Chapter 20
Training Requirements Page 10 of 10

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulations, Chapter 20, Training Requirements, was duly ORDAINED,
ADOPTED, AND RATIFIED on this the _Sth_ day of March, 1999, at a duly called
meeting of the Gaming Commission of the Pueblo of Isleta, at which a quorum was
present, with __3_ voting for, 0 voting against, and_0 abstaining.

Burd. A bar

RAY W. ABEITA
Chairman

4 Ticeet) Xz Lesine

(ATRICIA L. JIRON

Vice-Chairman
Wh
GE

ECTARAMILLO
Secretary-Treasurer

ZZ
ATTEST

Subscribed and swom before me on this the _Sth_ day of March, 1999.

ODESSA A. MONTOYA NOTARY

(NOTARY PUBLIC-STATE OF EW MEXICO

crn i TMU, 9002.

My Commission Expires: Ty B HL?



Licensing

*SChapter 5
Page 12 of 35

for employment purposes with any Isleta Gaming Organization.

. The Commission, in its discretion, may suspend or revoke an applicant’s

temporary work permit or temporary vendor permit at any time, without
notice or a hearing based, in whole or in part, upon Article IX, Eligibility
Determination, of this Chapter.

. Only the Commission has the authority to sign a Temporary Permit of any

type, thereby executing and rendering the Permit valid and usable. However,
the Commission may designate, from time-to-time, this signatory authority to
a Commission Agent. This designation must be explicitly stated in writing by
the Commission and specify a time limit.

VII. BACKGROUND INVESTIGATIONS

A. Upon receiving a completed application and required licensing fee or

satisfactory arrangement for payment of the fee, the Commission shall
conduct a background investigation on the applicant. The background
investigation shall be ‘sufficient to allow the Commission to make an
eligibility determination under Article IX of this Chapter.

. Background investigations shall be performed in the following manner:

1. Employees:

a. All applicants must complete an application for a gaming
license in the Office of the Isleta Gaming Commission after
being hired by the Isleta Gaming Operation’s Human
Resources Department.

b. Upon completion of an Application for a Gaming License by
the applicant, the Commission shall conduct a background
investigation on the applicant. The Commission shall:

1) contact'all persons and entities identified in the
application, either by telephone or in writing, in order to
verify that the information in the application is truthful
and accurate;

2) interview a sufficient number of knowledgeable people,
such as references, former employers, partners, business
associates, and others, referred to in the application;

Isleta Gaming Commission Regulation ‘ . Revised December 01, 1999



Chapter 11
Variance Reporting Requirements Page 4 of 5

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate.

To the fullest reasonable extent possible, confidentiality is to be maintained in all
applications of this Regulation.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, form time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 3

Gaming Participation & Operation

Authority
Purpose
Scope
Gaming Participation
A. Patrons
B. Employee

1. Employee Practices

2. Employee Benefits-
Vv. Gaming Operations
Checks and Credit = -
Automatic Teller Machine(s) (ATM) ------------------~=-----------00---
Management Contractor(s)
Construction Standards
Political Contributions
Funding Assistance for Treatment of Support Programs -------------
VI. Enforcement Activity -
VII. Notice of Disciplinary Action For Policy Violations ---------------------------
VI. Acknowledgments
Commission Certification

3BRO

mM OA D>



Chapter 15
Race and Sports Book Computerized Page 4 of 16

includes the station number, date, time of test, time on machine,
name or signature of employee performing the test, and any other
relevant information.

J Keys (originals and all duplicates) to the date, time and numerical
sequence stamping devices are maintained and used by a
department or personnel who are independent of the ticket writing
and cashiering functions.

VI. WAGERING STANDARDS ©:

A. Whenever a betting station is opened for wagering or turned over
to a new writer, the betting ticket writer signs on and the computer
documents the writer’s identity, the date and time, and the fact that
the station was opened on either the unused ticket that is first in
sequence or in a separate report.

B. Whenever the betting station is closed or the writer is replaced, the
writer signs off and the computer documents the date and time,
and the fact that the station was closed out on either the unused
ticket that is next in sequence after the last ticket written or in a
separate report.

Cc. Upon accepting a wager a betting ticket is created which consists
of at least three parts:

1. An original, which is transacted and issued through a printer
and given to the patron.

2. A copy, which is recorded concurrently with the generation
of the original ticket either on paper or other storage media
(e.g., tape or diskette). .

2. An internally recorded copy to which access by book
employees is adequately restricted.

D. If a book voids a betting ticket then:
1. The word “Void”.is immediately written/stamped and the date

and time at which the ticket was voided is stamped on the
original.

ee

2. A key employee and one other person signs the ticket at the
time of voiding. :

Isleta Gaming Commission Regulation a i Revised December 16, 1999


Chapter 14
Drug Free Workplace Page 11 of 11

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 14, Drug Free Workplace, was duly REVISED,
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with _2 voting for, 0 voting against, and _0_ abstaining.

Vacant

Chairman

Secretary-Treasurer

ATTEST

Subscribed and sworn before me on this the _16th “day of December, 1999.

iia 27 jt

NOTARY

ane

SP My commission expres:

2:
My Commission Expires: ay) it ZL Z

Isleta Gaming Commission Regulation Revised December 16, 1999


AYaonays4
. Real {a
SOS-869-0457

Treat Counen. OFrrer: *
pus a Fax: SOS-869-0454

P.O, BOX 1270 ISLETA, NM 87022

RESOLUTION NO. 01- 906
Pueblo of Isleta Gaming Regulatory Agency

At a duly called meeting of the Tribal Council of the Pueblo of Isleta, the
following resolution was passed:

WHEREASthe Pueblo of Isleta Tribal Council has by Resolution 95-03, as
subsequently amended by Resolution 00-108, established the Pueblo of
Isleta Gaming Commission to exercise tribal regulatory authority over
Gaming activities conducted upon the sovereign lands of the Pueblo of
Isleta, including those conducted by the Pueblo’s gaming enterprise, the
Isleta Casino & Resort (“Pueblo Gaming”);

WHEREAS, based upon the experience of the Pueblo of Isleta, Tribal Council has
determined that the Gaming Commission Model provided for in
Resolution 95-03 and 00-108 is no longer the most effective and efficient
way in which to exercise the sovereign governmental authority of the
Pueblo of Isleta over Pueblo Gaming;

WHEREAS, in view of the Pueblo’s newly approved Compact for Class III Gaming
with the State of New Mexico (the “Compact”), the adoption of the Pueblo
of Isleta Gaming License Review Procedures by Resolution 01-104, and
other events and circumstances, this is an opportune time at which to
restructure the regulatory entity through which the Pueblo of Isleta’s
sovereign regulatory authority over Pueblo Gaming is exercised.

