Commission and approved by the Business
Committee.

Rules for each new game must be included
in the Standard Operational Procedures
Manual.

The Gaming Business Plan must be amended
as required.

The gaming budget for the fiscal year
shall be amended as necessitated by the
new game.

If the new game is defined as Class III,
such games may not be commenced unless
and until the Compact has been amended to
provide therefore.

Standard of Gaming Procedure

1.

4.

Standard Operational Procedures Manual
a. This Manual shall specify detailed
rules and procedures for the conduct
of each game. The Manual shall also
include necessary procedures for
security, reporting and any other
related areas.
All games shall be separately operated
with rules for each set forth in the
Standard Operational Procedures Manual.
The Standard Operational Procedures shall
be drafted by the Gaming Manager or
responsible entity or department and
reviewed by the Gaming Commission and
approved by the Business Committee.
Revision of rules for any reason shall
conform to the same process.

Prohibitions:

1.

Gaming may not be conducted by any Indian
or Oneida Tribal member, not employed by
the Oneida Tribe of Indians of Wisconsin
to specifically conduct gaming on the
Oneida Indian Reservation

No person who has been convicted of a
felony or a violation of any provision of
the Personnel Policies and Procedures
Manual resulting in dismissal or any
misdemeanor crime of fraud or theft of
any kind may be employed in the conduct
of any game defined in this Ordinance
unless such person has been formally
pardoned by the Oneida Business Committee
upon the recommendation of the Gaming
Commission. Provided, however, that
V.A.4. requirements of this Ordinance are
adhered to. .
Prohibited Prizes: There shall be no

14.


Business Committee. Vacancies shall be filled
by appointment by the Oneida Business
Committee until the next election.

1. Purpose

The purpose of the Commission is to

provide the basis for regulation and

operation of gaming pursuant to this

Ordinance.

2. Qualifications for Election

a. Must be an enrolled tribal member,
21 years of age or older.

b. Must meet one (1) of the following
criteria: Experience of at least
one (1) year in;

1) Marketing
2) Accounting

3) Business Management

4) Previous Tribal Board,
Committee, or Commission,

5) Gaming,

6) Law Enforcement and/or

7) Formal training in any of the
above areas

c. No individual shall be eligible for

election to, or to continue services

on, the Commission, who:

1) Has been convicted of a felony
or crime of fraud as defined in
this Ordinance or gaming
offense unless pardoned by the
Business Committee

2) Has any financial interest in,
or management responsibility
for any gaming activity that
would be in direct competition
with gaming authorized by this
Ordinance.

3) Has any Conflict of Interest as
defined in this Ordinance and
the Tribal policy defining
Conflicts of Interest.

da. Compensation, if any, shall be paid
for attendance at each meeting and
consistent with common tribal
practice and policy as set forth in
the Standard Operational Procedures
by the Commission and approved by

the Business Committee.

B. Election of Commission

1. All candidates shall submit to a thorough
background investigation initiated by the
Gaming Security Director or Oneida Public

8.


ARTICLE XII.

ARTICLE XIII.

ARTICLE XIV.

1. Special audits as set forth in the
Standard Operational Procedures Manual,
including surprise cash counts and other
unannounced verification procedures may
be authorized at any time by:

a. Oneida General Tribal Council, or
b. Oneida Business Committee, or

c. Oneida Gaming Commission, or

da. Audit Committee.

ALLOCATION OF GAMING FUNDS

The Oneida Business Committee may directly
appropriate gaming revenues for the purposes set
out in Article IV, Section 1 (F) of the Oneida
Tribal constitution.

AGREEMENTS

Pursuant to this Ordinance, the Oneida Tribe may
enter into agreements or compacts to further its
gaming interests with any of the following:

A. Other tribes, this shall mean cooperative
gaming with other tribe on their reservations
or trust lands, or consultation on gaming
issues.

B. State and local governments, this shall mean
Tribal-State Compacts pursuant to this Indian
Gaming Regulatory Act, (P.L. 100-497).

Cc. Other private or corporate entities, this
shall mean any private company, business or
group and such agreements may be subject to
provisions of the Indian Gaming Regulatory
Act.

AMENDMENTS

This Ordinance may be revised only by the Oneida
Business Committee and reviewed by the General
Tribal Council pursuant to procedures duly enacted
for the purpose of enacting, revising, amending, or
revocation of the laws of the Oneida Tribe. Such
revisions and amendments shall be based upon Gaming
Commission recommendations.

Adopted by Oneida General Tribal Council July 6, 1992 by Resolution

18.


