextual information, which are only required 
where the parent undertaking identifies significant differences between the risks or impacts of the Group and 
those of the subsidiaries, in line wit h FAQ 12 in the Commission Notice on the interpretation and 
implementation of certain legal provisions of the Disclosures Delegated Act under Article 8 of EU Taxonomy 
Regulation on the reporting of Taxonomy -eligible and Taxonomy -aligned economic activities  and assets 
(second Commission Notice). The Group is currently in the process of identifying such risks and impacts as 
part of its preparation for subsequent reporting, depending on the outcome of the EU’s Omnibus Package 
proposal for CSRD simplification, CSRDDD, the EU Taxonomy and the CBAM. 
  
The Group does not identify any significant differences between the risks or impacts of the Group and those 
of its subsidiaries. In addition, none of the Group’s subsidiaries are currently obliged to publish non -financial 
information pursuant to the NFRD. Neither do they avail of the subsidiary exemption emanating from 
paragraph (9) of Article 19a, or paragraph (8) of Article 29a, of the Accounting Directive, respectively.  
 
9.1 OUR ACTIVITIES 
9.1.1 Overview 
The proportion of taxonomy -eligible and taxonomy-aligned economic activities in total turnover, CapEx and 
OpEx are presented in the table below: 
  
  Total (€000) 
Proportion of 
taxonomy-eligible 
(non-aligned) 
economic 
activities 
Proportion of 
taxonomy-aligned 
economic activities 
Proportion of 
taxonomy non -
eligible economic 
activities 
FY 2024:         
Turnover 122,778 0% 0% 100% 
CapEx 18,408 11.3% 0% 88.7% 
OpEx 26,671 0% 0% 100% 
     
FY 20237:     
Turnover 88,616 0% 0% 100% 
CapEx 24,728 2.1% 0% 97.9% 
OpEx 103 0% 0% 100% 
 
7 The figures relating to the discontinued operations have been excluded for comparability.

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● A ‘Taxonomy-eligible economic activity’  means an economic activity that is described in the 
delegated acts supplementing the Taxonomy Regulation (that is, either the Climate Delegated Act or 
the Environmental Delegated Act), irrespective of whether that economic activity meets any or all of 
the technical screening criteria laid down in those delegated acts. 
The Climate Delegated Act is structured such that Annex I contains a list of activities and the 
respective technical screening criteria in relation to the Climate Change Mitigation objective, whereas 
Annex II relates to the Climate Change Adaptation objective, with potentially different activities being 
considered in the different annexes. The Environmental Delegated Act similarly comprises respective 
lists of activities and technical screening criteria in relation to the non -climate environmental 
objectives therein. 
● A ‘Taxonomy-aligned economic activity’ refers to a taxonomy-eligible activity which complies with 
the technical screening criteria as defined in the Climate Delegated Act or Environmental Delegated 
Act and is carried out in compliance with minimum safeguards regarding human and consumer rights, 
anti-corruption and bribery, taxation, and fair competition. To meet the technical screening criteria, 
an economic activity must contribute substantially to one or more environmental objectives while 
‘doing no significant harm’ to any of the remaining environmental objectives therein.  
● A ‘Taxonomy-non-eligible economic activity’ refers to any economic activity that is not described 
in the delegated acts supplementing the EU Taxonomy. 
9.2 TAXONOMY-ELIGIBLE AND TAXONOMY-ALIGNED ECONOMIC ACTIVITIES 
9.2.1 Identification of Taxonomy-eligibility of Turnover-generating Activities 
The identification of any Taxonomy -eligible activities performed by the Group was carried out by extracting 
the total turnover, CapEx and OpEx required to be captured in the denominators of the respective KPIs and 
assessing the NACE code of the activities to which the amounts relate. The Group then assessed which of 
the identified NACE codes relate to activities included within the annexes to the Climate Delegated Act and 
Environmental Delegated Act. 
  
The Group’s economic activities (i.e. affiliate marketing services) are not captured as part of the Climate 
Delegated Act or Environmental Delegated Act and therefore the Group has fully classified its turnover -
generating activities as taxonomy non-eligible. 
  
Therefore, CapEx and OpEx associated with turnover -generating activities are also considered to be 
taxonomy non-eligible. 
 
9.2.2 Taxonomy eligibility of Investment Activities not directly related to turnover -generating 
activities 
Further to the activities from which the Group generates turnover, which generally incur both CapEx and 
OpEx, the Group also engages in investment activities not directly related to its turnover-generating activities. 
Such investment activities which are taxonomy-eligible have been highlighted below.

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Economic 
activity 
Description of 
the taxonomy -
eligible 
purchased 
output or 
individual 
measure 
CapEx 
(%)* 
OpEx 
(%)* 
Environmental 
objective(s) 
NACE Code 
7.7 Acquisition 
and ownership 
of buildings 
The acquisition of 
leasehold 
property to be 
utilised internally 
by the Group 
11.3% - CCM, CCA L68.2 
*% of the total CapEx and OpEx included in the denominator of the respective KPI 
9.2.3 Taxonomy Alignment 
For the identified eligible activities (i.e. the acquisition of leasehold property to be utilised internally by the 
Group), the Group then began the process to begin assessing them against the technical screening criteria.  
  
Determining whether an activity meets the requirements to be classified as taxonomy -aligned requires 
considerable detailed information about the activity in order to properly assess it against the established 
technical screening criteria. 
  
The Group is currently in the process of gathering the necessary information in order to conclude that 
activities may be considered as taxonomy -aligned and verifying its accuracy. As a result of the ongoing 
process, the Group has not been able to substantiate the alignment of any of its activities in the current year. 
 
Therefore, as a result of no activities being considered as taxonomy -aligned in the current year, disclosure 
requirements surrounding the assessment of taxonomy -alignment in accordance with section 1.2.2.1 of the 
Disclosures Delegated Act are not deemed to be applicable to the Group. 
 
9.3 OUR KPIs AND ACCOUNTING POLICIES 
 
The key performance indicators (‘KPIs’) comprise the turnover KPI, the CapEx KPI and the OpEx KPI. In 
presenting the Taxonomy KPIs, the Group uses the templates provided in Annex II to the Disclosures 
Delegated Act. The Group also presents comparative figures on Taxonomy-alignment. 
  