NOW, THEREFORE, BE IT RESOLVED by the Tribal Council of the Pueblo
of Isleta:

Article I—- Gaming Regulatory Agency
1, There is hereby established the Pueblo of Isleta Gaming Regulatory Agency
(the “Isleta Gaming Regulatory Agency”). For purposes of maintaining
familiarity of reference to regulated parties, consuming existing stationary,
forms, supplies and other materials, and to allow the Isleta Gaming

Page 1 of 5

a


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 11

Variance Reporting
Requirements


Licensing

Chapter 5
Page 21 of 35

XL DENIAL OF APPLICATION AND DENIAL OF A GAMING LICENSE

A. The Isleta Gaming Commission may deny an application based on Article IX,
Eligibility Determination, herein. Without limiting the foregoing, the
Commission may deny the application on any of the following grounds:

1.

10.

Evidence of an untrue or misleading statement of material fact, or
willful omission of any material fact, in any application, statement, or
notice filed with the Commission or made in connection with any
investigation, including any part of the background investigation;

Conviction of any felony, gross misdemeanor, or history of excessive
criminal activity in any jurisdiction, even though the convicted person’s or
entity’s post-conviction rights and remedies have not been exhausted, if
the crime or conviction discredits or tends to discredit the Pueblo of Isleta
or the gaming industry;

Conviction of any gaming offense in any jurisdiction;

Conviction or charge of theft (Larceny), embezzlement, and/or fraud in
any amount;

Committed, attempted, or conspiracy to commit larceny, fraud, or
embezzlement against any Isleta Gaming Operation or upon the premises
of a gaming establishment;

Excessive DWI or DUI charges or convictions in any jurisdiction or
combination thereof;

Entry of a civil judgment against the applicant that is based, in whole or
in part, on conduct that allegedly constitutes a crime;

Direct or indirect association with persons or businesses of known.
criminal background or persons of disreputable character that may
adversely affect the general credibility, security, integrity, honesty,
fairness, or reputation of the proposed activity;

Any aspect of the applicant’s past conduct, character, or behavior that the
Commission determines would adversely affect the credibility, security,
integrity, honesty, fairness, reputation of the proposed activity, or
adversely effects the regulation of Gaming;

Failure of the applicant or its employees to demonstrate adequate business
ability and experience to establish, operate, and maintain the business for

Isleta Gaming Commission Regulation Revised December 01, 1999


Chapter 15

Race and Sports Book Computerized Page 2 of 16

IL AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity of the Isleta Gaming Enterprise
pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any ordinance adopted
thereto.

I. PURPOSE

The purpose of this regulation is to provide a comprehensive set of guidelines for
Computerized Horse Race and/or Sports Book wagering which shall be followed by the
Isleta Gaming Operation(s) management and employees. Further, this regulation will
specifically enumerate the manner in which the Commission will exercise said authority
in its oversight of all Palace Horse Racing or Sports Book activity. In applying this
authority to Horse Racing or Sports Book operations, the Commission shall act in a
responsible and consistent manner when promulgating, adopting, approving, revising,
implementing, administering, and enforcing the rules, regulations, policies, and decisions
of the Commission.

I. SCOPE

This regulation applies to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
resolution adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo of
Isleta/State of New Mexico Class III Gaming Compact. This regulation does not apply to
other tribal entities or agencies within the Pueblo of Isleta Tribal Government.

IV. SYSTEM SECURITY STANDARDS

A. Access to the computer system is adequately restricted (e.g.,
passwords are changed at least quarterly, access to computer
hardware is physically restricted, etc.).

B. Procedures have been developed for use in case of hardware
failure, power failure, fire, etc. -

Vv. BETTING TICKET AND EQUIPMENT STANDARDS

A. All race and sports book wagers must be transacted through the
computer system. In case of computer failure, tickets may be
written up to twenty-four (24) hours after the failure. In those

_-______ -—»seainstances where.system failure has occurred and tickets are
manually written, a log will be maintained which includes:

ene
Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 5
Licensing 2 ane Page 32 of 35

-~ All non-gaming vendors shall renew their licenses every two (2) years. In
order to renew a license, a non-gaming vendor shall resubmit to the entire
licensing process as set forth in Articles V through XI herein. Non-
gaming vendors shall pay the nonrefundable licensing fee required under
Article VI, herein, each time they renew their license.

C. Gaming Vendors

All Gaming Vendors must renew their licenses every two (2) years. In
order to renew a license, a gaming vendor shall resubmit to the entire
licensing process as set forth in Articles V through XI herein. Gaming
vendors must pay the nonrefundable licensing fee required under Article
VI, herein, each time they renew their license.

XVI. EXCEPTIONS
A. Waiver

1. The Commission, in its discretion, may grant a one-time waiver on
a particular purchase(s) from a non-licensed vendor.

2. Management of the Isleta Gaming Operation must justify, in
writing, the reasons why the waiver should be allowed and submit
that justification along with the request for a waiver to the
Commission. a

3. Upon receipt of the Request for Waiver, the Commission has five
(5) business days to render a decision and inform Management.
The Commission may, if necessary, require more information on a
particular waiver request, therefore, any request for additional
information by the Commission to Management shall suspend the
aforementioned five (5) day rule, until such information is
provided by Management.