Oneida Tribe of Indians of Wisconsin
Post Office Box 365

Phone: 869-2214 Oneida, WI 54155

Onewas punging several
nunores Bags of corn 10

veasmngion § starving army, So rakons ans the Sunn
at aney Forge me
Is haa consistently

GENERAL TRIBAL COUNCIL
RESOLUTION # GTC-_7-6-92-B_

WHEREAS, the Oneida General Tribal Council is the duly recognized governing body
of the Oneida Tribe of Indians of Wisconsin,

WHEREAS, the Oneida Business Committee may be delegated duties and
responsibilities by the Oneida General Tribal Council and is at all
times subject to the review powers of the Oneida General Tribal Council,
and

WHEREAS, the General Tribal Council has been delegated the authority of Article
Iv, Section I of the Oneida Tribal Constitution, and

WHEREAS, the Oneida Business Committee has determined that due to expansion of
the Oneida Gaming enterprise, also known as the First American Games, to
include games denominated as Class III games under the Indian Gaming
Regulatory Act of 1988 (P.L. 100-4097), which federal law also provided
for Compacts between Tribal and State governments governing the
regulation of Class III games on reservations, and

WHEREAS, the Oneida Tribe and the State of Wisconsin entered into a Class III
Gaming Compact on November 7, 1991 which was approved by the Secretary
of the Interior, Manual Lujan, on January 24, 1992. Said Compact
addresses the conduct of the game known as Blackjack and gaming machines
with video, or electronic displays and sets forth a system of joint

regulation of these Class III games by the Tribe and the State, and

WHEREAS, the Oneida Gaming Ordinance adopted by the Oneida Business Committee on
April 21, 1989 has been revised by subsequent directives of the Oneida
General Tribal Council which includes amending the composition of the
Oneida Gaming Commission and the manner of their selection, as well as 8
recommendations of the Bingo Investigation Committee, and

WHEREAS, these revisions and cthers have been incorporated into the proposed
Comprehensive Oneida Gaming Ordinance, and

WHEREAS, more than three public hearings have been held to allow the general
membership and elected entities of the Onedia Tribe to comment and offer
proposed revisions to this Ordinance, and

NOW THEREFORE BE IT RESOLVED: that the attached Comprehenisve Oneida Gaming
Ordinance is hereby approved by the Oneida General Tribal Council for
adoption by the Oneida Business Committee. It is specifically intended


prize consisting of alcoholic or
fermented malt beverage or an interest in
real estate or securities.
Alcohol and Drugs: No alcoholic
beverages and/or illegal drugs shall be
allowed on tribal premises where gaming
is conducted. Anyone caught possessing
and/or using alcoholic beverages or
illegal drugs shall be removed from the
premises and barred from participating in
any gaming activity on tribal premises.
Violators may be subject to criminal
prosecution.
Sale of Supplies and Refreshments:
a. No person shall sell any merchandise
on the premises where bingo is being
conducted unless authorized by the

bingo management. This does not
include the sale of food or
refreshments.

b. Customers are prohibited fron

bringing food and refreshments onto

the premises where bingo is

conducted other than what is
purchased on the premises.

WHO MAY NOT PLAY

a. No member of the Oneida Business

Committee, Oneida Gaming Commission,

Gaming Security and surveillance

personnel, Machine Technicians or

Repair persons, Accounting

Personnel, Key Personnel or Primary

Gaming Management employees or

Professional Advisors or consultants

may play.

b. Except as provided elsewhere in this

Ordinance, any person 18 years of

age or over may participate as a

player in games conducted by the

Oneida Tribe.

c. Age Limitations:

1) No person under the age of 18
shall play any game authorized
by this Ordinance.

2) No person under the age of 18
shall be present on or in
tribal premises where games are
conducted, unless otherwise
authorized.

da. No Tribal employee may participate
or be a patron alone or in
partnership with any other person or

15.


ARTICLE VIII.

ARTICLE Ix.

ARTICLE X.

ARTICLE XI.

INVESTIGATIONS

A.

B.

General

1. All investigations shall be coordinated
pursuant to procedures set forth in the
Standard Operational Procedures Manual.

All management personnel shall be trained in

appropriate investigative processes.

ENFORCEMENT AND PENALTIES

A.

No Indian shall conduct gaming operations

within the borders of the Oneida Indian

Reservation except as prescribed above.

Violations/Prosecutions:

1. Violators of these rules may be subject
to disciplinary action and civil/criminal
prosecutions where circumstances so

indicate.
Remedies:
1. Any person violating any provision of

this Ordinance may be subject to:
a. Forfeit not more than $2,000.00 per
each violation to the Oneida Tribe.

b. Make restitution for all losses as
may be indicated.
c. The Oneida General Tribal Council or

other authorized body shall conduct
a hearing to enforce this provision
consistent with due process and
equal protection to tribal law.

da. The Oneida Business Committee shall
direct and authorize commencement of
an action in any court of competent
jurisdiction to recover losses,
restitution and forfeitures
previously adjudged by the Oneida
Business Committee or appropriate
tribal forum, and invoke other
appropriate tribal remedies.

REPORTS AND PROCEDURES FOR RECEIPT AND HOLDING OF
MONEY

A.

A monthly financial report shall be submitted
to the Oneida Gaming Commission and the Oneida
Business Committee.