Moreover, since the Group does not carry out any of the activities related to fossil gas and nuclear energy (activities listed 
in Sections 4.26-4.31 in Annex II to the Delegated Act and which are also presented hereunder), the Group only publishes 
Template 1 of Annex XII of the Disclosures Delegated Act as regards activities in certain energy sectors.

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Row Nuclear energy related activities 
1 The undertaking carries out, 
funds or has exposures to 
research, development, 
demonstration and deployment 
of innovative electricity 
generation facilities that produce 
energy from nuclear processes 
with minimal waste from the fuel 
cycle. 
NO 
2 The undertaking carries out, 
funds or has exposures to 
construction and safe operation 
of new nuclear installations to 
produce electricity or process 
heat, including for the purposes 
of district heating or industrial 
processes such as hydrogen 
production, as well as their 
safety upgrades, using best 
available technologies. 
NO 
3 The undertaking carries out, 
funds or has exposures to safe 
operation of existing nuclear 
installations that produce 
electricity or process heat, 
including for the purposes of 
district heating or industrial 
processes such as hydrogen 
production from nuclear energy, 
as well as their safety upgrades. 
NO 
  Fossil gas related activities

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4 The undertaking carries out, 
funds or has exposures to 
construction or operation of 
electricity generation facilities 
that produce electricity using 
fossil gaseous fuels. 
NO 
5 The undertaking carries out, 
funds or has exposures to 
construction, refurbishment, and 
operation of combined heat/cool 
and power generation facilities 
using fossil 
 gaseous fuels. 
NO 
6 The undertaking carries out, 
funds or has exposures to 
construction, refurbishment and 
operation of heat generation 
facilities that produce heat/cool 
using fossil 
 gaseous fuels 
NO 
 
Template 1 Nuclear and fossil gas related activities for financial year 2024  
 
For all three Taxonomy tables (that is, Turnover, CapEx and OpEx tables), the following applies: 
  
● Section A.1 ‘Environmentally sustainable activities (Taxonomy-aligned)’ columns 5 to 10 are marked as ‘N’ given 
that the Group has not identified any Taxonomy-aligned balances; 
 
● The columns 11-17 are marked as ‘-’ since under “DNSH Criteria” and “Minimum Safeguards”, there is no current 
Taxonomy-alignment assessment to be reported.  
 
The specification of the KPIs is determined in accordance with Annex I to the Disclosures Delegated Act. The Group 
adopts the methodology to determine taxonomy-alignment in accordance with the legal requirements and describes 
its policies in this regard as outlined in the subsequent sections.

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9.3.1 Turnover KPI 
Definition: The proportion of taxonomy-aligned economic activities of the total turnover has been calculated as the part 
of net turnover derived from products and services associated with taxonomy -aligned economic activities (numerator) 
divided by the net turnover (denominator), in each case for the financial year from 1 January 2024 to 31 December 2024. 
 
Turnover KPI = (Net turnover from services associated with taxonomy aligned activities) ÷ Net turnover 
 
Given that the Group has not identified any taxonomy -aligned economic activities (since none of the business’ activities 
are taxonomy-eligible), taxonomy-alignment is not possible to be assessed. 
 
The denominator of the turnover KPI is based on the consolidated net turnover in accordance with paragraph 82(a) of 
IAS 1. For further details on our accounting policies regarding the Group’s consolidated net turnover, refer to disclosure 
note 1.22  ‘Revenue recognition’ in the Group’s consolidated financial statements included in this Annual Report. 
  
Reconciliation: The Group’s consolidated net turnover captured in the denominator of the KPI of €122,772,975 
reconciles with the amount disclosed in the ‘Revenue’ financial statement line item included in the ‘Income Statements’ 
in the consolidated financial statements included in this annual report. 
 
The full amount of €122,772,975 is disclosed as ‘Turnover of Taxonomy non-eligible activities’ in the Turnover KPI.

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9.3.2 CapEx KPI 
Definition: The CapEx KPI is defined as taxonomy-aligned CapEx (numerator) divided by the Group’s total CapEx 
(denominator): 
 
CapEx KPI = (CapEx from services associated with taxonomy aligned activities) ÷ Total CapEx 
 
 
Total CapEx consists of additions to tangible and intangible fixed assets during the financial year, before 
depreciation, amortisation, and any remeasurements, including those resulting from revaluations and impairments, 
as well as excluding changes in fair value. 
 
It includes acquisitions of tangible fixed assets (IAS 16), intangible fixed assets (IAS 38) and right -of-use assets 
(IFRS 16) and additions as a result of business combinations. Acquisitions of investment properties (IAS 40) would 
also be captured, however, the Group had no such additions in the current year.  
 
For further details on our accounting policies regarding the Group’s CapEx, refer to disclosure notes 1.7 ‘Property 
plant and equipment’, 1.6 ‘Intangible assets’, 1.8 ‘Leases’  and 1.2 ‘Business Combinations and Consolidations’ in 
the Group’s consolidated financial statements included within this Annual Report. 
  
The Disclosures Delegated Act established three categories under which to classify CapEx: 
 
(a) CapEx related to assets or processes that are associated with Taxonomy -aligned economic activities 
(“category a”). In this case, the Group considers that assets and processes are associated with Taxonomy-
aligned economic activities where they are essential  components necessary to execute an economic 
activity. 
 
The Group follows the generation of external revenues as a guiding principle to identify economic activities 
that are associated with CapEx under this category (a). Given that none of the Group’s turnover -
generating activities are classified as taxonomy -eligible (and hence, not taxonomy -aligned), no 
CapEx has been identified under this category. 
  
b) CapEx that is part of a plan to upgrade a Taxonomy -eligible economic activity to become Taxonomy -
aligned or to expand a Taxonomy -aligned economic activity (“category b”). Given that none of the 
Group’s turnover -generating activities are classified as taxonomy -eligible (and hence, not 
taxonomy-aligned), no such plan may be developed by the Group, and therefore, no CapEx is 
considered to be eligible under this category. 
c) CapEx related to the purchase of output from Taxonomy -aligned economic activities and individual 
measures enabling certain target activities to become low -carbon or to lead to GHG reductions 
(“category c”). 
The Group distinguishes between the purchase of output and individual measures as follows: 
● ‘Purchase of output’ relates to when the Group just acquires the product or service that is mentioned in 
the activity description.

