(2) Expense Reimbursement. Board members are entitled to
claim reimbursement for reasonable expenses incurred while
performing authorized Board activities. Expense reimbursement
will take place on a basis comparable to the basis under which
members of the Siletz Tribal Council are reimbursed for expenses.

(3) Other Expenses. The Board of Directors and Board
members may incur other expenses as necessary in carrying out
their job responsibilities under the Charter and under this
policy. Such expenses will be judged for business-relatedness
according to GAAP principles, and will be reviewed and audited on
an annual basis or more frequently as deemed necessary in the
sole discretion of the Siletz Tribal Gaming Commission. The
underlying principle by which such expenses will be judged is
whether an expense was incurred on a reasonable basis to advance
the business purposes of the Siletz Tribe’s Gaming Operation, and
whether such expense would have been incurred but for the
existence and operation of Chinook Winds Casino by the Siletz
Tribe. In specific instances it will be appropriate for Board
members to engage in authorized Board activities in the company
of spouses or another appropriate person, and in such instances a
meal taken by such person shall be considered an authorized Board
or Gaming Operation expense; when and as these circumstances
arise, they will be listed below in this policy.

(4) Budget Category. Board member compensation and Board and
Board members expenses will be paid from and charged to the Board
of Directors’ annual budget or other appropriate Gaming Operation
budget, as permitted by GAAP principles.

(B) Authorized Board Activities:

The following list is a non-exhaustive list of Board of
Directors activities for which Board members will generally be
entitled to claim compensation and reimbursement of expenses, and
for which expenses incurred may appropriately be charged to the
proper Chinook Winds budget:

(1) Board of Directors meetings, regular or special;

(2) Board of Directors workshops, budget preparation and
review, strategic planning, similar meetings that are
not formal Board meetings (regular or special), and the
general conduct of Board business outside of formal
meetings;

Proposed Siletz Tribal Gaming Enterprise Board
of Directors Policy # 3 - Page 3 of 4


a. Board members may issue or authorize meal comps to
any or all dining venues within Chinook Winds
Casino to any player or patron of the Casino to
encourage or reward play or to other persons when
the business purposes of the Casino will be
advanced. Meal comps issued by the Board may set
out a specific amount, set a maximum amount, or
may be for a meal for a set number of persons at a
specific dining venue;

b. Board members shall not issue comps to themselves,
to other Board members, to the immediate family
(as defined in the Tribal Council Ethics Code) of
any Board members, to tribal employees, to casino
employees, or to other persons who would otherwise
be ineligible to receive a comp under the Board’s
comp policy.

6. Board members will be involved with entertainment
events sponsored by Chinook Winds Casino on the following basis:

a. Board members attend entertainment and special
events held at and sponsored by Chinook Winds
Casino as part of the marketing and promotional
efforts of the Casino (when an entertainer gives
more than one show during an appearance at the
Casino, this section will apply to only one show
given by said entertainer, the show to be selected
by each Board member). Each Board member will be
issued 2 tickets to each such event, to be used by
the Board member and another appropriate person
who may include an immediate family member. The
Board member and person accompanying the Board
member may take a meal, as a Board expense,
immediately before or after the entertainment
event. Each Board member will be issued an
additional six (6) tickets to each such
entertainment event, to be distributed by the
Board member to players or patrons of the Casino
to encourage or reward play or to other persons
who will advance the business purposes of the
Casino. Tickets distributed by the Casino to Board
members under this subsection (a) of paragraph 6
will be charged as a promotional or marketing
expense of the Casino or will be charged to
another appropriate Casino budget category. Board
members will not distribute their additional

Proposed Siletz Gaming Enterprise Board
of Directors Policy # 1 - Page 3 of 6


The Commission will review and audit comps as defined
above to determine whether they should be disallowed
and other enforcement action taken.

The Commission will be guided by the following policy
statements in reviewing and auditing comps issued or
authorized by the Board or Board members:

1.

Comps will not be issued to or authorized to cover
expenses incurred by the Board of Directors or
Board members while engaged in authorized Board
activities. Expenses incurred by the Board of
Directors or Board members while engaged in
authorized Board activities that are directly
related to the gaming operation shall be charged
separately to the gaming operation accounts.
Authorized Board and Board member expenses will be
charged to the Board budget or other appropriate
Gaming Operation budget category, and will not be
charged as a comp expense. Casino management will
review Board and Board member comp expenses on a
monthly basis to ensure that activities have been
properly charged as a comp or as an expense, and
will correct comps that should be charged as an
expense. Nothing in this regulation is intended
to authorize the Board or tribal government or its
employees to incur expenses for evaluating gaming
operation games if such Board member, Tribal
Council member, or employee does so with the
intent of retaining any winnings from the play of
a gaming operation game.

The Gaming Operation shall not issue or authorize
comps on behalf of the Board or individual Board
members. The Board and Board members will issue
or authorize comps to others, within the scope of
their authority to do so. The Gaming Operation
may charge expenses incurred by the Board or Board
members while engaged in authorized activities to
the Board or other appropriate budget.

Tribal Council, tribal governmental, and tribal
departmental events or activities will not be
covered or charged as a comp. Such expenses are
tribal governmental expenses, will be billed by
the Gaming Operation to the Tribe, and reimbursed

Proposed changes Chapter 17

Page 3 of 6


EXHIBIT 1

Amendment to
Siletz Tribal Gaming Enterprise Charter, § 6.65

§ 6.65 Role of the Tribal Council: Board of Directors.
(a) Policy. The Tribal Council exercises ultimate authority

for the conduct of gaming activities and gaming operations by the
Siletz Tribe. The Tribal Council has determined that the most
efficient way to exercise its authority over tribal gaming is to
separate the governmental and regulatory functions of the Tribe’s
gaming operations from management of the Tribe’s Gaming
operation(s) itself. The Tribal Council, as the governmental
representative of the Tribe, which the Indian Gaming Regulatory
Act mandates “have the sole proprietary interest and
responsibility of the conduct of any gaming activity,” will
retain authority over governmental and regulatory aspects of the
Siletz Tribe’s gaming activities. 25 U.S.C. §§ 2710(b) (2) (A),
2710(d) (1) (A) (ii). A Board of Directors is hereby established
pursuant to this Charter to exercise the authority set forth
herein over the Tribe’s gaming operations.

(b) Board of Directors.