AUDITS

A.

Annual audits shall be conducted pursuant to
the financial policies of the Oneida Tribe.

17.


supervision as set forth in Article VI,
below and the Standard Operational

Procedures.

a. Personnel policies shall conform to
Tribal Personnel Policies and
Procedures unless otherwise
required.

b. All such policies shall be reviewed

by the Gaming Commission and

approved by the Business Committee.

4. The Gaming Manager shall supervise the

receipt and deposit of monies realized as

revenues from gaming operations in the

Oneida Gaming account as directed at

banks designated by the Oneida Business
Committee.

ARTICLE VI. GAMING SECURITY; POWERS, DUTIES AND LIMITATIONS

A.

A Director of Security will supervise a
separate arm of the Public Safety Department
which shall have jurisdiction over all
security activities including all surveillance
equipment. This person shall have a
background as a police officer, federal
officer, criminal investigator, and/or gaming
security specialist. As a condition of
employment, the candidate shall receive
training in all of the above areas in which he
is not fully qualified at the time of
employment.

The Director of Security shall report directly
to the Oneida Gaming Commission on a monthly
basis or as required. The Director of
Security shall communicate with the Chief of
Public Safety on daily matters, if any, for
security, and with the Gaming Manager on daily
requirements, if any, for operational
purposes.

The Director of Security shall maintain
written policies and procedures for the
conduct of security operations. These
policies and procedures shall be reviewed by
the Chief of Public Safety, the Oneida Gaming
Commission, and Gaming Manager for approval by
the Oneida Business Committee.

The Director of Security shall conduct or
cause to be conducted such _ background
investigations of contractors and vendors, as
may be necessary prior to the accomplishment
of any contracts and agreements by Gaming
Management. — Procedures governing for

12.


26.

27.

28.

29.

30.

31.

32.

33.

which additional expenditures will be
required which have not been previously
provided for in the Business Plan or
Approved Budget.

"ONEIDA BUSINESS COMMITTEE" means the
elected representatives of the Oneida
General Tribal Council, composed of nine
(9) Oneida Tribal members who perform
duties authorized by the Oneida General
Tribal Council.

"ONEIDA GENERAL TRIBAL COUNCIL" means the
governing body of the Oneida Tribe of
Indians of Wisconsin composed of all the
qualified voters of the Oneida Tribe of
Indians of Wisconsin as determined by
Article III, Section 2 of the Oneida
Tribal Constitution.

"ON-LINE LOTTERY" means Point of Sale,
the online system is a series of computer
terminals which are similar in appearance
to cash registers and are geographically
dispersed. The terminals are linked up
by dedicated phonelines to a central
computer. A player picks six numbers out
of a specified array of numbers, the
agent enters the digits at their terminal
and that play is recorded at the central
site via a dedicated phone line. A
player may select to have the computer
randomly select the numbers.

"OVERSEE" means to review, investigate,
hold hearings, find facts, report, review
and recommend amendments to the Gaming
Ordinance, rules and regulations, the
annual gaming budget, recommendation on
prosecution if necessary.

"PARI-MUTUEL" means of system of betting
on races in which the winners divide the
total amount bet after deducting
management expenses .in proportion to the
sums they have wagered individually.

"PLAN OF OPERATIONS" means of
comprehensive document of operating
authorities including all codes,

resolutions, policies, regulations, anda
summary of operating procedures.

"PREMISES" means any building, room,
hall, enclosure, tent, or outdoor area in
which gaming is being conducted.

"RAFFLES" refers to games that result in
random winners, whereby each person
purchasing a raffle ticket is afforded an

4.


COMPREHENSIVE ONEIDA GAMING ORDINANCE

PREAMBLE

It is the intent of the Ordinance to clearly set forth the
laws and requirements of promulgation of regulations of the Oneida
Tribe regarding all gaming conducted on the Oneida Indian
Reservation. It is intended to govern the gaming activities of all
persons, employees, consultants, and vendors as well as the Oneida
Gaming Commission. It is further intended that all internal
departments, enterprises and officials and employees of the Oneida
Tribe shall work cooperatively to advance the best interests of the
Oneida Tribe in protecting its gaming resources as well as its
patrons.

ARTICLE I. A. TITLE
This Ordinance shall be known as_ the
COMPREHENSIVE ONEIDA GAMING ORDINANCE
B. DEFINITIONS
1. “BACKGROUND CHECK" means a standard and
thorough investigation conducted by
Oneida Gaming Security, Oneida Public
Safety or other authorized delegate of
the Oneida Tribe pursuant to applicable
federal laws or regulations. Said checks
may be in cooperation with federal, state
or other tribal law enforcement agencies.
2. "BINGO" means a game of chance in which
75 numbered objects are available for
random selection and in which each player
participates by means of cards sold,
rented or used only the time and place of
game. Each card contains five rows of
five spaces each, each space printed with
a number from 1 to 75, except the central
space which is marked "FREE". Winners
are determined and prizes awarded on the
basis of possessing a bingo card on which
some combination of numbers are printed
and conform to the numbered objects
selected at random based on a
predetermined winning arrangement.
Winners are determined by covering
publicly announced squares, by card to
reveal a prize won, or by drawing a name
or number from a _ container. This
includes all bingo games conducted
pursuant to the Ordinance whether
transmitted by cable, satellite or any
other manner.
3. "BINGO OCCASION" means a single gathering
or session at which a series of
successive bingo games are played.