4. All waivers are handled on a-case-by-case basis.
XVII. ENFORCEMENT ACTIVITY: ..°
A. The Commission reserves the right to enforce this regulation as follows:

1. an imposition of a fine of no less than fifty dollars ($50.00) and no
more than five hundred dollars ($500.00) for employees;

Isleta Gaming Commission Regulation Revised December 01, 1999


Commission Certification -—~

§ SS<28F"

Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 2

Promulgating
Internal Procedures & Regulatory Provisions

Authority

Purpose
Scope

Definitions

Promulgating Regulations

Promulgating Ordinances
Promulgating Policies, Procedures, and Controls
for the Pueblo of Isleta Gaming Operation

RANNNN

Methods of Enforcing Rules, Controls, Regulations, Minimum

~ Internal Control Standards, Gaming Laws, Other Applicable

Laws, Policies, and Procedures ===:



Code of Conduct

Chapter 18
- Page 7 of 14

B. Vendor

1.

A conflict of interest occurs when any vendor is in a situation in
which they can gain from information or from personal contact and
such gain or potential gain would not be available except through
said contact with the Isleta Gaming Operation. Such conflict of
interest is to the benefit of the vendor or to the detriment of the
Isleta Gaming Operation, either monetarily or to its’ public image.
All such situations are strictly prohibited.

Vendors must avoid financial, business, and personal relationships
with Isleta Gaming personnel which might be opposed to Isleta
Gaming Operation interests or which might impair the independent
judgment of such personnel related to Isleta Gaming matters.

All vendors who have an interest in or a relationship with an
employee, of the Isleta Gaming Operation must report this fact and
carefully follow any precautionary steps established by the
Commission. The Isléta Gaming Commission Regulation Chapter
18, Section VI, B, 4, below, details the policies and the procedures
for reporting possible conflicts of interest.

Vendors must report any conflict of interest or potential conflict of
interest on the Vendor Licensing Application. In the event a
potential conflict of interest arises at a later date, the Vendor must
submit, in writing, all pertinent details of such a conflict, to the
Commission. The Commission will then, in its discretion, address
such a potential conflict in writing, via hearing or other acceptable
method. .

A vendor will not perform, propose to perform, or participate in
any business transaction directly with an immediate family
member who is employed by the Isleta Gaming Operation.

All vendors are strictly prohibited from giving or offering or
proposing to offer any compensation, loan, gift, gratuity, benefit,
or unusual hospitality of any value to any Commissioner,
Commission staff member, Tribal Official, or Isleta Gaming
Operation employee, with whom they are performing any activity
or transaction.

Isleta Gaming Commission Regulation Revised December 16, 1999


Marketing & Promotions

Chapter 12
Eis anes Page 3 of 6

Vv. DESCRIPTION OF THE PROMOTION

A.

It is the responsibility of the Marketing and Promotions Director or his/her
designee to submit the following to the Gaming Commission at least five
(5) business days prior to the start of any promotion:

1.

This shall include the exact days in which the promotion shall take
place (start to finish);

who shall be allowed to participate;

a detailed description of how the promotion shall be conducted;
and

which department(s) shall be responsible for conducting said
promotion. oo

VI. MINIMUM CONTROLS

A.

The following detailed description of the Minimum Controls which shall
be implemented by he Palace to ensure a fair and successful promotion
shall also be given to the Commission at least five (5) business days prior
to the start of any promotion:

1.

This shall include the names of Palace employees authorized to
conduct the promotion,

The controls that will be implemented to ensure fair contestant
entry into the promotion.

Vil. THE GAMING COMMISSION WILL REVIEW ALL PROMOTION
CONTROLS ESTABLISHED FOR SAID PROMOTION.
ADDITIONALLY, FINAL WRITTEN COMMISSION CERTIFICATION
OF SAID CONTROLS IS NECESSARY BEFORE ANY PROMOTION
MAY BEGIN. _

sot

VI. CONCLUSION OF PROMOTIONS

A. At the conclusion of any given promotion, the Palace shall provide the

Commission with a Post Promotion Audit report. This report shall include,
but is not limited to:

1. Originals or copies of winning document (coupon)

Isleta Gaming Commission Regulation vse Revised December 16, 1999


Chapter 13

Surplus Palace Property Page 2 of 5

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

I. PURPOSE

The purpose of this regulation is to effectively regulate the disposal of any and all
Palace property or equipment, which through normal wear or obsolescence, may be
deemed surplus. This will ensure and protect any funds, which may have been expended
in purchasing said property or equipment.

I. SCOPE

This regulation shall apply to all Palace and Palace West property and equipment.
This regulation shall further apply to all functions and duties over which the Commission
Tetains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
ordinance adopted thereto, the Indian Gaming Regulatory Act of 1988, 25 U.S.C. 2701,
and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact. This regulation
does not apply to other Tribal entities or agencies within the Pueblo of Isleta Tribal
Government. . _

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural.

Casino Games - includes, but is not limited to, all Electronic Gaming Devices
(EGD’s), all Table Games; all forms of Poker; Blackjack; Roulette; Craps; Let It
Ride; Keno; Wheel of Fortune; Pai Gow; Bingo; any and all Class II or III games
of chance.

Commission/Gaming Commission/Isleta Gaming Commission ~ pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

IGCR - Isleta Gaming Commission Regulation.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 17 >
Notification to the Commission Page 12 of 12

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 17, Notification to the Commission, was duly
REVISED, ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of
December, 1999, at a duly called meeting of the Gaming Commission of the Pueblo of
Isleta, at which a quorum was present, with 2 voting for, 0 voting against, and _0
abstaining.