(1) Authority. The Tribal Council has by resolution
delegated day-to-day management and working policy
authority of Gaming operations to the General
Manager of each tribal Gaming operation. The
Board is delegated authority to establish general
gaming policy for Siletz tribal Gaming operations
and exercises oversight authority over each tribal
Gaming operation. The Board may adopt bylaws and
policies, enact procedural rules, and hire, retain
or contract for staff as necessary to carry out
its duties under this Charter.

(2) Makeup. There is established a Board of Directors
of the Siletz Tribal Gaming Enterprise, which
shall be comprised of the members of the Tribal
Council, sitting as a separate tribal entity. The
Board shall conduct its own meetings, retain or
contract staff as necessary, and exercise its
authority separate and independent from the Tribal

Proposed Amendment Siletz Tribal Gaming Enterprise
Charter, § 6.65 - Page 1 of 7


(3)

(4)

(5)

(6)

(7)

(8)

(9)

Observation of Casino manager meetings and other Casino
meetings and events such as employee luncheons,
entertainment review, staff meetings, sitting in on
Director interviews, and the like;

Meeting with the General Manager and other management
staff on Casino issues;

Attendance at entertainment events and at other Casino
sponsored events and activities, including but not
limited to Casino giveaways, promotional events and the
introduction of new games, activities or services;
provided, that compensation shall not be claimed for
such activities;

Attendance at national, regional or local gaming
meetings or conferences, and conducting fact-finding
investigations related to Casino policy issues;

Speaking on behalf of the Board at conferences or other
events taking place at the Casino and attending
meetings or activities outside the Casino on behalf of
the Board or to promote the Casino;

Meeting with local, State or Federal officials or
personnel, or with business people or the public, on
Casino related matters;

Meeting with or hosting at the Casino representatives
and officials of other Indian tribes who are visiting
the Casino on Casino related matters, or who are
engaged or wish to engage in gaming under IGRA.

(C) Other Activities:

The fact that an activity engaged in by a Board member or
the Board is not listed in Subsection (B) does not mean that the
activity is not an authorized Board activity; each activity must
be judged on its individual merits based upon the policy
standards set forth herein. The Board may amend this Policy from
time to time to add to or delete from activities listed under
Subsection (B). Board activities are subject to Tribal Gaming
Commissions regulatory oversight.

Proposed Siletz Tribal Gaming Enterprise Board
of Directors Policy # 3 - Page 4 of 4


Directors and Tribal Council, and the process the
Commission will follow to enforce this regulation
and to correct and/or sanction violations.

4. Notwithstanding sections V through XI, the
Commission may determine that the progressive
notification and sanction system is inappropriate
and proceed directly to section X or such other
process as it adopts to assure the integrity of
the Gaming Operation.

E. The Commission, in its annual engagement letter with an
independent auditor to audit the Gaming Operation
pursuant to IGRA and the Tribal-State Compact, will
specifically request the auditor to audit Board comps
for the previous calendar year for compliance with
Board Policy No. 1 and this regulation.

(The remainder of Commission Regulation Chapter 17 stays the
same).

Proposed changes Chapter 17
Page 6 of 6


working policy of the Casino.

The Board of Directors has adopted a policy stating
that Board and Board members have authority to incur
expenses while engaged in activities related to Board

“ responsibilities and the business purposes of the

Tribe’s Gaming Operation. Expenses incurred by the
Board and Board members pursuant to their authorized
responsibilities are charged as expenses of the Gaming
Operation and are charged to the Board of Directors’
budget or other appropriate Gaming Operation budgets.
The Commission finds that this Policy is reasonable and
related to the business purposes of the Tribe’s Gaming
Operation.

III. Definitions.

A.

Complimentary items (“comps”), for the purposes of this
regulation, are items and services, including cash and
non-cash gifts, and which are issued or authorized for
the purpose of attracting new patrons, rewarding
frequent patrons, retaining existing patrons, or which
are otherwise issued or authorized to advance the
business purposes of the Gaming Operation.

Iv. Policy.

A.

Proposed ch
Page 2 of 6

The Commission will review and audit comps issued by
the Board, General Manager and Guest Services Manager
to ensure compliance with the Indian Gaming Regulatory
Act, with the Tribal Gaming Ordinance, with Commission
regulations including this regulation, and with the
Class III Gaming Compact between the Siletz Tribe and
the State of Oregon. The Commission will require the
correction of comps that have been issued or authorized
or expenses that have been incurred in violation of any
of these authorities, and will take enforcement action
if corrections are not made in a timely fashion or if
intentional violations occur.

Such enforcement action may include the revocation or
suspension of the responsible persons gaming license,
the imposition of fines, the repayment of the
disallowed expense with interest, and such other action
as the Tribal Gaming Commission shall deem appropriate.

anges Chapter 17


EXHIBIT 3

Adopted by Board Resolution No.
Date:

Siletz Tribal Gaming Enterprise Board of Directors
Policy # 3

Role of the Board of Directors

Policy Statement:

The Siletz Tribal Gaming Enterprise Charter, adopted by
Tribal Council Resolution No. 97-104, March 21, 1997, as amended,
creates a Board of Directors as one of the four entities
responsible for the Siletz Tribe’s gaming activities under the
Indian Gaming Regulatory Act - the other three being the Gaming
Operation itself, the Tribal Council and the Siletz Tribal Gaming
Commission.

Section 6.65 of the Charter describes the role of the Board
of Directors. This role is currently vested with the Siletz
Tribal Council, sitting in a separate capacity than its tribal
government role. Section 6.65(a) declares that the Board of
Directors establishes gaming policy for the Tribe and exercises
oversight authority over the Tribe’s gaming operations.

The remainder of Section 6.65 sets out some of the specific
responsibilities of the Board, such as formally authorizing each
gaming activity engaged in by the Gaming Operation (§ 6.65(b),
necessary to ensure compliance with IGRA and the Tribal-State
Compact), approval of specific annual gaming budgets (§ 6.65(c),
necessary to balance gaming policy against other tribal interests
and to exercise oversight authority to ensure maximum return to
the Tribe), and for hiring and firing of the General Manager and
retention or contracting of Board staff (§ 6.65(d), necessary
because the General Manager is ultimately responsible for the
success and profitability of the Gaming Operation). Section 6.65
also sets out some functions that the Board will not be
responsible for, such as implementation of specific gaming
activities (§ 6.65(b)), personnel matters of the Gaming
Operation(§ 6.65(d)) and gaming operations (§ 6.65(d)).

Proposed Siletz Tribal Gaming Enterprise Board
of Directors Policy # 3 - Page 1 of 4


Operations of the Tribe, including the activities of the Board of
Directors as set out in this Charter.

