PAP.9.3.040 Gaming Regulations

(a) Title 31. Certain team members must complete Title 31 certification within ninety (90) days of their date of hire.

(b) Team Member Identification Badge.

(1) The Human Resource Department will issue an identification badge to team members upon their employment.

(A) In addition to identifying the team member, the identification badge is designed to gain access to restricted areas.

(B) If a team member transfers or is promoted to a different position, they must report to the Lac Court Oreilles Gaming Commission for a change of license prior to performing the responsibilities of the new position.

(C) The team member is responsible for this card and must immediately report any lost or stolen cards to their supervisor.

(2) All team members are required to display their team member badge at all times while on the property of the Gaming Enterprises, while conducting business of the employer, or whether they are on or off duty.

(A) All team members who are required to receive a gaming license must display their team member badges with their permit number visible and have their tribal gaming license in their possession.

(B) Pins, decorations and any other material, which could potentially obscure the badge, are prohibited.

(C) Team members who forget their badge may obtain a temporary badge from the Human Resource Department. The temporary badge must be returned to the Human Resource Department, Security Desk or Manager on Duty at the end of the team member's shift.

(D) Key team members must also have their gaming license with them that was issued by the Lac Court Oreilles Gaming Commission.

(3) Replacement ID badges will be made by the Human Resource Department. A cost may be assessed to the team member for replacement badge.

(4) Replacement licenses will be made by the Lac Court Oreilles Gaming Commission.

(5) Employer-issued I.D. badges and licenses are the property of the Gaming Enterprises and Tribe respectively and therefore, they must be collected when a team member terminates their employment.

(c) Responsible Gaming.

(1) The Gaming Enterprises are committed to a proactive approach to the role of a responsible business within the general community. Compulsive gambling behavior can negatively impact the lives of guests and/or other team members. This problem can also interfere with regular business operations.

(2) The employer utilizes the posting of helpful information so persons who seek assistance are directed to professional resources that specialize in assisting the compulsive gambler.

(d) Team Member Gaming on Premises.

(1) The following team members are excluded from any and all gaming activities at the Casino:

(A) Chief Executive Officer;

(B) Chief Operations Officer;

(C) Chief Financial Officer;

(D) Executive Manager;

(E) Manager on Duty (MOD);

(F) Directors/Managers of all Departments;

(G) Information Technology Department;

(H) Revenue Audit Department;

(I) Accounting Department;

(J) Marketing Department;

(K) Compliance Officer;

(L) Slot Analyst;

(M) Grindstone Creek Casino – Floor Key and On-Call positions.

(2) Except as established in Section PAP.9.3.040(d)(1) above, all slot personnel are prohibited from playing the slots but can play table games and bingo;

(3) All Table Games Personnel are prohibited from playing the table games, including poker;

(4) All Bingo Personnel are prohibited from playing Bingo;

(5) Except as established in Section PAP.9.3.040(d)(1) and (c) above, all team members are allowed to play poker.

(6) All team members are prohibited from playing any wide area progressive machines.

(7) Requirements for team members to gamble at the premises:

(A) Be 18 years of age at the Casino;

(B) Be out of uniform;

(C) Be off duty;

(D) Have ID badge removed;

(E) Abide by all the employer's policies and procedures while gambling at the employer's premises;

(F) Be consistent with gaming rules and regulations of the enterprise, and all other applicable laws and regulations;

(G) Team members are not allowed to utilize a Players Club Card or participate in any promotional activity.

(e) Underage Gaming.

(1) The Gaming Enterprises shall ensure that no one under the age of 18 is permitted to participate in gaming activities at Gaming Enterprises.

(2) The Gaming Enterprises provide ongoing, mandatory training to customer contact team members to ensure that persons less than 21 years of age at the Gaming Enterprises are not permitted to consume alcoholic beverages.

(f) Key and Non-key Employees.

(1) Key Employees (Full-time / Part-time):

(A) Bingo Caller;

(B) Counting room supervisor;

(C) Chief of security;

(D) Custodian of gaming supplies or cash;

(E) Floor manager;

(F) Pit boss;

(G) Dealer;

(H) Croupier

(I) Approver of credit;

(J) Custodian of gambling devices including persons with access to cash and accounting records within such devices;

(K) If not otherwise included, any other person whose total cash compensation is in excess of fifty thousand dollars ($50,000.00) per year; or

(L) If not otherwise included, the four most highly compensated persons in the gaming operation.

(2) Non-key Employees:

(A) Administration – Elder Host / Hostess and Receptionist;

(B) Facilities – Warehouse Supervisor, Maintenance Supervisor, Maintenance Technician;

(C) Food & Beverage – Lead Kitchen Supervisor, Buffet Supervisor, Line Supervisor, Buffet Cook, Line Cook, Kitchen Helper, Assistant Steward, and Sous Chef positions;

(D) Lodge – Housekeeper, Laundry Assistant, Public Space Cleaner, and Room Attendant positions.