Vacant

Chairman

(tie fie

TRICIA L. JIR
Vice-Chairman

<

RNEST C.$ARAMILLO
Secretary-Treasurer

= 4 esx

ATTEST

Subscribed and sworn before me on this the _16th_ day of December, 1999.

a ODESSA A, MONTOYA - CH
Be ey 7 NOTARY

‘Sy commission

My Commission Expires: j

Isleta Gaming Commission Regulations Revised December 16, 1999


Pueblo of Isleta Gaming Commission’
Regulation

TABLE OF CONTENTS

Chapter 17

Notification to the Commission

L Authority 2
Il. Purpose 2
Ill. Scope 2
IV. Definitions 2
V. Policy 3

A. Casino Games 3

B. Construction/Modification of Gaming Facility ----------------------. 4

Cc. Modification/Alteration of Standard Operating Procedures (SOP’s)-5

D. Contracts 7
VI. Exception(s) 9

A. Emergencies - 22+“ 9
VII. Enforcement Activity 10
VIII. Notice of Disciplinary Action for Policy Violations -------------------------- 10
IX. Acknowledgments 10

Commission Certification 12



Licensing

Chapter 5.
Page 27 of 35

investigation, including any part of the background investigation;

. Charge of any felony, gross misdemeanor, or history of excessive

criminal activity in any. jurisdiction. If the charged person’s or
entity’s post-conviction rights and remedies have not been exhausted,
if the crime or conviction discredits or tends to discredit the Pueblo of
Isleta or the gaming industry;

. Charge of any gaming offense in any jurisdiction;
. Charge of theft (Larceny), fraud, or embezzlement in any amount;

. Reasonable evidence implicating committed, attempted, or conspiracy

to commit larceny, fraud, embezzlement or other criminal offense of
any type and in any amount from any Pueblo of Isleta Gaming
Operation; :

. Contumaciously defied any legislative investigative committee or other

officially constituted bodies acting on behalf of the United States, any
Tribe, State, County, or Municipality which seeks to investigate crimes
relating to gaming, corruption of public officials, or any organized
criminal activities;

. Entry of a civil judgment against the applicant that is based, in whole

or in part, on conduct that allegedly constitute a crime;

. Direct or indirect association with persons or businesses of known

criminal background or persons of disreputable character that may
adversely affect the general credibility, security, integrity, honesty,
fairness, or reputation of the gaming industry;

i. Any aspect of the applicant’s past conduct, character, or behavior that

the Commission determines would adversely affect the credibility,
security, integrity, honesty, fairness, reputation of the proposed
activity, or adversely effects the regulation of Gaming;

Failure of the licensee or its employees to demonstrate adequate
business ability to operate, and maintain the business for the type of
activity for which application is made;

. Failure to maintain adequate financing for the operation undertaken

in the application; _

1. Failure to timely respond to any request, oral or written, by the ——-——————--—___

Isleta Gaming Commission Regulation — . Revised December 01, 1999



Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 4

Gaming .
Equipment or Devices or Supplies



Training Requirements

Chapter 20
—Page 5 of 10

at least, all materials mentioned in this regulation, allow for
questions and answers posed to the provider of said training, and
may provide for a test of said materials, if necessary.

Due to the fact that the material(s) to be covered is extensive, the
training session(s) may be held consecutively over a period of days
or even several weeks, but it is not to exceed more than ninety (90)
calendar days in duration.

Each Isleta Gaming Palace Department shall maintain a Training
Profile Folder on each of its subordinate employees in order to
maintain a record of the training received by the employee and the
results of the training. It is the responsibility of the Department
Manager to assure that this folder is implemented and maintained.
The Department Manager shall send all original documents on all
pertinent information concerning training to the Human Resource
Department to be place in the employee’s official file. The
Department Manager shall retain a copy of all original documents
on all pertinent information concerning training on each
subordinate employee to be placed in the departmental Training
Profile Folder. (For information on training forms see Section VI,
The Role of the Human Resource Department, below)

Each Isleta Gaming Palace Department Manager will keep one (1)
copy of the Isleta Gaming Commission Regulations and one (1)
copy of each Departments Standard Operating Procedures (as
applicable) in his/her administrative office or the general vicinity
thereof.

Each Isleta Gaming Palace Department Manager shall make
available, for continuous educational purposes, all materials
covered by this regulation to all employees upon request.

Each Isleta Gaming Palace Department Manager shall be
responsible for writing and implementing a Basic Tasks Manual,
detailing the policies and procedures for the performance of the
duties of the subordinate employees and shall give a copy to each
employee. This Basic Tasks Manual shall be considered only as an
aide in assisting employees in the performance of there duties and
is not all inclusive of duties which may be assigned from time to
time by the Isleta Gaming Operation.

In the event a new subordinate employee is hired by the Isleta
Gaming Palace and the aforementioned training(s) has been


Chapter 8
Employee Grievance Procedures Page 5 of 7

processing such grievance appeals, with fundamental fairness, justice, and
common sense. .The Gaming Management Board shall maintain organized
record of all appeals, whether actually heard or simply denied on the
merits. .

1. Petition

The Management Board shall be petitioned by the aggrieved for a
formal hearing. Since the employee should have had two prior
appeals (Employee Grievance Committee and General Manager)
by this point, there is no automatic right of appeal beyond the
Palace General Management. An employee wishing to appeal to
this level shall do so of his own accord.

2. Contents of a Formal Petition

A formal petition to the Management Board shall be submitted in
written form. This should not be the grievance form used at Palace
level but a new pleading which shall include the procedural wrongs
allegedly perpetrated by Palace Management when hearing the
initial grievance. The aggrieved should plead with specificity, all
alleged wrongs. If the Management Board believes a serious
wrong has been committed, it may institute a formal hearing. If
there is no serious wrong, the Management Board should inform,
in writing, the aggrieved of its decision, with reasons, as soon as
possible. .

3. Hearing

If a formal hearing is deemed necessary, Palace management must
provide an advocate to answer any and all charges made by the
aggrieved at the formal hearing. It may be necessary for the Palace
representative to submit the formal answer in written form. The
Management Board shall give an appropriate amount of time for
each party to prepare for the formal hearing.