(b) The Commission will adopt rules, regulations and
policies for the regulation of the Tribe’s gaming activities and
Gaming operation(s). Such rules and regulations will be
submitted to the Tribal Council for its review, and shall become
effective sixty (60) days after submission unless vetoed by
majority vote of the Tribal Council. If an emergency exists, the
Commission may provide for immediate effectiveness of a rule or
regulation, provided, that said emergency rules or regulations
will terminate if vetoed by the Tribal Council at the Council’s
next regular or special meeting.

(c) The Commission is constituted as an independent
regulatory agency of the Siletz Tribe, subject only to the
oversight authority of the Tribal Council. The Commission will
be responsible for developing and implementing its own budget,
subject to approval of the final budget by the Tribal Council,
and for hiring, firing, and discipline of its own staff. The
Tribal Council will ensure a sufficient budget for the Commission
for it to carry out its responsibilities under this Charter and
under the Tribal-State Compact. Commissioners may only be
terminated or removed by the Tribal Council during their term of
office for cause, upon due notice and after an opportunity for a
hearing open to tribal members, provided, the Chairman of the
Commission has authority to discipline or suspend other
Commissioners in the exercise of his or her authority as
Chairman. The Commission may contract with Tribal Administration
for purchase of support services such as accounting, payroll,
fleet services, etc. The Commission will be responsible for its
purchasing, provided, that all contracts for purchases of goods
and services not provided for in the Commission’s annual budget
will be subject to Tribal Council approval. The Commission staff
will be subject to the Tribe’s Personnel Policies and Operations
Manual (Annual Plan of Operations) until such time as the
Commission adopts its own Personnel Policies and Operations
Manual and such Policies and/or Manual are approved by the Tribal
Council. The Chairman of the Gaming Commission will serve as the
liaison between the Tribal Council and Gaming Commission and will
supervise the Gaming Commission and its staff. The Commission is
delegated authority to deal directly with the Tribal Attorney.
The Tribal Council may approve the Commission to contract with
outside counsel for technical assistance, or as necessary in the
event of a conflict.

Proposed Amendment Siletz Tribal Gaming Enterprise
Charter, § 6.65 - Page 6 of 7


EXHIBIT 6

COMPANY POLICY MEMORANDUM #

EFFECTIVE:

REVISED:

SUBJECT:

PURPOSE:

BILLING OF TRIBAL AND BOARD OF DIRECTORS EXPENSES

To enact a policy to provide for the charging of
expenses incurred by the Tribal Council, Tribe, and
tribal departments to the Siletz Tribe and the billing
of expenses incurred by the Board of Directors and
Board members to the Board budget.

APPLICATION: Accounting Department and Financial management

PROCEDURES:

1.

Policy. Chinook Winds will bill all expenses incurred
at the Casino by the Tribe, Tribal Council, or tribal
departments or programs to the appropriate tribal
department. Chinook Winds will charge all expenses
incurred by the Board of Directors or Board members in
carrying out their authorized activities to the Board
budget (send to the Tribal Council Executive Secretary
to charge to the Board of Directors’ Gaming Budget) or
to another appropriate Casino expense category.
Expenses incurred by the Tribe or the Board will be
charged at the Casino’s cost or at an appropriate value
assigned to that expense by Casino financial personnel.

Tribe, Tribal Council, and tribal departments or tribal
programs.

A. Tribal governmental activities will be encouraged
to take place at Chinook Winds where not in
conflict with other revenue generating activity.
Tribal, Tribal Council, tribal departmental or
tribal program activities will not receive
financial assistance for their activities from

Proposed Expenses Policy
Page 1 of 3


(3) The Board will approve the budget of each
Gaming operation as well as its own budget.
The Board will develop, present, approve and
modify the budgets specified in this
subsection.

(4) The Board will have no direct involvement in
personnel matters of tribal Gaming operations
except as set forth in subsection (A) of this
section.

(5) The Board will review any proposed changes to
the Personnel Policies of the Gaming
Operation for consistency with the general
gaming policy of the Tribe and, in
particular, compliance with tribal preference
policies in hiring and advancement. The
Board will be provided copies by each Gaming
Operation of proposed internal policies of
the Gaming Operation, or changes thereto, for
its information and review.

(6) The Board is responsible for communicating
information about the Gaming Operation to the
Tribe’s membership.

(5) Conduct of Board Meetings. Because of the
sensitive nature of the Tribe’s gaming activities,
and because confidential financial information,
business strategies and decisions, and personnel
information are the regular subject of Board
discussions, Board meetings will take place in
closed session, and members of the public will be
excluded therefrom. The Board Chairman, who shall
be the.Chairman of the Tribal Council, will have
the authority to open meetings of the Board to the
public. upon written or oral notice. Persons
connected with the gaming activities of the Tribe
or who are invited by the Board Chairman will be
included in the closed Board meetings as
appropriate and necessary.

(6) Interaction of Board and Tribal Council; Gaming
Commission. The Board is subject to the overall
direction and control of the Siletz Tribal
Council, pursuant to the Siletz Constitution. The

Proposed Amendment Siletz Tribal Gaming Enterprise
Charter, § 6.65 ~- Page 3 of 7


Council.

(3) Budget. The Board of Directors will adopt an
annual budget pursuant to the budget procedures of
the Tribe, which budget will be reviewed and
approved by the Tribal Council as a separate
component of the Tribal Council’s gaming budget.
In the event the Board of Directors in the future
is made up of persons other than members of the
Tribal Council, the Board’s budget will be
included within the budget of the Tribe’s Gaming
Operation.

(4) Specific Powers and Duties.

(1) The Board is delegated the authority to hire,
fire and review the performance of the
General Manager of each tribal Gaming
operation, as well as any staff which the
Board hires, retains or contracts for to
carry out its duties under this Charter.

(2) The Board will formally authorize each
Compact-approved gaming activity engaged in
by a Gaming operation, subject to
requirements of the Tribe’s Class III Gaming
Compact with the State of Oregon. Once a
gaming activity has been authorized by the
Board, the rules of each game will be
reviewed and adopted by the Commission and
the General Manager of the Gaming operation
will implement the gaming activity in his or
her discretion within the Gaming. operation.
The Board’s approval authority is limited to
general authorization for a particular gaming
activity. It will be the responsibility of
the Commission and General Managers to
develop and implement particular forms of
each gaming activity, and the Board’s
approval authority set out in this subsection
is intended to give the Commission and
General Managers broad discretion in
developing and conducting different
permutations of an authorized gaming
activity.