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● ‘Individual measure’ refers to when the Group acquires a product through an activity that is regularly 
performed by the supplier, but where the Group controls the content and design of the product in detail.  
 
Eligible CapEx under this category has been disclosed in the table named ‘Individually taxonomy-eligible 
CapEx/OpEx and the corresponding economic activities’ in the ‘Taxonomy eligibility of investment 
activities not directly related to turnover -generating activities’ section above. The full amount of CapEx 
considered under this category relates purely to ‘purchase of output’. 
 
Purchases of output qualify as taxonomy -aligned CapEx in cases where it can be verified that the 
respective supplier performed a taxonomy-aligned activity to produce the output that the Group acquired. 
Since taxonomy-alignment also includes DNSH criteria a nd minimum safeguards, the Group is not able 
to assess the Taxonomy -alignment on its own. For the purchased output in 2023, we were not able to 
obtain any conclusive confirmation of taxonomy-alignment. 
  
Reconciliation: The Group’s total CapEx captured in the denominator of the KPI can be reconciled to the 
consolidated financial statements of the Group included in this Annual Report, by reference to the respective 
disclosures capturing the additions for property, plant and equipment, intangible assets, and right-of-use assets.

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CapEx Reconciliation 2024 
(€000) 
20238 
(€000) 
  
CapEx as per KPI denominator 
 
18,408 
 
24,728   
Additions as per the consolidated 
financial statements relating to: 
18,408 24,728   
Tangible Assets (Property, Plant 
and Equipment) 
656 3,439 Disclosure note 9 
Intangible assets 15,672 526 Disclosure note 8 
Right-of-use assets 2,080 20,762 Disclosure note 5  
Difference  - -   
  
From the amounts disclosed above, the full amount of €656,163 allocated to ‘Property, plant and equipment’ and 
€15,672,044 allocated to ‘Intangible assets’ are disclosed as ‘CapEx of Taxonomy non -eligible activities’ in the 
CapEx KPI. 
 
The full amount of €2,080,524 allocated to ‘Right-of-use assets’ is disclosed as taxonomy-eligible under activity 7.7 
‘Acquisition and ownership of buildings’ in the CapEx KPI.
 
8 The figures relating to the discontinued operations have been excluded for comparability.

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9.3.3 OpEx KPI 
Definition: The OpEx KPI is defined as taxonomy -aligned OpEx (numerator) divided by the Group’s 
total OpEx (denominator): 
 
OpEx KPI = (OpEx from services associated with taxonomy aligned activities) ÷ Total OpEx  
 
Total OpEx consists of direct non -capitalised costs that relate to all forms of maintenance and repair. 
This includes staff costs, costs for services and material costs for daily servicing as well as for regular 
and unplanned maintenance and repair measure s. Direct non-capitalised costs in relation to research 
and development, building renovation measures and short -term leases would also be captured, 
however, no such costs were incurred in the current year. It does not include expenses relating to the 
day-to-day operation of PPE, such as raw materials, cost of employees operating any equipment and 
electricity or fluids that are necessary to operate the PPE. Amortisation and depreciation are also not 
included in the OpEx KPI. 
 
The Group also excludes direct costs for training and other human resources adaptation needs from 
the denominator and the numerator. This is because Annex I to the Disclosures Delegated Act lists 
these costs only for the numerator, which does not allow a mathematically meaningful calculation of the 
OpEx KPI. 
 
The OpEx of the Group recognised during the financial year ended December 2024 is disclosed further 
in the Group’s consolidated financial statements included within this annual report in disclosure note 23  
‘Net Revenue and other operating expenses’. The f ull amount included in the denominator of the KPI 
of €26,000 is captured in the ‘other operating expenses’ segment of part b ‘Other operating expenses’ 
of disclosure note 23. 
 
Given that the Group has not identified any CapEx as being taxonomy -aligned, naturally, no OpEx is 
able to be considered as taxonomy-aligned.

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Statements of financial position 
 
   Group  Company 
   As at 31 December 
     
 Notes 2024 2023 2024 2023 
  € € € € 
      
ASSETS      
Non-current assets      
Intangible assets 8 96,202,260 93,017,113 - - 
Property, plant and equipment 9 1,037,497 953,206 - - 
Right-of-use assets 5 2,901,820 2,166,494 - - 
Investments in subsidiaries 10 - - 33,700,911 135,392,664 
Deferred income tax assets 22 19,745,676  5,987 - - 
Trade and other receivables 11 - 890,835 - - 
Total non-current assets  119,887,253  97,033,635 33,700,911 135,392,664 
      
Current assets      
Trade and other receivables 11 26,996,001  18,528,395 2,261,423  1,147,009 
Cash at bank and other 
intermediaries 
 
12 
 
11,283,801 
 
15,326,692 
 
223,832 
 
9,517,738 
  38,279,802  33,855,087 2,485,255  10,664,747 
      
Assets classified as held for 
distribution to owners 
 
7 
 
- 
 
130,900,010 
 
- 
 
- 
Total current assets  38,279,802  164,755,097 2,485,255  10,664,747 
      
Total assets  158,167,055  261,788,732 36,186,166  146,057,411

===== SIDA 57 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
56 
 
 
Statements of financial position - continued 
 
   Group  Company 
   As at 31 December 
      
 Notes 2024 2023 2024 2023 
  € € € € 
EQUITY AND LIABILITIES      
      
Equity      
Share capital 13 14,638,000 50,000 14,638,000 50,000 
Share premium 13 2,304,345 2,304,345 2,304,345 2,304,345 
Capital reserves 15 84,349,890 151,701,963 67,367,933 129,571,597 
Merger reserve 16 - 3,533,484 - 5,886,789 
Other reserves 17 (731,227) (14,181,562) - - 
Accumulated deficit  (126,528,693) (73,484,973) (211,860,450) (142,664,072) 
    (25,967,685) 69,923,257 (127,550,172) (4,851,341) 
Non-controlling interests 18 1,240,126  315,278 - - 
Total equity  (24,727,559) 70,238,535 (127,550,172) (4,851,341) 
      
Liabilities      
Non-current liabilities      
Borrowings 20 89,475,654  74,551,082 89,475,654 74,551,082 
Deferred income tax liabilities  22 2,447,660 3,990,421 - - 
Lease liabilities 5 2,113,774 3,405,673 - - 
Contingent consideration  - 408,118   
Deferred consideration 21 852,636 27,923,525 - - 
Trade and other payables 19 - 1,862,575 - - 
Total non-current liabilities  94,889,724 112,141,394 89,475,654  74,551,082 
      