4. Minimum Procedural Requirements of a Formal Hearing

The Management Board shall prepare procedural instructions for a
formal hearing: The Management Board shall make these
instructions available to all interested parties and the Isleta Gaming
Commission (it will be these instructions that the Tribal Council
will examine to determine if an appeal will be entertained beyond
the Gaming Management Board, if the need should arise). Finally,

Isleta Gaming Commission Regulation veh See Revised December 16, 1999


Chapter 4
Gaming Equipment or Devices or Supplies Page 7 of 13

c. The following items will be recorded by the Commission
Inspector on thé “Isleta Gaming Commission EPROM
Verification Work Sheet”:

Machine Number

Serial Number and/or Asset Number

Main, Personality, and Supplement Chip Numbers
Seal Number

Kobetron Signature

Date and Time

Inspectors signature

MAYPYNS

d. The Commission Inspector will affix the Official Commission
Seal (tape) on the Main, Personality, and Supplemental chips as
appropriate. The board will then be placed, by the Slot
Technician, back into the EGD. The EGD will be turned on
and tested for proper operation.

e. Ifa Main, Personality, or Supplemental Chip(s) has previously
been sealed and access becomes necessary, only a
Commissioner or their designee may break the Commission.
Seal, allowing access. No exceptions! Penalties for breaking a
Commission Seal without Commission authorization are
severe.

f. If the Main, Personality, or Suppleméntal Chips reside on
different or several boards in'an Electronic Gaming Device,
each and every board that contains any one of these chips is
considered a Logic Board and must be treated accordingly.
This includes but is not limited to, slot machines, progressive
meter, etc.

g. No Main Chip, Personality Chip, or Supplemental Chip(s) or
logic board. will be installed, removed, or replaced in any EGD
without first obtaining a Commission Seal and completing
this process, herein.

h. When the above actions occur, the Isleta Gaming Commission
EPROM Verification’ Work Sheet(s) aré to be kept on file,
under protected. miode, in the Commission Inspectors Office.

i. The Kobetron shall be kept in the Commission Inspectors
office.

Isleta Gaming Commission Regulation - Revised December 16, 1999


Chapter 15

Race and Sports Book Computerized Page 14 of 16

1. The date, amount, and a description of each debit and credit
to the account.

2. For each wager accepted:

a. The date the book accepts the wager.
b. The number of the betting ticket.

c. The amount of the wager.
3. The personal identification number or other security code, if
any, assigned to the patron.
E. All credit limits in excess of a specified amount (not to exceed

$20,000.00) are approved in advance by management

independent of the book, if possible, or at a minimum by an
individual at the level of book manager. (See Section XVIII, Credit
Wagering of this document).

F. A master listing of all wagering accounts is prepared and
reconciled to the individual account balances at least monthly.

XVII. CREDIT WAGERING (if applicable)

A. An account is not established Until a documented credit check has
been performed on the patron.

B. All credit limits in excess of a specified amount (not to exceed
$20,000.00) are approved in advance by management
independent to the book, if possible, or at a minimum by an
individual at the level of book manager.

Cc. The record of each account includes the patron’s name and
address, each extension of credit, payment on credit, and current
balance.

D. A master listing of all credit accounts is prepared to the individual
account balances at least monthly.

E. At specific intervals (to be determined by management) and upon
failure of the patron to make payment within a reasonable time (to
be determined by management) the gaming facility pursues
collection of the patron’s debt.

Isieta Gaming Commission Regulation Revised December 16, 1999



Chapter 5
Licensing . Page 17 of 35

Gaming Commission. The National Indian Gaming Commission is
responsible for obtaining a criminal history record from the Federal
Bureau of Investigation (FBI) on each h applicant and forwarding it to the
Isleta Gaming Commission.

G. Additional Investigations

1. The Commission retains the right to conduct additional investigations,
background or otherwise, of any individual or entity required to be
licensed, at any time while the application or license of that person or
entity is valid or in use.

2. Due to unforeseeable circumstances that may occur during the tenure
of an issued gaming license of an individual or entity, the Commission
reserves the right to conduct additional investigations as necessary.
Therefore, licensees have a continuing responsibility to fully cooperate
with any Official Commission Investigation, inquiry, or request for
information regardless of the subject matter.

3. During the course of any Official Commission Investigation, Isleta
Gaming Operation employees, other persons, or entities that are
interviewed must maintain the confidentiality of the subject matter
discussed with the Commission or its’ agents and shall not breach this
confidentiality to any third party unless otherwise required by law. A
third party includes, but not limited to, outside entities, co-workers,
supervisors, managers, the general manager, family members,
relatives, government agencies, etc. Retaliation, in any form, by an
employee or superior toward their co-worker(s) or subordinate(s) for
refusal to breach this confidentiality may result in severe disciplinary
action against the perpetrator.

H. Absolute Privilege of Certain Communications and Documents;
Restrictions On and Protections against Disclosure.

1. Any communication or document of an applicant or licensee, or an
affiliate of either, which is made or transmitted to the Commission or
any of their agents or employees to:

a. Comply with any law or the regulations of the Commission;

b. Comply with a subpoena or order issued by the Commission; or

c. Assist the Commission in the Performance of their respective
duties,

is absolutely privileged and does not impose liability for defamation or

constitute a ground for recovery in any civil action.

Isleta Gaming Commission Regulation _., Revised December 01, 1999



. Chapter 18
Code of Conduct Page 13 of 14

This policy may be amended as necessary to meet the interests of the objectives of
this policy as may be determined, from time to time.. All rights to further amend, refine,
and redefine are specifically reserved to the Isleta Gaming Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 14
Drug Free Workplace Page 10 of 11

1. All positives reported by the laboratory may be reviewed by a medical
officer designated by the Commission.

IX. ACKNOWLEDGMENTS —

Compliance with this drug-free workplace regulation, is a condition of
employment at the casino(s). Nothing in this policy shall be construed as any guarantee
or promise to any applicant or any employee, of any employment or any continued
employment whatsoever, nor shall any provisions of this policy constitute or be
interpreted by any party or tribunal to constitute any contractual rights of employment
expressed or implied, or any obligation of employment rights created by covenants of
good faith and fair dealing, either expressed or implied.