Proposed Amendment Siletz Tribal Gaming Enterprise
Charter, § 6.65 - Page 2 of 7


The Gaming Operation is responsible for management and
operation of Chinook Winds Casino, and for setting
working/internal policy for the Casino. The Board of Directors
is responsible for setting the Siletz Tribe’s overall gaming
policy, and for oversight of Chinook Winds Casino gaming
operations.

In addition, the Board of Directors acts as the “ambassador”
for Chinook Winds Casino, having been delegated the Tribal
Council’s gaming authority under the Gaming Enterprise Charter.
The Board is the public projection of the owner of Chinook Winds
Casino; that owner is the Siletz Tribe and the tribal membership.
The Board represents the owner in the Casino’s interaction and
interface with the public (including the gaming public), with
Casino contractors, and with governments - State, federal, local
and tribal - who have business with Chinook Winds Casino or have
reason to visit Chinook Winds Casino. This “ambassador” role
requires a visible presence at the Casino as a marketing and
promotional tool of the Gaming Operation and as a way to
emphasize and reinforce that Chinook Winds Casino is owned and
operated by the Siletz Tribe. Fulfillment of these “ambassador”
duties is a proper function for Board members to perform.

As part of this “ambassador” role, the Board may engage in
limited comping activity. This comp role and activity is
specifically addressed in Board Policy No. 1.

This policy is enacted pursuant to § 6.65(a) of the Gaming
Enterprise Charter, which authorizes the Board of Directors to
adopt any procedural rules necessary to carry out its duties
under the Charter.

Policy No. 3:
(A) Board Member Compensation and Expense Reimbursement:

(1) Compensation. Board members will be compensated for
authorized Board activities. Board members will be compensated
on the same basis that Tribal Council members may claim
compensation. All claims for compensation by Board members will
be submitted to the Siletz Tribal Gaming Enterprise Board of
Directors Executive Secretary, and will be processed in
conformance with tribal policies and procedures.

Proposed Siletz Tribal Gaming Enterprise Board
of Directors Policy # 3 - Page 2 of 4


including but not limited to negotiation of
Tribal-State Compacts under IGRA, agreements
with local jurisdiction, communication with
relevant federal officials, conduct of
litigation or legal disputes with outside
governmental authorities, and lobbying
governments on gaming matters. The Gaming
Commission has authority to communicate and
interact with governments and government
officials as necessary to carry out its
duties and to fulfill its legal
responsibilities under law.

(C) Contracts. Because the Siletz Tribe owns the
land underlying the Tribe’s Gaming
operation(s) and the buildings in which
gaming is conducted, the Tribal Council must
approve any contracts directly affecting such
land or waiving, in limited form, the
sovereign immunity of the Tribe. The Tribal
Council may delegate this approval authority,
by resolution, as appropriate, to the Board
of Directors or to the General Manager of the
Gaming Operation. From time to time a
contractor doing business with the Tribe’s
Gaming operation may insist or require that
the Tribe itself be a party to a contract or
agreement involving the Gaming Operation.

The Tribal Council may, in its sole
discretion and as necessary and appropriate
to advance the business purposes of the
Gaming operation(s), agree to make the Tribe
a party to such contracts or agreements for
such purpose.

§ 6.66 Role of the Commission.

(a) The Commission will be responsible for regulation of
the Gaming operation(s) of the Tribe, and any other gaming
activities within the jurisdiction of the Tribe. The Tribal
Council has delegated its authority to regulate tribal gaming
activities to the Commission by resolution adopting the Tribal
Gaming Ordinance and pursuant to the Tribe’s State-Tribal Compact
for the regulation of Class III Gaming with the State of Oregon.
The Commission’s regulatory authority extends over all Gaming

Proposed Amendment Siletz Tribal Gaming Enterprise
Charter, § 6.65 ~ Page 5 of 7


from tribal funds to the Gaming Operation. The
General Manager of the Casino may decide to
absorb, sponsor, subsidize or cover the costs of a
tribal, tribal governmental, or tribal
departmental activity when the General Manager, in
his or her business judgment, determines and
confirms in writing that underwriting all or a
portion of a tribal government expense constitutes
a gaming operation expense because it will
generate revenues for the Casino or advance the
business purposes of the Casino. The Commission
will review and audit General Manager decisions
made under this subsection on an annual basis or
more frequently as appropriate to determine
whether the expenses are properly charged to the
gaming operation.

Tribal Council members shall not issue or
authorize comps. Comps will not be issued to
Tribal Council members for any reason.

Comps. will be issued or authorized by the Board or
individual Board members in conformance with the
Board comp budget, which will be established
annually. Comps will not be issued or authorized
in excess of the Board comp budget unless that
budget is modified by Board resolution.

Board members will not issue comps to themselves.
Board members will not issue or authorize comps to
immediate family members (as defined by the Tribal
Ethics Code) of any Board member, to tribal
employees, to casino employees, or to other
persons who would be otherwise ineligible to
receive a comp under the Board’s comp policy.

Allowable comp items or services that Board
members may issue or authorize include food and
beverage items at any Chinook Winds dining venue.
Board members are authorized to distribute
entertainment and event tickets as a marketing or
promotional activity of the Casino as set out in
Board Policy #1, and such distributed tickets will
be charged by the Casino to the appropriate budget
category. Board members may be issued tickets,
pursuant to Board Policy No. 1, and such tickets

Proposed changes Chapter 17

Page 4 of 6


ational Sndian Gaming Commission

SETTLEMENT AGREEMENT

NOV-00-09; CFA 00-09

This agreement is entered into by and between the Confederated Tribe of Siletz Indians
of Oregon (Tribe) and the Chairman of the National Indian Gaming Commission (NIGC)
to resolve the Chairman’s concerns regarding the Tribe’s use of gaming revenues and the
Tribe’s concerns regarding the legal authority of NIGC and the actions of the Chairman
regarding the Tribe.

RECITALS

1. Under the Indian Gaming Regulatory Act (IGRA), 25 U.S.C §§ 2701 - 2721, the
NIGC is responsible for regulating Class II and certain aspects of Class III
gaming on Indian lands. The Tribe disputes whether the NIGC has legal authority
to regulate the aspects of Class III gaming on Indian lands that are the subject of
these proceedings.

2. On August 20, 1994, the Tribe adopted the Siletz Tribal Gaming Ordinance
Number 6.20, by Resolution 94-188. The Chairman of the NIGC approved the
Ordinance on December 15, 1994. Section 6.21 of the Ordinance authorizes
Class II and Class If] gaming, as defined in the IGRA and the NIGC’s
implementing regulations.