RESOLUTION GTC 7-6-92-»
Page 2

that this -ordinance conforms to the requirements of the Oneida
Constitution, the Indian Gaming Regulatory Act of 1988, the Oneida Tribe
of Wisconsin Class III Gaming Compact, regulations of the Federal Indian
Gaming Commission as well as directives of the Oneida General Tribal
Council. It is also intended that specific regulations as required by
Oneida Administrative Procedure Act authorized by and for the purpose of
implementing this Ordinance be promulgated, published and maintained in
a Oneida Gaming Standard Operating Procedures Manual.

BE IT FURTHER RESOLVED, that this Ordinance be published in the Kalihwisaks and
copies available to the general membership and the public at their
request. This ordinance shall also be provided to all Managers and
Directors who shall insure that all employees are familiar with its
requirements, and

BE IT FINALLY RESOLVED, this Ordinance and its implementing regulations shall be
presented to the U. S. Department of the Interior, the Federal Indian
Gaming Commission, the State of Wisconsin.

I, the undersigned, as Secretary of the Oneida Business Committee, hereby certify
that the Oneida General Tribal Council in session with a quorum of 128 members
present at a meeting duly called, noticed, and held on the 6TH day of JULY, 1992;
that the foregoing resolution was duly adopted at such meeting by a unanimous
vote of those present and that said resolution has not been rescinded or amended

CZ pmelia foclies, Tribai Secretary
Cee Business Committee



ARTICLE VII.

obtaining, recording and reporting background
investigations shall be promulgated by the
Director of Security, approved by the Oneida
Gaming Commission and set forth in the
Standard Operational Procedures.

E. Reports of incidents shall be the
responsibility of the Director of Security.
Procedures governing the use or release of
reports or investigations shall be promulgated
by the Director of Security and approved by
the Gaming Commission and included in the
Standard Operational Procedures Manual.

GAMES

A. All games of chance shall be designated as
class II or class III games and consistent
with agreements or compacts executed by the
Oneida Tribe or the Indian Gaming Regulatory
Act or other federal law determined by the
federal courts.

B. The following games are hereby authorized by
this Ordinance:

1. Bingo

2. Raffles

3. Lottery

4. Machines

5. Table Games
a. Black Jack

6. Parimutuel wagering

c. The following games shall be authorized and
designated as class III games if permitted by
federal and state laws:

1. Table Games
a. Craps
b. Roulette

2. Card Games
a. Poker style games
b. Other games authorized and defined

by the Gaming Commission as set
forth in the Standard Operational
Procedures.

3. Electronic games of chance with video
facsimiles or mechanical displays.

4. Pull-tab or break open tickets, if not
Played at the same location where bingo
is played.

D. New Games: New games shall not be commenced

unless and until such game has specifically

met the following criteria:

1. New games must be proposed by the Gaming
Manager, reviewed by the Oneida Gaming

13.


15.

16.

17.

18.

19.

20.

21.

22.

23.

24.

25.

or provided for in the annual Business
Plan.

"GAMING MANAGEMENT" means the Gaming
Manager, Directors of individual games,
Supervisors and all personnel involved in
the processing of Lotto tickets for sale
or selection of winners.

"GAMING RETAIL LICENSE" means the license
the Commission shall issue to each
authorized retailer. Each retailer shall
conspicuously display the certificate of
authority, on the premises where lottery
tickets are sold, for public inspection.
"GROSS RECEIPTS" means total receipts
received from the conduct of each gaming
operation.

“INCENTIVE SYSTEM" means a  reward/
recognition system that will encourage
good employee morale in the gaming area.
"INCIDENT" means an accident or event
involving any person on the premises
where gaming is conducted which results
in injuries, damages to property or any
unusual occurrence in the conduct of any
game or machine.

"INSTANT TICKETS" means factory covered
tickets which are purchased and opened by
customers revealing predetermined winning
arrangement.

"KEY PERSONNEL" means a primary
management official, or any person who is
a custodian of cash or other things of
value or any person in a_ supervisory
position.

"LOTTERY" means a game in which numbers
are randomly selected for a predesignated
total in combinations determined by the
Oneida Tribe as winners. This shall
include scratch off tickets.

"LOTTERY GAME RETAILER" means a person
and/or business with whom the Gaming
Commission has contracted for the purpose
of selling Lotto tickets to the public.
"MACHINES" means all devices, mechanical
or electronic, used by the Oneida Gaming
enterprise to facilitate gaming
operations. This includes Class III
games of chance defined in the Oneida/
Wisconsin Class III Gaming Compact.