Nothing in this policy shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees responsibility to protect,
guard, and take adequate precautions for his or her own safety and health in the
workplace.

To the fullest reasonable extent possible, confidentiality is to be maintained in all
applications of this regulation. yet

This policy may be amended as necessary to meet the interests of the objectives of
this policy as may be determined, from time-to-time. All rights to further amend, refine,
and redefine are specifically reserved to the Isleta Gaming Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 4
Gaming Equipment or Devices or Supplies a Page 3 of 13

b. Slot Department Manager or their designee,
Duties: Invoke any remedial action required and confirm
by their signature what actions have been completed.

c. Palace Security Officer,
Duties: Security personnel are to witness and confirm by
their signature (if applicable) what actions took place and
by whom.

B. Procedure for the Control of Electronic Gaming Devices (EGD’s)
1. License required; applications

a. A person may act as a manufacturer only if that person
holds a non-restricted license specifically permitting the
person to act as a manufacturer or distributor.

b. Applications for manufacturer’s or distributor’s licenses must
be made, processed, and determined in the same manner as
applications for non-restricted gaming licenses, using such
forms as the Commission Chairman may require or approve.

NOTE: See Chapter 5, Licensing, hereto, for further information
on obtaining a Vendor License.

2. Approval of Gaming Device; applications and procedures

a. A manufacturer or distributor shall not distribute a gaming
device in the Pueblo of Isleta Reservation and a license shall
not offer a gaming device for play unless it has been approved
by the Commission or is offered for play pursuant to a field test
ordered by the Commission Chairman.

b. Applications for approval of a new gaming device must be
made and processed in-such manner and using such forms as
the Chairman may prescribe. Only licensed manufacturers may
apply for approval of a new gaming device. Each application
must include, in addition to such other items or information as
the Chairman may require:

1A complete, comprehensive, and technically accurate
description and explanation in both technical and lay

Isleta Gaming Commission Regulation oe Revised December 16, 1999


Licensing

Chapter 5
Page 20 of 35

E. The Commission shal] not issue a Gaming License, under this article, to any

individual or entity that has previously been denied within three (3) years of
the date of the newly submitted application provided that the applicant is
determined to be ineligible under this Article (IX.) of this Chapter.

X. REPORTING REQUIREMENTS (KEY EMPLOYEES AND PRIMARY
MANAGEMENT OFFICIALS ONLY)

A. When a key employee or primary management official begins work at a

Gaming Operation of the Pueblo of Isleta, the Commission shall send the
required information to the National Indian Gaming Commission and the State
of New Mexico Gaming Representative.

. Upon completion of a background investigation on a key employee or primary

management official, the Commission Investigator or the Commission’s
designated investigative agency shall prepare a report on the investigation.
The Commission Investigator or the Commission’s designated investigative
agency shall send the report to the National Indian Gaming Commission and
the State Gaming Representative within sixty (60) regular days after an
employee begins work. The report shall include:

1. the steps taken in conducting the background investigation;
2. the results of the background investigation;

3. the Commission’s conclusion; -

4. the basis for the Commission’s conthisions; and

5. acopy of the eligibility determination made under Article [X of this
regulation.

. If the Commission decides not to issue a license to a key employee or a

primary management official, it shall notify the National Indian Gaming
Commission and the State of New Mexico Gaming Representative of its
decision.

. The Commission must retain copies of a key employee or primary

management official’s application for employment and background
investigation for three (3) years after the date.of termination of employment.
During the three (3) year period; the Chairman of the National Indian Gaming
Commission and the State Gaming Representative may inspect these records
with forty-eight (48) hours prior written notice, not including weekends.

Isleta Gaming Commission Regulation a Revised December 01, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 18, 1999)

Chapter 18

Code of Conduct


Code of Conduct

Chapter 18
Page 6 of 14

10.

11.

All Isleta Gaming Operation employees are strictly prohibited from
receiving any compensation, loan, gift, benefit, or unusual
hospitality of any value from any patron, supplier, vendor, other
employee, or official to the Isleta Gaming Operation. (See JGCR,
Chapter 16, Gifts, Gratuities, & Solicitations, hereto, for further
details) -
All Isleta Gaming Operation employees are strictly prohibited from
disclosing, revealing, or sharing, in any way or form, confidential
information, proprietary information, or inside information which
may give an unfair advantage or benefit to a patron, vendor,
official, or another employee when pursuing transactions,
employment, employment promotions or activities with the Isleta
Gaming Operation.

An employee in any management position will not directly
supervise, in any way or form, an immediate family member in a
subordinate position.

An employee in any management or authority position will not
preside over or participate in a disciplinary process, in any way, of
an immediate family member in a subordinate position. This
includes, but is not limited to, grievances, disputes, etc.

An employee in any management or authority position will not
preside over or participate in the evaluation process, in any way, of
an immediate family member in a subordinate position. This
includes, but is not limited to, employment evaluations,
promotions, pay raises, etc.

An employee in any management or authority position will not
participate in any business transaction, in any way or form, with a
vendor who is an immediate family member.

In the event that a situation arises in which an employee, in any
management or authority position, is related to a subordinate
employee or business vendor, that employee will immediately
excuse himself/herself from participating in any such proceeding
and/or transaction and advise the other party that this situation
needs to be dealt with by an objective individual(s) bigher in the
chain-of-command of the Isleta Gaming Operation. This may
deem it necessary that the Gaming Management Board, Governor,
or Tribal Council preside over said situation, proceeding, or
transaction, ~ :

My

Isteta Gaming Commission Regulation Revised December 16, 1999


Chapter 8
Employee Grievance Procedures _ Page 6 of 7

any such instructions shall be created with the sole purpose of
providing a fair and convenient forum for all parties to be heard
and all disputes adjudicated justly.

5. Final Determination

After the formal hearing, the Management Board shall consider the
evidence and the testimony offered and make a final determination
on the grievance. All interested parties shall be notified, in
writing, of the Management Board’s final determination within a
reasonable time after the Board has made this determination.