3. Under the IGRA, Respondent may conduct Class III gaming only in conformance
with a Tribal-State compact. 25 U.S.C. § 2710 (d)(1)(C). The Tribe and the State
of Oregon entered into such a tribal state compact on November 10, 1994, with
subsequent amendments.

4. Since approximately May 25, 1995, the Tribe has operated a Class II and II
gaming operation called Chinook Winds at Lincoln City, Oregon.

5. Members of the Tribal Council serve as the Board of Directors for the gaming
operation. As Board members, Tribal Council members have authority to award
Complimentary Items (also known as “‘comps”).

6. On June 14, 2000, the NIGC Chairman issued Notice of Violation 00-09, (NOV)
alleging that the Tribe’s practice of awarding comps to individual Tribal Council
members and to the Tribal Council itself and alleging that this practice constituted
a violation the IGRA.


EXHIBIT 2
Siletz Gaming Enterprise Board of Directors
Policy #1

Issuance of Comps by Board Members to Third Persons; Allocation
and Billing of Board Expenses; Auditing

Policy Statement:

Chinook Winds Casino is the gaming enterprise of the Siletz
Tribe. The gaming enterprise is an integral part of the Tribe,
and is an expression of the Siletz Tribe's sovereign authority.
In establishing the gaming enterprise and constructing Chinook
Winds Casino, tribal involvement and use and expression of tribal
symbols and history was a critical element in deciding to go
forward with the enterprise. An essential element in the success
and profitability of Chinook Winds Casino, as well as the
continued support of the tribal membership in continuing ‘the
enterprise, is the integral identification of Chinook Winds
Casino with the Siletz Tribe as an Indian owned and run
operation. Visibility of the Board of Directors in the Casino
and at Casino events, activities and functions is an essential
element in marketing Chinook Winds Casino as a business entity
and ensuring the long term success of the enterprise, and is a
business purpose of the gaming enterprise. The General Managers
of Chinook Winds Casino have requested that the Tribal Council or
Tribal Council acting in its role of the Board of Directors
participate and assist in the marketing and promotion of the
Casino.

At the same time, it is essential to continued profitability
of the gaming enterprise that expenses be kept to a minimum so
that the maximum amount of gaming revenue be made available to
the tribal membership and tribal government, as required by the
Indian Gaming Regulatory Act and the Siletz Tribe's Distribution
of Net Revenues Ordinance. Expenses incurred by the Siletz
Gaming Enterprise Board of Directors should be tied directly to
reasonable business necessity and purposes of the gaming
enterprise. Board activities and expenses shall be subject to
regular review and audit by the Siletz Tribal Gaming Commission
(“STGC”) to ensure that complimentary items (comps) issued by the
Board as well as Board expenses are incurred as legitimate gaming
operation expenses.

In furtherance of these policy declarations, the Siletz

Proposed Siletz Gaming Enterprise Board
of Directors Policy # 1 - Page 1 of 6


(d) The Commission will not conduct day-to-day management of
tribal gaming operations. The Commission will issue a separate
operating license for each gaming operation.

(e) The Commission will ensure that tribal gaming operations
are operated in compliance with all applicable laws and
regulations, and in a manner that protects the safety of
employees and patrons and protects the integrity of gaming
activities being conducted. The Commission may impose sanctions
upon gaming operations and upon the Board of Directors for non-
compliance with its rules or regulations or with governing law as
the Commission determines is appropriate and necessary to protect
the tribal assets and integrity of the gaming operation. The
Commission will not involve itself directly in personnel matters
arising with a gaming operation. The Commission is authorized to
impose sanctions that may include the revocation or suspension
of a gaming license, the imposition of civil fines and such other
action as the Tribal Gaming Commission shall deem appropriate and
necessary.

(£) The Commission shall provide an appropriate
administrative process for sanctions it imposes including the
granting, suspension or revocation of licenses.

(The remainder of § 6.66 stays unchanged)

° Proposed Amendment Siletz Tribal Gaming Enterprise
Charter, § 6.65 - Page 7 of 7


4.

marketing budget, to the Board budget if budgeted
for, or other appropriate Casino budget. The six
tickets distributed to each Board member for each
entertainment or special event for that member to
distribute to players or patrons or to other
persons to advance the business purposes of the
Casino will not be charged as a comp to the Board
or to individual Board members, but will instead
be charged as an expense to the appropriate budget
category.

Casino financial management will provide a monthly
report of Board expenses for the month and the
fiscal year to the Board of Directors at the
Board’s regular monthly meeting.

Procedure for Charging Tribal or Board Expenses.

A.

The CFO will develop a procedure to allow the
Tribe, Tribal Council or tribal departments or
programs to charge tribal government expenses
incurred at Chinook Winds. The CFO will develop a
comparable procedure for the Board and Board
members to charge for expenses incurred at the
Casino while engaged in Board activities. The
procedure is left to the discretion of the CFO,
subject to Tribal Gaming Commission oversight, to
develop and implement. Food register checks may be
signed to charge Board or Tribal expenses so long
as sufficient information, including the activity
taking place, the persons receiving the meal, the
date, and the person authorizing the charge, is
included to allow the slip to be reviewed for
monitoring and audit purposes.

The CFO of Chinook Winds will review the comp
report on a monthly basis to ensure that expenses
incurred by the Tribe or Board have not been
improperly charged to the Tribe or Board as comps,
to assure that ‘all persons authorizing such
expenses are documenting them sufficiently, and to
assure that Board does not incur expenses that are
not gaming operation expenses.

Proposed Expenses Policy

Page 3 of 3


Chinook Winds, except as set forth below, but will
instead be charged as an expense to the Tribe and
billed by Chinook Winds to the appropriate tribal
entity or department. Such expenses will be
billed in the regular billing cycle of Chinook
Winds.

Tribal officials, employees, staff and others
conducting tribal governmental business will not
be comped by Chinook Winds during the course of
their employment or while engaged in tribal
governmental activity. Tribal government expenses
shall be charged as a tribal expense and billed to
the Tribe. Tribal government expenses will be
charged as a tribal expense and billed to the
Tribe, except as set forth in paragraph (C) below.