"NEW GAME" means any game not
specifically set forth in Article V, or
any variation of an existing game for

3.


OMMISSION -

Deborah Doxtator, Chairperson
Oneida Tribe of Indians of Wisconsin
P.O. Box 365

Oneida, Wisconsin 54155

Dear Chairperson Doxtator:

This letter responds to your request to review and approve the
tribal gaming ordinance adopted by the Oneida Tribe of Indians of
Wisconsin (the Tribe) on July 6, 1992 and amended by resolution
dated April 27,.1994. This letter constitutes such approval
under the Indian Gaming Regulatory Act (IGRA).

Under the IGRA and the regulations of the National Indian Gaming
Commission (NIGC), the Chairman is directed to review ordinances
with respect to the requirements of the IGRA and the implementing
regulations. Thus, the scope of the Chairman's review and
approval is limited to the requirements of the IGRA and the NIGC
regulations. Provisions other than those required under the IGRA
or the NIGC regulations that may be included in a tribal
ordinance are not subject to review and approval. Also, such
approval does not constitute approval of specific games.

It is important to note that the gaming ordinance is approved for
gaming only on Indian lands as defined in the IGRA.

With the Chairman's approval of the Tribe's gaming ordinance, the
Tribe is now required to conduct background investigations on its
key employees and primary management officials. The NIGC expects
to receive a completed application for each key employee and.
primary management official pursuant to 25 C.F.R. § 556.5(a) and
an investigative report on each background investigation before
issuing a license to a key employee or primary management
official pursuant to 25 C.F.R. § 556.5(b).

Thank you for submitting the ordinance of the Oneida Tribe of
Indians of Wisconsin for review and approval. The NIGC staff and

I look forward to working with you and the Tribe in implementing
the IGRA.

Sincerely yours,

Anthony J. Hope

Anthony J. Hope
Chairman

1850 M STREET.NW..SUITE 250 WASHINGTON. DC 20036 TEL 202-632-7003 FAX 202-632-7066



ARTICLE II.

performance criteria.

39. "SECURITY" means the protection of the
equipment, money, anything of value and
the premises and the occupants thereof
for all gaming activities, and personnel
policies and procedures used to assert
such protection.

40. "SPECIAL BINGO CARD" means a disposable,
specially marked bingo card which affords
a person the opportunity to participate
in a special bingo game to be played with
special bingo cards for special prizes.

41. "SPECIAL BINGO GAME" means any bingo game
which is not a regular bingo game and
which is played with special bingo cards
for special prizes.

42. "STANDARD OPERATIONAL PROCEDURES" means
rules and processes set forth separately
but deriving from authority stated in
this Ordinance.

43. "TRIBAL LAND" means all lands within the
exterior boundaries of the Oneida Indian
reservation as defined by the 1838
Treaty, or otherwise possessed by the
Oneida Tribe.

GENERAL PRINCIPLES

A.

The purpose of this Ordinance is to regulate
the conduct of all gaming operations of the

Oneida Tribe of Indians of Wisconsin. All
gaming operations of the Oneida Tribe shall be
conducted pursuant to this Ordinance. All

gaming operations shall be conducted in
accordance with Article V below and duly
authorized regulations set forth in a Standard
Operational Procedures Manual.

This Ordinance shall supersede all previous
Ordinance, Resolutions and any and all
Memorandum of Agreements or other tribal law
governing the conduct of gaming by the Oneida
Tribe. All provisions are effective upon
enactment by the Oneida Business Committee.
Licenses shall be required of the Gaming
Manager, Key Personnel, vendors and/or
contractors in accordance with the duly
enacted license policy and procedure.

Gaming addiction disorders are recognized as a
potential hazard to a successful gambling
operation. There will be provided referrals
and educational services addressing this
issue. Annual reporting of the incidence and

6.


34.

35.

36.

37.

38.

equal opportunity to win a prize whether

cash or merchandise.

"REGULAR BINGO CARD" means a card issued

to a person upon payment of the admission

fee which affords a person the
opportunity to participate in all regular
bingo games played at a bingo occasion.

"REGULAR BINGO GAME" means a bingo game

in which a person, upon payment of the

admission, is issued a regular bingo card
and may purchase or rent extra regular
cards.

"REMOVAL FOR CAUSE" means suspension or

terminating the employment of any person

connected with any aspect of the Oneida
gaming operations for:

a. Behavior or conduct which may in any
was affect local perceptions of the
Oneida Gaming Enterprises in a
negative manner, causing suspicion
to be raised as to the actual
conduct of said games, and which may
lead to an inordinate decline in
revenues actually received from the
gaming operations.

1) Such behavior shall include
theft, embezzlement, conversion
and/or fraud.