Current liabilities      
Trade and other payables 19 11,896,898  12,340,070 55,359,347  61,566,085 
Contingent consideration  740,586  360,716 - - 
Deferred consideration 21 33,254,661  16,560,348 - - 
Current income tax liabilities  24,824,109  4,324,430 40,010 40,010 
Borrowings 20 16,200,349 3,164,698 18,861,327 14,751,575 
Lease liabilities 5 1,088,287 1,701,310 - - 
  88,004,890  38,451,572 74,260,684  76,357,670 
      
Liabilities directly associated with 
assets classified as held for 
distribution to owners 
 
7 
 
- 
 
40,957,231 
 
- 
 
- 
Total current liabilities  88,004,890  79,408,803 74,260,684  76,357,670 
      
Total liabilities  182,894,614  191,550,197 163,736,338  150,908,752 
      
Total equity and liabilities  158,167,055  261,788,732 36,186,166  146,057,411

===== SIDA 58 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
57 
 
 
Statements of financial position - continued 
 
The notes on pages 68 to 128 are an integral part of these consolidated financial statements.  
 
The consolidated financial statements on pages 55 to 128 were authorised for issue by the Board of 
Directors on 11 April 2025 and were signed on its behalf, as per the Directors' Declaration on the ESEF 
Annual Financial Report submitted in conjunction with the Annual Report and Consolidated Financial 
Statements 31 December 2024, by: 
 
 
__________________________________  __________________________________ 
 
Mr. Jonas Warrer     Mr. Giuseppe Muscat 
Director       Director

===== SIDA 59 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
58 
 
 
Income statements 
 
   Group  Company 
   Year ended 31 December 
      
 Notes 2024 2023 2024 2023 
  € € € € 
      
Net revenue 23(a) 122,772,975  88,616,883  - - 
      
Operating expenses      
Personnel expenses 24 (15,594,427) (10,176,446) - - 
Depreciation and amortisation 5, 8, 9 (17,624,741) (12,487,809) - - 
Impairment losses 10 - - (59,993,661) (55,614,924) 
Marketing, including commission 23(c) (32,019,869) (26,777,432) - - 
Other operating 
(expenses)/income 23(b) (18,700,274) (9,725,658) (453,725) 10,397,671 
Total operating expenses  (83,939,311) (59,167,345) (60,447,386) (45,217,253) 
      
Other income/(expense) 25 637,229  718,117 43,255 (898,382) 
Operating profit/(loss) pre 
transaction costs 
  
 
39,470,893  30,167,655 (60,404,131) (46,115,635) 
Transaction costs 23(d) - (2,007,435) - (1,690,743) 
Operating profit/(loss)  39,470,893  28,160,220 (60,404,131) (47,806,378) 
Finance income 26 373,720  - 1,301,515 - 
Finance costs 27 (13,889,659) (9,470,908) (10,093,762) (7,611,025) 
Profit/(loss) before tax  25,954,954  18,689,312 (69,196,378) (55,417,403) 
Tax credit/(expense) 28 371,601  (3,245,902) - 21,187 
Profit/(loss) for the year from 
continuing operations 
 
26,326,555  15,443,410 (69,196,378) (55,396,216) 
      
Loss from discontinued 
operations distributed to 
owners 7 (78,912,417) (1,416,454) - - 
      
Profit/(loss) for the year  (52,585,862) 14,026,956 (69,196,378) (55,396,216) 
      
Profit for the year is attributable 
to: 
 
    
Owners of the company from 
continued operations 
 
25,868,697 15,368,117   
Owners of the company from 
discontinued operations 
 
(78,912,417) (1,416,454)   
Non-controlling interests  457,858 75,293   
  (52,585,862) 14,026,956   
 
The accompanying notes on pages 68 to 128 are an integral part of these consolidated financial statements.

===== SIDA 60 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
59 
 
 
Statements of comprehensive income 
 
   Group  Company 
   Year ended 31 December 
      
  2024 2023 2024 2023 
  € € € € 
      
Profit/(loss) for the year  (52,585,862) 14,026,956 (69,196,378) (55,396,216) 
      
Other comprehensive income      
Items that may subsequently be 
reclassified to profit or loss 
 
    
Exchange differences on 
translation of foreign operations 
 
(311,842) (175,042) - - 
Recycling of accumulated 
exchange differences from 
disposal of Platform & Sportsbook 
segment 
 
373,000 - - - 
Total other comprehensive income 
for the year, net of deferred tax 
 
61,158 (175,042) - - 
Total comprehensive income for 
the year 
 
(52,524,704) 13,851,914 (69,196,378) (55,396,216) 
      
      
Total comprehensive income for 
the year is attributable to: 
 
    
Owners of the company  (52,982,562) 13,776,621   
Non-controlling interests  457,858  75,293   
  (52,524,704) 13,851,914   
      
Total comprehensive income 
attributable to the Owners of the 
company relates to: 
 
    
Total comprehensive income from 
continuing operations 
 
25,929,855  15,193,074   
Total comprehensive income from 
discontinued operations 
 
(78,912,417) (1,416,453)   
  (52,982,562) 13,776,621   
 
The accompanying notes on pages 68 to 128 are an integral part of these consolidated financial statements.