The General Manager may, in his or her sole
discretion, decide to sponsor, subsidize, cover or
absorb the expenses for a tribal event or activity
when the General Manager determines that
underwriting all or a portion of the tribal
expenses constitutes a gaming operation expense
because it will generate increased revenues for
Chinook Winds or otherwise advance the business
purposes of the Gaming Operation. In such event
the General Manager will record his or her
decision in writing and document the reasoning for
the decision in each specific instance. Costs
incurred by Chinook Winds in providing such
financial assistance will be assigned to the
appropriate budget category.

3. _ Board of Directors and Board Member Expenses.

A.

The Board of Directors and Board members will not
be comped by Chinook-Winds while engaged in
authorized Board activities. Expenses incurred by
the Board or by Board members while engaged in
Board activities will be charged to the Board’s
budget or to another appropriate budget category.

The two tickets distributed to each Board member
for each entertainment or special event as part of
the marketing and promotional effort of Chinook
Winds will be charged to the promotional or

Proposed Expenses Policy

Page 2 of 3


Board, as an integral part of the Siletz Tribe’s
Gaming operation(s), is subject to the regulatory
authority of the Tribal Gaming Commission. The
Board has no authority over the Commission under
this Charter.

Tribal Council.

(1) Authority. The Tribal Council retains its
constitutional authority over governmental and
regulatory aspects of the Siletz Tribe’s gaming
activities. The Tribal Council has by resolution
delegated regulatory authority over the Tribe’s
Gaming Operation(s) to the Tribal Gaming
Commission, which will have exclusive authority to
regulate the Tribe’s Gaming Operation(s) and
Gaming Enterprise, including activities of the
Gaming Enterprise Board of Directors. The Tribal
Gaming Commission will report to and is subject to
the authority of the Tribal Council.

(2) Specific Powers and Duties.

(A) Gaming Commission. The Tribal Council
retains the authority to hire and fire and

review the performance of Tribal Gaming
Commissioners, provided, that the Chairman of
the Gaming Commission also has authority to
suspend or discipline Commissioners. The
Tribal Council will have no involvement with
Commission staff, in personnel matters of the
Commission (not involving Commissioners) or
in implementation, once approved, of the
Commission’s annual budget. Commission staff
(persons other than’ Gaming Commissioners) are
subject to the control and authority of the
Gaming Commission. Travel will be at the
discretion of the Commission, so long as
budgeted. The Commission will report on its
activities to the Tribal Council on a monthly
basis or more often as necessary.

(B) Inter-governmental affairs. The Tribal
Council will retain responsibility for all
governmental and political interaction
related to the Tribe’s gaming activities,

Proposed Amendment Siletz Tribal Gaming Enterprise
Charter, § 6.65 - Page 4 of 7


EXHIBIT 4

Chapter 17 as amended
Complimentary Items Issued or Authorized by

the Siletz Tribal Gaming Enterprise Board of Directors

I. Purpose.

A.

The purpose of this regulation is to establish
regulatory guidelines governing the issuance or
authorization of complimentary items by the Siletz
Tribal Gaming Enterprise Board of Directors (“Board”)
to third persons, to provide for the proper
classification by Chinook Winds Casino of complimentary
items and expenses of the gaming operation, and to
provide for review and audit of complimentary items and
Board expenses by the Siletz Tribal Gaming Commission
(“Commission”), other relevant regulatory agencies, and
independent auditors.

II. General.

A.

Chinook Winds Casino has established, as a feature of
its marketing and promotional program, the emphasis and
image of an Indian owned and operated business and in
particular the ownership of this business by the Siletz
Tribe, as a means of contributing to the success and
profitability of the Casino. The Commission finds that
this goal is reasonable and related to the business
purposes of the Tribe’s Gaming Operation.

Casino management has requested Board and Tribal
Council participation in the marketing and promotion of
Chinook Winds Casino. The Board has established a
policy of visibility related to Chinook Winds Casino by
Board members as part of this marketing strategy; the
Board and Board members act as ambassadors of the
Casino. Board members have been given limited comping
authority by Board policy, by request of Casino
management, to assist in the promotion and marketing of
the Casino. The Commission finds that this limited
comping authority is reasonable and related to the
business purposes of the Tribe’s Gaming Operation, and
does not operate to give the Board authority over the

Proposed changes Chapter 17
Page 1 of 6


EXHIBIT 5
Amendments to

Chinook Winds Policy Memorandum #20

Delete § 20.2.d. in its entirety

Amend 20.4 to provide

20.4 Board of Directors Comps:

a.

Chinook Winds will establish a separate comp category
for the Board of Directors, and the Board will be
issued separate comp books with the designation “Board
of Directors” on them. The Board comp books will limit
Board comps to food and beverage comps at Chinook Winds
dining venues, and Board comps will be issued to a
specific person, for a set amount, for a set number of
persons, or for a maximum dollar amount. The comp
books will provide for the same information to be
included that is required for customer comps under this
policy memorandum.

Chinook Winds will not issue or authorize comps to or
on behalf of the Board of Directors, and will not
charge comps issued by Casino personnel to players or
patrons to the credit of the Board or Board members.
If a specific comp slip authorization issued or
authorized by a Board member does not include
sufficient information to document the comp as provided
for under this policy memorandum, Chinook Winds
personnel will contact the Board member who

issued or authorized the comp to acquire the necessary
additional information.

Expenses incurred by the Board of Directors or Board
members while engaged in authorized Board activities
will be charged as expenses to the Board and will not
be charged as comps. Such expenses will be processed as
set out in Internal Policy Memorandum # _.

Proposed Changes to Chinook Winds Policy
Memorandum #20 - Page 1 of 2


22. The parties agree to work in good faith and in accordance with NIGC consultation
practices to resolve any future disputes concerning the Tribe’s gaming activities.

ka

Dated this_] |? ay of Maa, , 2001,
Ls

On behalf of the National Indian Gaming Commission:

ul

Montie R. Deer, Chairman

kK

va.0) - ’
Dated this 32” day of Cabaret, 2001,

On behalf of the Confederated Tribes of Siletz Indians of Oregon:

ph lois) Jab)
Delores Pigsley, Chairman” FT
Tribal Council

kK

a
Dated this 20” _ day of OM ayy 2001,

With the authority vested in me by 25 C.F.R. § 577.9, I herby accept this Settlement
Agreement as a full settlement of this action and hereby dismiss the action subject to the
terms of the settlement.