2) Such behavior shall include
under the influence of drugs or
alcohol.

b. Direct noncompliance with any rule
or regulation pertaining to gaming
control or causing another either
directly or indirectly to disregard
such rules and regulations.

c. Violation of any rule or policy of
the Oneida Tribe as set forth in the
Oneida Personnel Policies and
Procedures.

da. All procedures under this provision
shall be as provided for in the
Tribe’s Personnel Policies and
Procedures.

"REVENUES" means the gross receipts
collected from one or more gaming
occasions, less sums necessarily and
actually expended for conducting said
games, supplies, equipment, prizes or
utilities.

"REVIEW PROCESS" means a process whereby

gaming management is evaluated on

5.


10.

11.

12.

13.

14.

"BINGO SUPPLIES & EQUIPMENT" means all
cards, boards, sheets, markers, pads or
other supplies, devices or equipment
designed for use in the play of bingo.
"BUSINESS PLAN" means a plan extended
over a period of years to be determined
by the Oneida Business Committee or
Oneida Gaming Commission with narratives
and financial projections including
operating budgets which serve as a
planning guideline for all gaming
operations. The plan includes sections
devoted to management, organization,
legal background, operations, market,
financial analysis, and contingency
planning.

"CONDUCT OF GAMES" means all games of
chance conducted pursuant to this
Ordinance.

"CONFLICTS OF INTEREST" means personal,
financial, family nepotism or any other
circumstances in which a person has an
interest in the outcome of a decision or
action.

"CUSTOMIZED TRAINING PROGRAM" means
training specifically related to the
employee duties and responsibilities as
gaming employees, i.e. customer
relations, operation of equipment,
accounting procedures and other training.
"EMPLOYEE" means a person employed by the
Oneida Tribe.

"EXTRA REGULAR CARD" means an
indispensable card which affords
additional opportunities to play in a
regular bingo game at a bingo occasion.
“FELONY" means a crime which has been
proven in a court of competent
jurisdiction which is more than a
misdemeanor and for which the convicted
person may be subject to fines or
imprisonment.

"FRAUD" means any act of trickery or
deceit used to gain control or possession
of the property of another.

"GAMES" means all games of chance
authorized and/or conducted by the Oneida

Tribe. Classes of games shall be as
defined in IGRA and the Tribal/State
Compact.

"GAMING EXPANSION PLAN" means a plan for
any future gaming activities not defined

2.


employee during their normal hours
of employment.

e. No consultant or vendor, their
associates or members of their
immediate families shall be a patron
or player at any game authorized by
this Ordinance.

No manager or employee of the Oneida

Tribe or for one (1) year following

employment may participate in any

personal business venture or other
endeavor which competes with any
enterprise governed by this Ordinance or
undermines said enterprise, or utilizes
expertise gained by virtue of their
employment by the Oneida Tribe, except by
prior disclosure and approved by the
Oneida Business Committee.

Rules for All Games

1.

Sufficient space to Play: Each play is
entitled to a place with sufficient room
in which to play.
Limitation on Players: Limited to the
capacity of the premises/facility as
defined by applicable safety standards.
Payouts: Shall be as authorized and as
set forth in the Standard Operational
Procedures Manual. Limitations on
payouts shall be conspicuously posted and
specific notice of such pe proved to all
persons to whom such limitations apply.
Payouts by annuities shall be as set
forth in the annuity agreement.
Advertisement of Games: All gaming
advertising shall be consistent with this
Ordinance, the provisions of the Indian
Gaming Regulatory Act, and the Compact
and shall be set forth in the Standard
Operational Procedures Manual.
Bus Regulations: Shall be promulgated by
the Manager and reviewed by the Gaming
Commission to insure the following:
a. Applications for permits including
IRS taxpayer I.D. numbers
b. Orderly procedures for the bus
patrons, parking.
c. Consistency with the laws and
policies of the Oneida Tribe and
this Ordinance.

d. Compliance with the Ordinance, the
IGRA and the Oneida/Wisconsin
Compact.

16.


Resolution 4:27-94B

CERTIFICATION

I, the undersigned, as Secretary of the Oneida Business Committee, hereby certify
that the Oneida Business Committee is composed of nine members, of whom 5 members
constitute a quorum. _§ members were present at a meeting duly called, noticed and held
on theZ#nw _ day of

Hori} 1994 ; that the foregoing resolution was duly adopted at
such meeting by a vote of _'7. members for; _© members against, and () members not
voting; and that said resolution has not been rescinded or amended in any way.

lie Barton, Tribal Secretary
‘Oneida Business Committee



Safety Department and completed prior to
election as required pursuant to the
Election Ordinance.

All candidates shall complete a form
requiring disclosure of conflicts of
interest prior to the election as
required by the Oneida Election
Ordinance.

Elections shall be made by the Oneida
General Tribal Council pursuant to the
Oneida Election Ordinance and the
requirements of this Ordinance.
Installation shall be administered by
oath at a regular meeting of the Oneida
Business Committee.

Upon installation, all Commission members
shall be issued a Tribal Gaming Security
Card setting forth their title and term
of office.