===== SIDA 61 =====

Gentoo Media p.l.c. 
 Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
60 
 
 
Statements of changes in equity 
 
Group  Attributable to owners of the company   
           
         Non-  
 Note Share Share   Capital  Merger Other Accumulated  controlling Total 
  capital premium reserves reserve reserves deficit Total interest equity 
  € € € € € € € € € 
             
Balance at 1 January 2023  50,000 2,304,345 145,902,884 3,533,484 (14,006,520) (87,436,646) 50,347,557 239,985 50,587,542 
Comprehensive income           
Profit for the year  - - - - - 13,951,663 13,951,663 75,293 14,026,956 
Other comprehensive income:           
Currency translation differences 17 - - - - (175,042) - (175,042) - (175,042) 
Total other comprehensive 
income for the year, net of tax  
 
- - - - (175,042) - (175,042) - (175,042) 
Total comprehensive income 
for the year 
 
- - - - (175,042) 13,951,663 13,776,621 75,293 13,851,914

===== SIDA 62 =====

Gentoo Media p.l.c. 
 Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
61 
 
 
Statements of changes in equity - continued 
 
Group   Attributable to owners of the company    
           
          Non-   
 Note Share Share Capital Merger Other Accumulated  controlling Total 
  capital premium reserves reserve reserves deficit Total interest equity 
  € € € € € € € € € 
Transactions with owners           
Share-based payments 15 - - 1,534,286 - - - 1,534,286 - 1,534,286 
Capital contribution arising on 
acquisition of subsidiary 
15 
- - 4,264,793 - - - 4,264,793 - 4,264,793 
Total transactions with 
owners, recognised directly 
in equity 
 
- - 5,799,079 - - - 5,799,079 - 5,799,079 
           
Balance at 31 December 2023  50,000 2,304,345 151,701,963 3,533,484 (14,181,562) (73,484,973) 69,923,257 315,278 70,238,535

===== SIDA 63 =====

Gentoo Media p.l.c. 
 Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
62 
 
 
Statements of changes in equity - continued 
 
Group  Attributable to owners of the company   
           
         Non-  
 Note Share Share   Capital  Merger Other Accumulated  controlling Total 
  capital premium reserves reserve reserves deficit Total interest equity 
  € € € € € € € € € 
             
Balance at 1 January 2024  50,000 2,304,345 151,701,963 3,533,484 (14,181,562) (73,484,973) 69,923,257 315,278 70,238,535 
Comprehensive income           
Loss for the year  - - - - - (53,043,720) (53,043,720) 457,858 (52,585,862) 
Other comprehensive income:           
Currency translation differences 17 - - - - (311,842) - (311,842) - (311,842) 
Recycling of accumulated 
exchange differences from 
disposal of Platform division 17 - - - - 373,000 - 373,000 - 373,000 
Total other comprehensive 
income for the year, net of tax  
 
- - - - 61,158 - 61,158 - 61,158 
Total comprehensive income 
for the year 
 
- - - - 61,158 (53,043,720) (52,982,562) 457,858 (52,524,704)

===== SIDA 64 =====

Gentoo Media p.l.c. 
 Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
63 
 
 
Statements of changes in equity - continued 
 
Group   Attributable to owners of the company    
          Non-   
 Note Share Share Capital Merger Other Accumulated  controlling Total 
  capital premium reserves reserve reserves deficit Total interest equity 
  € € € € € € € € € 
Transactions with owners           
Issue of share capital 13 115,000,000 - (115,000,000) - - - - - - 
Reduction in share capital 13 (100,412,000) - 100,412,000 - - - - - - 
Fair value of employee services 15 - - 58,709 - - - 58,709 - 58,709 
Capital contribution arising on 
acquisition of subsidiary 
 
15 - - 13,335,561 - - - 13,335,561 - 13,335,561 
Business combinations 6, 8 - - - - - - - 662,867  662,867 
Changes in ownership interest in 
subsidiaries without loss of control 8 - - - - (303,790) - (303,790) (195,877) (499,667) 
Transfers within equity 13, 15 - - (10,159,483) (3,533,484) 13,692,967 - - - - 
Distributions 7, 13 - - (55,998,860) - - - (55,998,860) - (55,998,860) 
Total transactions with owners, 
recognised directly in equity 
 
14,588,000 - (67,352,073) (3,533,484) 13,389,177 - (42,908,380) 466,990 (42,441,390) 
           
Balance at 31 December 2024  14,638,000 2,304,345 84,349,890 - (731,227) (126,528,693) (25,967,685) 1,240,126 (24,727,559)

===== SIDA 65 =====

Gentoo Media p.l.c. 
 Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
64 
 
 
Statements of changes in equity - continued 
 
Company Note Share Share Capital Merger Accumulated  
  capital premium reserves reserve deficit Total 
  € € € € € € 
        
Balance at 1 January 2023  50,000 2,304,345 125,323,957 5,886,789 (87,267,856) 46,297,235 
Comprehensive income        
Loss for the year  - - - - (55,396,216) (55,396,216) 
Total comprehensive income for the year   - - - - (55,396,216) (55,396,216) 
          
Transactions with owners         
Capital contribution arising on acquisition of subsidiary 15 - - 4,247,640 - - 4,247,640 
Total transactions with owners, recognised directly in 
equity 
  
- - 4,247,640 - - 4,247,640 
          
Balance at 31 December 2023   50,000 2,304,345 129,571,597 5,886,789 (142,664,072) (4,851,341)

===== SIDA 66 =====

Gentoo Media p.l.c. 
 Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
65 
 
 
Statements of changes in equity - continued 
 
 
The accompanying notes on pages 68 to 128 are an integral part of these financial statements.
Company Note Share Share Capital Merger Accumulated  
  capital premium reserves reserve deficit Total 
  € € € € € € 
        
Balance at 1 January 2024  50,000 2,304,345 129,571,597 5,886,789 (142,664,072) (4,851,341) 
Comprehensive income        
Loss for the year  - - - - (69,196,378) (69,196,378) 
Total comprehensive income for the year   - - - - (69,196,378) (69,196,378) 
          
Transactions with owners         
Issue of share capital 13 115,000,000 - (115,000,000) - - - 
Reduction in share capital 13 (100,412,000) - 100,412,000 - - - 
Capital contribution arising on acquisition of subsidiary 15 - - 2,496,407 - - 2,496,407 
Transfers within equity 15, 16 - - 5,886,789 (5,886,789) - - 
Distributions 7, 13 - - (55,998,860) - - (55,998,860) 
Total transactions with owners, recognised directly in equity   14,588,000 - (62,203,664) (5,886,789) - (53,502,453) 
        
Balance at 31 December 2024   14,638,000 2,304,345 67,367,933 - (211,860,450) (127,550,172)

===== SIDA 67 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
  66 
 
Statements of cash flows 
 
   Group  Company 
   Year ended 31 December 
      
 Notes 2024 2023 2024 2023 
  € € € € 
      
Cash flows from operating activities      
Cash generated from/(used in) 
operations 29 37,448,687 46,005,462 (11,742,790) (15,230,833) 
Interest received  4,500  196,974 - - 
Interest paid  - (1,559,460) - (108,157) 
Tax paid/(received)  (362,930) (99,087) - 21,187 
Net cash generated from/(used in) 
operating activities  37,090,257 44,543,889 (11,742,790) (15,317,803) 
      