E. Step V.

“Step V” shall be an appeal to the Pueblo of Isleta Tribal Council. Since
the Tribal Council is the Legislative Body of the Tribe, appeals procedures
will be in the form prescribed by the Council. However, an appeal should
come in the form of a petition, in the same manner of a Gaming
Management Board Appeal, including the same restrictions. After

appropriate action, the Tribal Council shall make its final determination on
the matter and notify all interested parties. The Pueblo of Isleta Tribal
Council may waive this process and rest the final determination with the
Management Board.

NOTE: ALL STEPS IN THIS PROCESS MUST BE COMPLETED WITHIN A
REASONABLE AMOUNT OF TIME.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 16

- Gifts, Gratuities,
Sk
Solicitations _



Pueblo of Isleta Gaming Commission
Regulation :

TABLE OF CONTENTS

Chapter 12

Marketing & Promotions

1. Authority 2
Il. Purpose 2
Ii. Scope -- 2
IV. Definition 2
Vv. Description of the Promotion 3
VI. Minimum Controls 3
VII. Gaming Commission Review and Approval of Said Promotion.... ---------- 3
VIII. Conclusion of Promotions 3
IX. Written Report of Said Promotion 4
x. Enforcement Activity - -- 4
XI. —_ Notice of Disciplinary Action For Policy Violations ------------------—-----~ 4
XII. Acknowledgments 5
Commission Certification 6



Chapter 4
Gaming Equipment or Devices or Sapplies Page 13 of 13

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 4, Gaming Equipment or Devices or Supplies, was
duly REVISED, ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day
of December, 1999, at a duly called meeting of the Gaming Commission of the Pueblo of
Isleta, at which a quorum was present, with _2_ voting for, _0_ voting against, and

_0_ abstaining.

Vacant

Chairman

Cte wd Koa.
TRICIA L. JIRON

Vice-Chairman

gt /
My Commission Expires:

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 6
Investigative Procedures Page 4 of 8

c. Rules of handling evidence for any and all evidence
collected/formulated in the furtherance.of each case will
be applied [Refer to.18 U.S.C. 3001 - 3731 (1948) as
applicable pursuant to the authority granted the
Commission].

B. Closed Issue Investigation,

1. “Closed Issue” investigations shall be referred to as “Operative
Investigations.” Unlike Open Issue investigations, issues and facts in
such an investigation may not be apparent or known to the general
Palace management. Palace management, at the discretion of the
Commission and only on a need-to-know basis, may be informed of an
Operative Investigation.

a. All the stated rules addressed in the “Open Issue”
investigations apply.

b. These investigations are conducted under very limited
circumstances and only under the closest of supervision and
authorization of the Isleta Gaming Commission.

c. Any and all informant evidence must be codified as
“OPERATIVE,” thus eliminating any direct identification by
name or other means.

C. Each investigative report shall be identified by a case number, unique to the
respective case. The case number will appear on all documentation relative to
each investigation. The case number format shall be: two (2) digits for the
year, a hyphen, then digits for the Julian calendar date followed by another
hyphen and a three (3) digit sequence control number. Example: 96-0131-
001, the preceding number indicates this is January 31, 1996 and the sequence
control number indicates this is the first case for this date.

VI. CONFIDENTIALITY OF INVESTIGATIONS

A. In conducting an investigation, the Isleta Gaming Commission or its’ agents
will keep confidential the identity of each person or entity interviewed in the
course of the investigation. , :

B. During the course of any Commissici Investigation, Isleta Gaming Operation
employees, other persons, or entities that are interviewed must maintain the
confidentiality of the subject matter discussed with the Commission or its’
Investigator(s) and shall not breach this confidentiality to any third party

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission

Regulations

TABLE OF CONTENTS
2. Grievance Form 4
(on Step HI. 4
Dz. Step IV. 4
1. Petition 4
2. Contents of a Formal Petition ------------------------------------ 5
3. Hearing 5

4 Minimum Procedural Requirements
of a Formal Hearing 5
5. Final Determination 6
E. Step V. 6
NOTE 6
Commission Certification 7

Chapter 9: Concession & Restaurant Health Standards

I
I.
Til.
IV.
Vv.

VI.

Vil.
VI.
Ix.

Commission Certification

Authority
Purpose
Scope
Department of Health and Human Services
Food Service Establishment Inspection Report -----------------—--------------~
A. 75 Points and Below -----
B. 76 Points and Above
State of New Mexico Department of Environment --
A. Inspection
Enforcement Activity --
Notice of Disciplinary Action for Policy Violations ---------------—--------—-
Acknowledgments ~

Chapter 10: Alcohol

2BR

Authority
Purpose
Scope
Alcohol Procedures
A. Sale of Alcohol ----
B. Alcohol Education
Cc Certification

Seemepmeanmuancesaaane’

WNNNNNN


from the regulations shall be approved by Tribal Council prior to their
effectiveness.

. The Isleta Gaming Regulatory Agency shall exercise such other authority,
carry out such other responsibilities and perform such other duties as may be
necessary to assure that the conduct of Pueblo Gaming is in compliance with
all applicable laws affecting the conduct of gaming.

Article IV — Miscellaneous

. The Isleta Gaming Regulatory Agency shall act as the independent gaming
regulator of all Pueblo Gaming and shall maintain the highest standards of
integrity and diligence in its work. No member of Tribal Council shall serve
as Executive Director or be employed by the Isleta Gaming Regulatory
Agency during the term of his or her service as a Tribal Council person.
Neither the Executive Director nor any staff member of the Isleta Gaming
Regulatory Agency shall receive any compensation or other valuable
consideration from the Gaming enterprise of the Pueblo of Isleta as an
employee, agent or vendor, or as an employee, agent or owner of any such
vendor. The Executive Director and the staff of the Isleta Gaming Regulatory
Agency are employed by the Pueblo of Isleta Tribal Government and are not
employed by the Gaming enterprise. Neither the Executive Director nor staff
of the Isleta Gaming Regulatory Agency shail participate in any form of
Pueblo Gaming during the period of their employment with the Isleta Gaming
Regulatory Agency.