There shall be an annual meeting within
thirty (30) days after the election at
which the Commission shall select from
amongst its members a chairperson, a
vice-chairperson and a secretary and
shall inform the Business Committee,
Gaming Manager and Kalihwisaks of its
membership.

c. Responsibilities of Commission

1.

No Commissioner shall act independently
of the Commission. Any such acts may be
grounds for removal.

Shall promulgate such rules, regulations,
procedures, and guidelines as it deems
appropriate to implement and enforce the
provisions of this Ordinance to be
approved by the Business Committee,
including and consistent with all
directives of the Oneida General Tribal
Council. These shall be set forth in the
Standard Operational Procedures,
specifically including meeting rules and
internal elections for officers. These
may be amended at the discretion of this
Commission and approved by the Business
Committee.

The Commission shall review and approve
all contracts and agreements prior to
execution deemed necessary in
implementing the annual business plan
according to the approved budget
following the same general policies .and
contract review procedures used by the

9.


Procedures Manual.

1.

All Primary Management personnel and
designated Key Employees shall be
enrolled members of the Oneida Tribe of
Indians of Wisconsin, 18 years of age or
over. . These positions shall be listed by
job title in the Standard Operational
Procedures Manual. All other gaming
personnel shall be employed pursuant to
the Standard Operational Procedures,
specifically Gaming Personnel Policies
and Procedures which will provide for
Oneida and Indian preference.

Gaming management must be licensed as
provided for in this Ordinance and
Standard Operational Procedures.

Any gaming management member or employee
may be removed for cause as provided for
in the tribe’s Personnel Policies and
Procedures or this Ordinance.

All management and employees must be
bondable under the Tribe’s policy.
Background checks will be made on al
applicants prior to employment and on
employees as necessary as set forth in
the Standard Operational Procedures
Manual.

Conflicts of Interest are to be avoided,
but in any case require full disclosure.
Gaming Management shall cooperate with
the Gaming Commission in all
investigations whether criminal or
otherwise and other responsibilities.
All management and employees’ shall
execute necessary disclosure statements
regarding conflicts of interest.

B. Powers of Gaming Manager

1.

The Gaming Manager shall have full
jurisdiction for daily operations of
gaming conducted under this Ordinance as
well as corollary services provided to
patrons.

The Gaming Manager shall draft and
propose regulations and rules governing
licenses. Such regulations and rules are
to be reviewed by the Commission with
recommendations, if any, and subject to
approval of the Oneida Business
Committee. Such rules and regulations
shall be set forth in the Standard
Operational Procedures Manual.

Conduct gaming operations by personal

il.


Resolution 427-94B

WHEREAS, the loss of the gaming operations and the resulting loss of revenue would
cause irreparable harm and undue hardship on the Oneida People, and

WHEREAS, the Oneida Tribe of Indians of Wisconsin, in consideration of the foregoing
statements, desires that the following actions be implemented;

THEREFORE, BE IT RESOLVED: that, in order to protect the integrity of gaming, the
Oneida Business Committee is hereby invoking their authority under the Administrative
Procedures Act, Resolution 8-19-91A, Section VI, to provide for interim measures, the
following of which will be in effect for a period not to exceed six months.

BE IT FURTHER RESOLVED: the Oneida Gaming Commission shall commence with

their regulatory function, ensuring both compliance with applicable Tribal, local, state and
federal laws and uniform application of said laws.

BE IT FURTHER RESOLVED: that the Oneida Gaming Commission shall consist of
three full-time members, to be responsible for the development of regulatory policy and
commencement of the regulatory function. The remaining members of the Commission
shall be apprised of any policies developed and actions taken by full-time members, and
must approve any new policies before they go into effect.

BE IT FURTHER RESOLVED: that, the General Manager is directed to oversee the day
to day operations of the Gaming Enterprises through supervision of the Gaming Manager

and Gaming Management, and that Gaming Management shall cooperate with the General
Manager regarding these oversight responsibilities.

BE IT FURTHER RESOLVED: that the following amendments be inserted into the
Comprehensive Oneida Gaming Ordinance of 1992 superseding the existing sections of the
Comprehensive Oneida Gaming Ordinance where indicated, and that such amendments
shall be valid for a period of not more than six months from the date of their passage.

BE IT FINALLY RESOLVED: the General Manager, Gaming Management, the Oneida
Gaming Commission, and the Office of the Chief Counsel shall participate in the drafting
of a new Gaming Ordinance, which addresses the present and anticipated future needs of
the gaming enterprises, and will become effective when the six month period lapses or a
new ordinance is passed.