Cash flows from investing activities      
Payments for intangible assets 8 (21,693,514) (20,762,876) - - 
Purchases of property, plant and 
equipment 9 (948,683) (1,454,021) - - 
Acquisition of subsidiaries, net of cash 
acquired 6 (17,167,491) (36,202,608) (11,000,000) (4,247,640) 
Net cash used in investing activities  (39,809,688) (58,419,505) (11,000,000) (4,247,640) 
      
Cash flows from financing activities      
      
Net receipts/repayment of loan from 
ultimate parent 20 (1,296,386) 7,775,390 578,613 8,532,472 
Net proceeds from issuance of bond and 
drawdowns on other borrowings 20 22,203,885 55,152,977 22,203,885 55,152,977 
Redemption of bond 20 - (28,839,696) - (28,839,696) 
Loan repayment (inclusive of accrued 
interest) 20 (12,258,000) (3,828,806) - - 
Interest paid on borrowings  (10,182,254) (6,260,356) (9,333,614) (6,260,356) 
Capital contribution received from 
Group's Parent 15 6,569,225 - - - 
Lease liability principal payments 5 (2,349,382) (2,569,820) - - 
Net cash generated from financing 
activities  2,687,088 21,429,689 13,448,884 28,585,397 
      
Net movement in cash and cash 
equivalents  (32,343) 7,554,073 (9,293,906) 9,019,954

===== SIDA 68 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
  67 
 
Statements of cash flows - continued 
 
 
 
 
 Group Company 
 
 Year ended 31 December 
 
 2024 2023 2024 2023 
  € € € € 
Cash and cash equivalents at 
beginning of year  21,284,062 13,729,989 9,517,738 497,784 
Cash and cash equivalents of 
distributed Platform & Sportsbook 
segment  (9,967,918) - - - 
Cash and cash equivalents at end of 
year  11,283,801 21,284,062 223,832 9,517,738 
Cash and cash equivalents 
classified as held for distribution to 
owners  - (5,957,370) - - 
Cash and cash equivalents at end of 
year in the statement of financial 
position 12 11,283,801 15,326,692 223,832 9,517,738 
 
 
The accompanying notes on pages 68 to 128 are an integral part of these consolidated financial statements.

===== SIDA 69 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
  68 
 
Notes to the financial statements 
 
1 Summary of material accounting policies 
 
The principal accounting policies adopted in the preparation of these consolidated financial statements are 
set out below. These policies have been consistently applied to all the years presented, unless otherwise 
stated. 
 
1.1 Basis of preparation 
 
During an extraordinary general meeting held on 23 September 2024, a decision was taken to change the 
name of the company from Gaming Innovation Group p.l.c. to Gentoo Media p.l.c. (the "Group", "Company", 
"Gentoo" or “Gentoo Media”). Reference to Group, C ompany or Gentoo going forward throughout the 
financial statement and notes to the financial statement refers to Gentoo Media p.l.c. (formerly known as 
Gaming Innovation Group p.l.c.). 
 
The consolidated financial statements include the financial statements of Gentoo Media  p.l.c. and its 
subsidiaries. These consolidated financial statements are prepared in accordance with IFRS Accounting 
Standards as adopted by the EU and the requirements of the Maltese Companies Act (Cap. 386).  They 
have been prepared under the historical cost convention, except for contingent consideration which is 
measured at fair value. 
 
The preparation of the consolidated financial statements in conformity with IFRS  Accounting Standards as 
adopted by the EU requires the use of certain critical accounting estimates.  It also requires the directors to 
exercise their judgement in the process of applying the Group’s accounting policies (see Note 4 – Critical 
accounting estimates and judgements). 
 
Going concern 
 
As at 31 December 2024, the Group’s current liabilities exceeded its current assets by EUR 49,725,088.  
 
2024 was a transformative period for the Group and after successfully completing the strategic split 
announced by the Board, the Group is well positioned as a stand -alone business to capitalize on growth 
opportunities and enhance its market presence. In May 2024, the Group completed the acquisition of Titan 
Inc. Limited which in line with the Group’s strategy was acquired with the objective to create long -term 
sustainable growth and from which the Group expects to obtain significant cost synergies. The full revenue 
and cost savings impacts are therefore expected for 2025. The Group is well -positioned for mowing into a 
growth phase to reach its aspirations for the future. 
 
Further, during 2024 the Group also achieved material revenue growth of 39%, both organically and due to 
prior year acquisitions. The Group has therefore proven its ability to integrate acquired businesses 
enhancing the growth potential of the Group. 
 
The Group’s net cash generated from operating activities, which includes the discontinued platform 
business, declined to EUR 32.8 million due to negative net working capital in 2024 compared with EUR 
44.6 million in 2023. The Group expects strong cash gene ration for 2025 in line with the Group’s business 
plans and track record over the years and expects a total outflow of EUR 35 million in payments related to 
acquisitions made in previous years, of which approximately EUR 23 million relates to Q1 2025.  
 
Further, in December 2024, the Group negotiated a EUR 25 million revolving credit facility with Citibank to 
ensure short term liquidity and long-term strategic partnership on financing. 
 
At year end EUR 7 million was borrowed on the revolving credit facility and subsequent to 31 December 
2024, EUR 16 million was drawn down to pay off current liabilities. Group management assesses that, 
based on the current business performance and the cred it facilities available, the Group has sufficient 
capital resources to continue its operations and to realise its strategic ambitions for the future.

===== SIDA 70 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
  69 
 
1 Summary of material accounting policies - continued 
 
1.1 Basis of preparation - continued 
 
Going concern - continued 
 
As a result of the above, the board of directors consider the going concern assumption in the preparation 
of the Group’s and Company’s financial statements to be appropriate as at the date of authorization of 
issuance of the 2024 annual report and Consolidated Financial Statements. 
 
Standards, interpretations and amendments to published standards effective in 202 4 
 
In 2024, the Group and Company adopted new standards, amendments and interpretations to existing 
standards that are mandatory for the Group's and company ’s accounting period beginning on 1 January 
2024.  The adoption of these revisions to the requirements of IFRS Accounting Stan dards as adopted by 
the EU did not result in substantial changes to the Group's and Company’s recognition, measurement and 
presentation of items in these financial statements. 
 