Presiding Official Bruce. Johnson



allotment of six (6) entertainment tickets under
this subsection to immediate family members (as
defined by the Tribal Council Ethics Code) or to
other persons who do not meet the standard for
issuance of tickets under this subsection (a) of
paragraph 6. In the event a Board member cannot
attend an entertainment event, the Board member
may distribute the two tickets issued to that
Board member to attend the event to another tribal
member, who shall act as the tribal host or
ambassador for that event. In any case in which a
Board member does not or is unable to distribute
or use his or her entire allotment of tickets,
remaining tickets will be returned to the Guest
Services Manager;

b. Board members will refer requests for additional
tickets to entertainment or special events held at
and sponsored by Chinook Winds Casino to the
Chinook Winds General Manager or Guest Services
Director, who shall only comp players to reward or
encourage play or otherwise advance the business
purposes of the Casino;

c. Board members may be invited by the Chinook Winds
Casino General Manager or Guest Services Director
from time-to-time to attend entertainment events
sponsored by Chinook Winds Casino and held inside
or outside the Casino, or to events in which
Chinook Winds has been invited by others to
participate. It is important for the Board to
have a presence at such events in its
ambassadorial role as a marketing tool of the
Casino; the Board’s attendance at such events will
be subject to the discretion of Chinook Winds
Casino management when the General Manager
determines that the Board members’ attendance will
further the business purposes of the Casino. In
such case, the cost of the Board members’
attendance at such event and any associated
expenses will be charged as a promotional or
marketing expense of the Casino or charged to
another appropriate budget category.

7. Board members and the Board of Directors may incur
expenses at Chinook Winds Casino while engaged in Board
activities authorized under Board Policy No. 3. Such expenses
will be charged by the Casino to the Board of Directors’ budget,

Proposed Siletz Gaming Enterprise Board
of Directors Policy # 1 - Page 4 of 6


authority to decide whether, in a specific instance, it will
advance the business purposes of the Casino to subsidize,
sponsor, pay for, or absorb the costs of a tribal event or
activity taking place at Chinook Winds Casino or elsewhere. The
Board of Directors will have no authority to make such decisions
and will not involve itself in any manner with such decisions.
Such decisions will be judged by whether they will generate
increased revenues at the Casino or will serve to market, promote
or otherwise advance the business purposes of the Casino. In each
case where the General Manager makes the discretionary decision
to underwrite a tribal event, the General Manager will document
his or her decision in writing and the reasoning for that
decision. The expenses in each case will be charged to the
appropriate Casino budget category, but in no event will be
charged to the Board of Directors. The Chief Financial Officer
will prepare an annual report of such expenditures to the Board,
and will send a copy of such report to the Siletz Tribal Gaming
Commission, which will review and audit such expenditures under
its own authority and regulations.

11. Comps and expenses that are not adequately documented
shall become the responsibility of the person who has incurred
the expense or has authorized the issuance of the comp.

Proposed Siletz Gaming Enterprise Board
of Directors Policy # 1 - Page 6 of 6


15.

16.

17.

18.

20.

21.

i

HW

H

ui

M

Commission may revise these procedures within 45 days of the date this Settlement
Agreement is signed and may submit them to the Chairman for his approval.

The Gaming Operation will amend its internal comp policy that governs how the
Casino will document comps. Such policy is attached hereto as Exhibit #5.

The Gaming Operation will formalize a billing policy requiring the Casino to account
for all expenses incurred by the Board and the tribal government. Such policy is
attached hereto as Exhibit #6.

The Tribal Gaming Commission shall monitor compliance with this agreement and
cooperate fully with the NIGC’s efforts to monitor gaming pursuant to the IGRA and
its implementing regulations. The Board of Directors, Gaming Operation and the
tribal government shall fully comply with the monitoring efforts pursuant to the
IGRA and its implementing regulations.

In light of the Tribal policies set forth in Exhibits 1-6, the Tribal Gaming
Commission will assume the responsibility for examining the prior use of comps by
Tribal Council members and for determining whether any additional action is
necessary to ensure the integrity of the tribal gaming operation.

The terms of this Settlement Agreement will be posted on the NIGC’s website, at a
location that will be linked to the original NOV and CFA.

The parties agree that this settlement will resolve all outstanding issues as to NOV-0-
09 and CFA-00-09, that each will waive its right to take any further procedural or
other action by the full Commission in this action. Execution of this Settlement
Agreement therefore constitutes full and final settlement of this action.

The parties hereby waive any right to challenge or contest the validity of the terms
entered into in accordance with the Settlement Agreement.


Proposed chi
Page 5 of 6

will be charged by the Casino to the appropriate
Casino budget category. Meal comps issued or
authorized by Board members will set out either a
specific dollar amount, set a maximum dollar
amount, or be for a meal for a specific number of
people at a specific dining venue. Meals taken by
Board members, who are attending Board functions,
will be charged by the Gaming Operation as a Board
expense and not as a comp.

8. All comps issued or authorized by the Board or
Board members will include sufficient documentary
information for the Commission to determine
whether a comp was validly issued or authorized in
conformance with this regulation.

9. All expenses charged by the Board or Board members
will include sufficient documentary information
for the Commission to determine that the expense
was incurred in conjunction with an authorized
Board activity or function.

Chinook Winds accounting department will set up a
separate account which will document and record any and
all comps issued or authorized by the Board or
individual Board members. Chinook Winds Casino will
prepare a monthly report on Board comps, which will be
submitted to the Board, with a copy to the Commission,
by the date of the regular monthly Board meeting.

1. The Commission will review each monthly Board comp
. report for compliance within thirty (30) days of
receipt.

2. The Commission will submit a report based upon its
review of this monthly report to the Board of
Directors and to the Tribal Council, identifying
any questioned comps and requesting that such
comps be corrected or that other remedial action
be taken.

3. Sections V through XI below outline how any
identified variances which are not immediately
corrected, or which reoccur on a continuing basis,
will be brought to the attention of the Board of

anges Chapter 17


10.

On August 9, 2000, Chairman Deer served a Notice of Proposed Civil Fine
Assessment (CFA) on the Tribe.

On August 22, 2000, the Tribe appealed the NOV and the Proposed CFA, and denied
that the Tribe’s comping activities violated the IGRA, the Tribe’s Compact, or tribal
law.

On September 28, 2000, the Office of Hearings and Appeals gave notice that the
matter had been assigned to Presiding Official Bruce A. Johnson.

Desiring to preserve the benefits of their longstanding relationship, representatives
of the parties to this Agreement explored amicable methods of resolving the above

referenced concerns.

AGREEMENT

ACCORDINGLY, the parties agree as follow:

11.

12.

13.

14.