Oneidas bringing several
hunared bags of corn to
Washington s starving army
at Valley Forge. atter the
Colonists nad consistently
relused 10 ava them

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

Oneida Tribe of Indians of Wisconsin
Post Office Box 365

Phone: 869-2214 Oneida, WI 54155

GWA DEMOLUM YATEHE
Because of tne helo of this
Oneida Crvel in cementing
a Inendship between the
‘six nations and the Colony
of Pennsyivania, a new na-
hon the Unitea States. was,
mage possible

RESOLUTION # 4-27-94B

the Oneida Tribe of Indians of Wisconsin is a federally recognized Indian

Government and a treaty tribe recognized by the laws of the United States,
and

the Oneida General Tribal Council is the governing body of the Oneida
Tribe of Indians of Wisconsin, and

the Oneida Business Committee has been delegated the authority of Article
IV, Section 1 of the Oneida Tribal Constitution by the Oneida General
Tribal Council, and

the Oneida General Tribal Council has adopted the Oneida Nation
Administrative Procedures Act, Resolution 08-19-91A, to ensure the
consistency of law and rule-making procedures, and

the Oneida Nation Administrative Procedures Act, Resolution 08-19-91A,
Section VI, allows the adoption of an emergency ordinance or amendment
by the Oneida Business Committee, where an emergency requires such an

adoption because of a threat to the general welfare of the Oneida Tribe of
Indians of Wisconsin, and

the Oneida Tribe of Indians of Wisconsin has received a letter from the
National Indian Gaming Commission outlining fourteen (14) deficiencies
within the Comprehensive Oneida Gaming Ordinance of 1992 and other
submissions to the Commission, and

said letter states that all deficiencies must be cured on or before May 6, 1994,
and

the gaming operations of the Oneida Tribe of Indians of Wisconsin are a
vital resource that provides for the general welfare of the Tribe, and


ARTICLE III.

ARTICLE Iv.

prevalence of this malady will be by the
various departments and programs who address
it and made directly to the Commission.

AUTHORITY

A.

This Ordinance is authorized by the Oneida
Constitution, Article IV which has_ been
delegated by the Oneida General Tribal Council
to the Oneida Business Committee.

The Oneida Business Committee, subject only to
review of the Oneida General Tribal Council,
may further delegate responsibilities under
the Oneida Constitution to subordinate
organizations which have been directed by the
General Tribal Council or which in the
discretion of the Business Committee are in
the best interests of the Oneida Tribe.

This Ordinance addresses as required all
provisions of the Indian Gaming Regulatory Act
of 1988, P.L. 100-497.

The Oneida Tribe shall be the sole operator,
conductor, manager and owner of all gaming
enterprises on the Oneida Indian Reservation.
The Oneida Business Committee shall retain the
exclusive power to enter into agreements or
compacts with states, any other governments or
any other entity for gaming purposes.

The Oneida Business Committee shall retain the
exclusive power to enter into contracts and
agreements effecting any sale, disposition,
leases or encumbrances of tribal lands,
interests in lands, or other assets of the
Tribe.

The Oneida Business Committee delegates to the
Oneida Gaming Commission duties and
responsibilities as set forth in Article IV of
this Ordinance.

This Ordinance authorizes the Standard
Operational Procedures Manual which shall set
forth the various procedures required by this
Ordinance.

COMMISSION; POWERS, DUTIES AND LIMITATIONS

A.

There shall be a Commission to insure the
integrity of all games authorized by this
Ordinance. Seven (7) members of the Gaming
Commission shall be elected by the Oneida
General Tribal Council for a term of three (3)
years. The terms shall be staggered pursuant
to a procedure duly enacted by the Oneida

7.


10.

11.

12.

Oneida Business Committee for all other
contracts and agreements.

The Commission shall meet quarterly
unless otherwise required.

Report activities to Business Committee
to coordinate corrective measures.
Monitor and regulate gaming activities on
a continuing basis as it relates to this
Gaming Ordinance.

May inspect and examine all premises
where gaming is conducted.

May conduct such hearings, sit and act at
such times and places, take such
testimony and receive such evidence as
the Commission deems necessary.

Shall submit a report semi-annually to
the Secretary of the General Tribal
Council.

May review licenses as may be deemed
necessary as well as the licensing
procedure.

Shall review the investigation of the
background of and issue a license to the
Gaming Manager.

Monitor and review all activities of
gaming management plans, budgets,
projects, and progress and implementation
of all directives of the Oneida Business
Committee and provisions of this
Ordinance.

Commission Reports to Business Committee or
Oneida General Tribal Council:

1.

Approved minutes of all meetings shall be
sent to the Secretary of the Oneida
General Tribal Council within thirty (30)
days.

Financial reports referred to in Article
X of this Ordinance shall be reported as
set forth in that Article.

Summary reports of investigations or
matters shall be made at the discretion
of the Commission or as _ requested,
provided that confidentiality is not
breached in criminal investigations or
otherwise.

ARTICLE V. GAMING MANAGEMENT; POWERS, DUTIES AND LIMITATIONS

A.

There is hereby authorized a Gaming Management
Structure as set forth under Article IV, Sec.

1,

(G) of the Oneida Tribal Constitution which

shall be defined in the Standard Operational

10.