Voluntary change in accounting policies 
 
(a) Application of the practical expedient to certain short-term leases 
 
The Group and the Company have changed their accounting policy for the recognition of short-term leases 
with effect from this financial period; prior to this change, they had applied the short-term practical expedient 
to leases of all classes of underlying  assets.  The Group and the Company are no longer applying the 
practical expedient (which is available on a class -by-class basis) to leases of office premises, but they 
continue to apply it to leases of other classes of underlying assets. This change in ac counting policy was 
adopted in order to have one consistent model for the classification and presentation of the Group’s and 
the Company’s rights and obligations arising from all its leases of office premises. The Group and the 
Company did not have any short-term lease arrangements for office premises prior to the fourth quarter of 
2024, and consequently the financial information for prior reported periods is not restated.  Right -of-use 
assets and lease liabilities amounting to EUR 393,737 were initially re cognised in 2024 as a result of the 
change in accounting policy, with amortisation charges and interest cost of EUR 130,761 and EUR 5,421 
respectively being recognised in profit or loss. Had the Group and the Company not changed their 
accounting policy, sh ort-term lease arrangements for office premises would not have been recognised in 
the statement of financial position, and lease rental costs of EUR 0.15m would have been recognised in 
profit or loss in place of the amortisation and interest charges. 
 
(b) Amortisation of transaction costs incurred upon originating debt 
 
The Group and the Company have also changed their accounting policy for the amortisation of transaction 
costs incurred upon originating floating -rate debt instruments.   IFRS 9 is silent on how such transaction 
costs should be amortised for floating rate instruments; prior to the change in accounting policy, the Group 
and the Company amortised such transaction costs by reference to the interest rate applicable at 
inception.  Following the change in accounting policy, the Group and the Company amortise capita lised 
transaction costs on floating -rate instruments on a straight -line basis.  Management believes that the 
practical application of the new policy more closely captures the economic effect of such transaction costs 
over the estimated life of the debt. 
 
The Group’s and the Company’s borrowings as at 1 January 2023 had a remaining maturity at that date of 
18 months.  Management determined that the adoption of the new policy has had an immaterial effect on 
the net carrying amount of the liabilities as at that date, as well as on the amounts amortised in the income 
statement for the year ended 31 December 2023.   Consequently, no changes have been made to the 
Group’s and the Company’s financial statements for the year ended 31 December 2023.

===== SIDA 71 =====

Gentoo Media p.l.c. 
Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
  70 
 
1 Summary of material accounting policies - continued 
 
1.1 Basis of preparation - continued 
 
New standards and interpretations not yet adopted 
 
Generally, all new and amended IFRS Accounting Standards and interpretations are expected to be 
implemented by the Group when they become mandatory and have been endorsed by the EU.  Certain new 
accounting standards and interpretations have been published that are not mandatory for 31 December 
2024 reporting periods. 
 
These amended and new standards are not expected to have a material impact on the Group's recognition 
and measurement of items within these consolidated financial statements in the current or future reporting 
periods and on foreseeable future transactions.  
 
IFRS 18: Presentation and Disclosure in Financial statements 
From 1 January 2027, IFRS 18 will replace IAS 1 subject to endorsement for use in the EU, introducing new 
requirements that will help to achieve comparability of financial performance of similar entities and provide 
more relevant information and transparency to users. 
 
Even though IFRS 18 will not impact the recognition and measurement of items, its impact on presentation 
(including definition of certain required subtotals) and disclosures is expected to be pervasive, in particular 
those related to the statement of profi t or loss and providing management -defined performance measures 
within the financial statements. The key new concepts introduced in IFRS 18 relate to:  
 
● the structure of the statement of profit or loss;  
● required disclosures in the financial statements for certain profit or loss performance measures that 
are reported outside an entity’s financial statements (that is, management -defined performance 
measures); and  
● enhanced principles on aggregation and disaggregation which apply to the primary financial 
statements and notes in general. 
 
The Group has not yet analysed the impact of the new standard but will do so in due course.  
 
1.2 Business combinations and consolidation 
 
(a) Business combinations 
 
The Group applies the acquisition method of accounting to account for business combinations other than 
those between entities under common control.  The consideration transferred for the acquisition of a 
subsidiary is the fair values of the assets transfer red, the liabilities incurred to the former owners of the 
acquiree, and the equity interests issued by the Group.  The consideration transferred includes the fair value 
of any asset or liability resulting from a contingent consideration arrangement.  Acquisition-related costs are 
expensed as incurred.  Identifiable assets acquired and liabilities and contingent liabilities assumed 
(identifiable net assets) in a business combination are measured initially at their fair values at the acquisition 
date. 
 
Goodwill is initially measured as the excess of the consideration transferred (together with, if applicable, the 
amount of any non -controlling interest in the acquiree and the acquisition -date fair value of any previous 
equity interest in the acquiree) over the fair value of the identifiable net assets acquired.

===== SIDA 72 =====

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Annual Report and Consolidated Financial Statements – 31 December 2024 
 
 
  71 
 
1 Summary of material accounting policies - continued 
 
1.2 Business combinations and consolidation - continued 
 
(b)  Subsidiaries 
 
Subsidiaries are all entities over which the Group has control.  The Group controls an entity when the Group 
is exposed to, or has rights to, variable return from its involvement with the entity and has the ability to affect 
those returns through its power over the entity. 
 
Subsidiaries are fully consolidated from the date on which control is transferred to the Group.  They are  
deconsolidated from the date that control ceases. 
 
Upon consolidation, inter-company transactions, balances and unrealised gains on transactions between  
Group companies are eliminated.  Unrealised losses are also eliminated but considered an impairment 
indicator of the asset transferred.  Accounting policies of subsidiaries have been changed where necessary 
to ensure consistency with the policies adopted by the Group. 
 
(c) Non-controlling interests 
 
The group recognises non -controlling interests in an acquired entity at the noncontrolling interest’s 
proportionate share of the acquired entity’s net identifiable assets. This decision is made on an acquisition-
by-acquisition basis. For the non-controlling interests in Time2Play, the group elected to recognise the non-
controlling interests at their proportionate share of the acquired net identifiable assets.  
 
1.3 Investments in subsidiaries 
 
In the Company’s separate financial statements, investments in subsidiaries are accounted for by the cost 
method of accounting, i.e. at cost less impairment. Cost includes directly attributable costs of the 
investment.  
 