The Tribe agrees that it will respond to accounting issues identified in the NOV and
CFA and further formalize the segregation of functions between the Tribal Gaming
Commission, the Board of Directors, and the Tribal Council. The Tribe agrees that
policies and procedures will be formalized to ensure that future compliance by the
Tribe will be monitored and enforced. The Tribe will amend its policy that clarifies
and refines the division of responsibility and authority between the various tribal
entities. The policy will formalize the Tribal Gaming Commission’s explicit
authority to conduct audits of Board activities. Such policy is attached hereto as
Exhibit #1.

The Tribe will clarify the comp policy and procedures for Board members to ensure
that comps and expenses are properly categorized and treated internally by the Board
and the Casino. The policy will formalize the Tribal Gaming Commission’s explicit
authority to audit Board comps and expenses. Such policy is attached hereto as
Exhibit #2.

The Tribe will formalize the functions and responsibilities of the Board of Directors,
including a policy by which Board expenses will be processed and billed. Such
policy is attached hereto as Exhibit #3.

The Tribal Gaming Commission will clarify the procedure by which it will monitor
and audit Board expenses and comps, including instituting reporting requirements
and enforcing sanctions for failure to follow such policies. Such policy is attached
hereto as Exhibit #4. Notwithstanding this section, however, the Tribal Gaming


d. Chinook Winds will prepare a monthly report detailing
all comps issued or authorized by the Board or
individual Board members. This report will be
submitted to the Board each month at its regular
monthly meeting. A copy of the Board comp report will
be sent each month to the Tribal Gaming Commission, or
otherwise as the Commission requests. The monthly
report will track Board comp authorizations against the
annual Board budget for comps.

e. Board members will be distributed eight (8) tickets to
each entertainment event as part of the marketing and
promotional efforts of the Casino. Board members will
use two tickets so that they can personally attend an
event and distribute six tickets to players or patrons
or to other persons who will advance the business
purposes of the Casino. The value of these tickets
will be charged to the appropriate budget category, and
will not be charged as a comp to the Board or to Board
members. Tickets not used or distributed by a Board
member as set out in Board of Directors Policy #1 will
be returned to the Chinook Winds Guest Services
Manager.

f. Failure to follow this policy will be reported to the
Tribal Gaming Commission.

Proposed Changes to Chinook Winds Policy
Memorandum #20 - Page 2 of 2


Gaming Enterprise Board of Directors adopts the following policy
with regard to issuing comps and reimbursement of expenses in
furtherance of Board activities related to Chinook Winds Casino.

Policy #1:

1. Siletz Gaming Enterprise Board of Directors ("Board")
shall be issued comp books by the CFO of Chinook Winds Casino.
The CFO shall print separate comp books for the Board and such
comp books shall have the phrase "Board of Directors Comp"
printed at the top of each book page. Board members shall issue
comps in accordance with general internal comp procedures adopted
by casino management (Chinook Winds Policy # 20), and in
accordance with this policy.

Comp books issued to Board members shall be turned into the
CFO upon request for audit purposes, to issue new comp books, or
for other business purposes.

2. The Board will, in its authority to review and approve
the annual budget for Chinook Winds Casino, develop and approve
an annual Board budget for comps for the coming calendar year.
This budget will be listed separately from the Casino
administration comp budget, and will be tracked separately. The
Board comp budget will be displayed in the appropriate Casino
budget category. The Board will establish on an annual basis a
maximum amount per comp issued by the Board and a maximum comp
limit for that fiscal year.

3. The CFO of Chinook Winds Casino will prepare a monthly
comp report for the Board, listing all comps issued or authorized
by Board members or the Board of Directors, or charged to the
Board or Board members in the previous month. This monthly comp
report will be submitted to the Board of Directors each month at
its regular meeting, and a copy will be sent at the same time to
the Siletz Tribal Gaming Commission.

4. Board members are authorized to issue comps only for
meals at any Chinook Winds dining venue.

Each authorization for a comp issued by a Board member will
include the name of the issuing Board member, the person to whom
the comp is being issued, the date, the amount, the reason why
the comp is being issued, and the signature of the Board member
issuing the comp.

5. Meal comps may be used only as follows:

Proposed Siletz Gaming Enterprise Board
of Directors Policy # 1 - Page 2 of 6


by notifying the Tribal Council Executive Secretary who is
responsible for administering the Tribal Council gaming budget.
In no event will such expenses be charged by the Casino as a comp
to the Board of Directors or to individual Board members. The
CFO of Chinook Winds Casino will develop an appropriate procedure
by which Board members and the Board may charge Board expenses
incurred at Chinook Winds Casino to the Board of Directors’
budget. The CFO will prepare a monthly report for the Board
detailing the Board budget and Board expenses charged by the
Casino in the previous month to that budget. This report will be
sent to the Board of Directors Executive Secretary on a monthly
basis and submitted to the Board at their regular monthly
meeting.

8. The Siletz Tribal Gaming Commission (STGC) will audit
all Board comps issued or authorized by the Board pursuant to
this policy on a periodic basis, not less than once per year.

The CFO will send a copy of his or her monthly report of Board
comps to the STGC, and will send such other comp information to
the STGC as requested. The STGC’s audit of Board comps will be
conclusive with regard to the Board as to the validity of any
comp authorized by the Board or Board members, provided, that the
Board and any individual Board member may exercise any appeal
rights they may have under STGC regulations to contest the
disallowance of a specific comp. The STGC will also ensure in
its annual engagement letter for the independent audit of Chinook
Winds Casino that the auditor is asked to audit Board comps
issued during the previous calendar year. The STGC will review
and audit Board expenses under its regular procedures, in its
sole discretion and authority.

9. Comps will not be issued or authorized by the Board or
by Chinook Winds Casino to the Siletz Tribal Council or the Tribe
for governmental expenses incurred by the Tribal Council, the
Tribe or tribal departments at Chinook Winds Casino. Such
expenses are an expense of the Tribe and not of the Siletz
Tribe’s Gaming Operation, and will be billed by the Casino to the
Tribe as an expense. Except as set forth below in paragraph 10,
such expenses will not be assisted by the Casino. Such
governmental expenses will be billed by the Casino to the
appropriate tribal entity or department on a monthly basis. The
Siletz Tribe will reimburse Chinook Winds Casino for all expenses
incurred by the Siletz Tribal Council, Tribe or tribal
departments at the Casino after receiving a billing statement
detailing such expenses from the Casino.

10. The General Manager of Chinook Winds Casino, subject to

review by the Tribal Gaming Commission, will have the sole

Proposed Siletz Gaming Enterprise Board
of Directors Policy #1 - Page 5 of 6