Impairment adjustments are recorded where, in the opinion of the directors, there is an impairment in the 
value of an asset.  Where there has been an impairment in the value of an investment, it is recognised as 
an expense in the period in which the diminution is identified.  The results of subsidiaries are reflected in 
the Company’s separate financial statements only to the e xtent of dividends receivable. On disposal of an 
investment, the difference between the net disposal proceeds and the carrying amount is charged or 
credited to profit or loss. 
 
1.4 Segment information 
 
The Group determines and presents operating segments based on the information that internally is provided 
to the Group’s management team, which is the Group’s chief operating decision -maker in accordance with 
the requirements of IFRS 8 ‘Operating segments’. 
 
An operating segment is a component of the Group that engages in business activities from which it may 
earn revenues and incur expenses including revenues and expenses that relate to transactions with any of 
the Group’s other components, and for which disc rete financial information is available.  An operating 
segment’s operating results are reviewed regularly by the Group’s management team to make decisions 
about resources to be allocated to the segment and to assess its performance executing the function of the 
chief operating decision-maker. 
 
The accounting policies of the reportable segments are the same as applied by the Group as described 
throughout this note.

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1 Summary of material accounting policies - continued 
 
1.5 Foreign currency translation 
 
(a) Functional and presentation currency 
 
Items included in the financial statements of each of the Group’s entities are measured using the currency 
of the primary economic environment in which the entity operates (‘the functional currency’).  The 
consolidated financial statements are presented in  euro (“EUR”), which is also the functional currency of 
the parent company. 
 
(b) Transactions and balances 
 
Foreign currency transactions are translated into the functional currency using the exchange rates prevailing 
at the dates of the transactions. Foreign exchange gains and losses resulting from the settlement of such 
transactions and from the translation at  year-end exchange rates of monetary assets and liabilities 
denominated in foreign currencies are recognised in profit or loss.  The Group’s and the Company’s 
accounting policy is to present all exchange differences within finance (costs)/income, including  exchange 
differences arising on cash and cash equivalents and amounts due from payment providers.  
 
(c) Group companies 
 
Income statements of foreign entities are translated into the Group’s presentation currency at the average 
exchange rates for the year and assets and liabilities are translated at the exchange rates ruling at year -
end.  All resulting translation differences are recognised in other comprehensive income. 
 
Exchange differences arising from the translation of the net investment in foreign operations are taken to 
other comprehensive income.  On disposal or partial disposal of a foreign entity, translation differences that 
were previously recognised in other co mprehensive income are recognised in profit or loss as part of the 
gain or loss on sale. 
 
Goodwill and fair value adjustments arising on the acquisition of a foreign entity are treated as assets and 
liabilities of the foreign entity and translated at the closing rate.  Translation differences are recognised in 
other comprehensive income. 
 
1.6 Intangible assets 
 
(a) Goodwill 
 
Goodwill arises on the acquisition of subsidiaries as set out in note 6 and goodwill as shown in note 8.  
 
For the purpose of impairment testing, goodwill acquired in a business combination is allocated to each of 
the cash-generating units (“CGUs”), or Groups of CGUs, which are expected to benefit from the synergies 
of the combination.  Each unit or Group of un its to which the goodwill is allocated represents the lowest 
level within the entity at which the goodwill is monitored for internal management purposes.  
 
Goodwill impairment reviews are undertaken annually or more frequently if events or changes in 
circumstances indicate a potential impairment. The carrying value of goodwill is compared to the 
recoverable amount, which is the higher of value in use and fair value less costs of disposal.  Any impairment 
is recognised immediately as an expense and is not subsequently reversed.

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1 Summary of material accounting policies - continued 
 
1.6 Intangible assets - continued 
 
(b) Domains 
 
Domains comprise the value of domain names acquired by the Group as well as the value derived from the 
search engine optimization activity embedded in the acquired portfolios.  Separately acquired domains are 
shown at historical cost, which represent their acquisition price and certain domains are expected to have 
a useful life of 8 years.  Amortisation is calculated using the strai ght-line method to allocate the cost of 
domains over their estimated useful lives.  
 
(c) Affiliate contracts and customer relationships 
 
Acquired affiliate contracts are shown at historical cost and are deemed to have a useful life of 3 years, 
determined by reference to the expected user churn rate.  Where such assets are acquired in a business 
combination, historical cost represents their acquisition-date fair value. 
 
(d) Trademarks 
 
Separately acquired trademarks and licences are shown at historical cost.  Trademarks acquired in a 
business combination are recognised at fair value at the acquisition date.  Trademarks have indefinite useful 
lives and are subsequently carried at cost les s impairment losses.  The trademarks are not amortised and 
are held indefinitely because trends show that they will generate net cash inflows for the Group for an 
indefinite period.  The assessment of indefinite useful life of trademarks is based on the Group’s track record 
of stability in market share and cash flows.  Furthermore, the commitment of management to continue to 
invest for the long term to extend the period over which the trademarks are expected to continue to provide 
economic benefits.  
 
(e) Computer software and technology platforms 
 
Acquired computer software and technology platforms are capitalised on the basis of the costs incurred to 
acquire and bring to use these assets.  Where such assets are acquired in a business combination, historical 
cost represents their acquisition-date fair value.  These costs are amortised over their estimated useful lives 
of 3 years, in the case of computer software, over the term of the licence agreement, if different.  
 
Development costs that are directly attributed to the design and testing of identifiable and unique software 
products controlled by the Group are recognised as intangible assets when the following criteria are met:  
 
● it is technically feasible to complete the intangible asset so that it will be available for use;  
● management intends to complete the intangible asset and use or sell it;  
● there is an ability to use or sell the intangible asset; 
● it can be demonstrated how the intangible asset will generate probable future economic benefits;  
● adequate technical, financial and other resources to complete the development and to use or sell 
the intangible asset are available; and 
● the expenditure attributable to the intangible asset during its development can be reliably measured. 
 
Directly attributable costs that are capitalised as part of these intangible assets include the development 
employee costs; the assessment of whether such costs satisfy the above conditions for capitalisation is 
made by members of the Group’s chief officers and is based on data logged in a project management 
platform.  Other development expenditures that do not meet these criteria are recognised as an expense 
as incurred.

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