. Unless expressly authorized by Pueblo of Isleta Tribal Council Resolution, the
Isleta Gaming Regulatory Agency may not:

1. Enter agreements of any kind for the Pueblo.
. Pledge the credit of the Pueblo.

3. Dispose of or encumber real or personal property of the
Pueblo.

4. Waive any right of, or release any obligation owed to the
Pueblo of Isleta.

5. Waive any other rights, privileges, or immunities of the
Pueblo of Isleta.

6. Approve unbudgeted expenditures.

. Actions of the Isleta Gaming Regulatory Agency with respect to the denial,
suspension or revocation of any gaming license of any employee of, or vendor
doing business with, the Pueblo’s Gaming enterprise shall be subject to review
under the Gaming License Review Procedures established by Resolution 01-
104.

. The Isleta Gaming Regulatory Agency as an integral part of the Tribal
Government of the Pueblo of Isleta shall possess sovereign immunity of the
Pueblo from suit, except as may otherwise be specifically approved by the
Tribal Council of the Pueblo of Isleta.

Page 4 of 5


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 15

Race and Sports
Book ~

(Computerized)


Chapter 4

Gaming Equipment or Devices or Supplies Page 10 of 13

all such data be electronically accessible to the State Gaming
Representative upon entry of appropriate security codes.

G. Gaming Supply Purchasing

1,

For purposes of purchasing supplies for Gaming, the Nevada
Standards, Regulation 14 will be adhered to.

For purposes of purchasing and disposing of EGD’s, the Johnson Act,
the Transportation of Gambling Devices Act, and IGCR, Ch. 13,
Surplus Palace Property shall be strictly adhered to.

For purposes of purchasing supplies for Gaming, the Isleta Gaming
Operation, Standard Operating Procedures (SOP’s) Manual,
Purchasing will be strictly adhered to.

The purchase, removal, storage, replacement, and/or relocation of any
EGD must be in compliance with IGCR, Ch. 17, Notification to the
Commission (V)(A). : -

See IGCR, Chapter 18, Code of Conduct, for details on Conflict of
Interest, hereto.

See IGCR, Chapter 5, Licensing, for details on Vendor licensing
procedures, hereto.

See IGCR, Chapter 17, Notification to the Commission, for details on
Casino Games, Contracts, Construction, etc., hereto.

NOTE: Attached herein are copies of adopted State of Nevada Standards,
Regulation 14 for Gaming Equipment or Devices or Supplies.

Vv. EXCEPTIONS

A. Emergencies

1.

Commission agents are available and on-call twenty-four (24)
hours a day seven (7) days a week in the event of an emergency.
The Palace Security Office has an Emergency Contact List for the
Commission in which any Agent may be reached via pager and/or
home phone number. °

All emergency situations must be immediately brought before the
Isleta Gaming Commission aid will be’ considered on a case-by-

Isleta Gaming Commission Regulation Revised December 16, 1999



Chapter 15
Race and Sports Book Computerized Page 11 of 16

and compared to an independent source for extravagant or
questionable activity. .

B. For all voided tickets:

1. The computer reports which display voided ticket information
are examined to verify that tickets were properly voided prior
to the cutoff time for event wagering.

2. The voided tickets are examined for the word “VOID” and
proper signatures.

Cc. The book’s computerized summary of events/results report is
traced to an independent source for 5% (five percent) of all sporting
events and 5% (five percent) of all races to verify the accuracy of
starting times (if available from an independent source) and final
results.

D. Exception reports are reviewed on daily basis for propriety of
transactions and unusual occurrences.

E. Any investigation performed regarding the exception reports is
documented.

F. At least one day per calendar quarter, the computer-generated
reports are reviewed for proper handling of future wager, unpaid
winners, and telephone accounts.

XV. STATISTICS
A. Reports are maintained for each month and year-to-date which
indicate the total amount of wagers accepted, total amount paid out

on winning wagers, the net amount won by the book, and the win-
to-write percentage for:

1. Each sport (e.g., baseball, basketball, football, hockey, golf,
boxing, etc.) as required by industry standards.

2. Sports parlay cards...

3. Horse racing. *

Isleta Gaming Commission Regulation Revised December 16, 1999



Chapter 5
Licensing Page 26 of 35

in writing, of the reasons for this suspension and that upon the
conclusion of the investigation, the Commissions will issue a written
determination to either lift the suspension or revoke the license.

d. The Commission investigation must be completed within ten (10)
business days from the U. S. Post Mark date noted on the envelope of
the Notice of Suspension.

e. After the Suspension procedures are completed, the Commission must,
within forty-eight (48) hours of the completion of the investigation,
render a decision to either lift the suspension or revoke the license. The
Commission shall, within twenty-four (24) hours of this decision,
inform the licensee, via certified mail return receipt requested, of the
reinstatement or issue a Notice of Revocation of Gaming License.

f. Ifthe suspension is lifted, the licensee is to follow the Reinstatement
procedures under Article XIV(C) Reinstatement, herein.

g. Ifthe suspension is not lifted and the decision of the Commission is to
tevoke, then the license shall be revoked immediately.

h. As an alternative to suspending a license, the Commission may impose
fines or lesser penalties on all licensees. The Commission may also
place conditions or restrictions on the retention of any license.

B. Revocation

1. A Gaming License is a revocable privilege, and no holder thereof shall be
deemed to have acquired any vested rights therein or thereunder. The
burden of proving qualifications to hold any license rests at all times on
the licensee. The Commission is charged by law with the duty of
observing the conduct of all licensees to the end that licenses shall not be
held by unqualified, disqualified, or unsuitable persons or entities.

2. The Commission shall revoke a Gaming License, of any form, if there is
reasonable evidence indicating that the licensee is no longer eligible to
participate in the gaming operation of the Pueblo of Isleta under the
requirements of Article IX, herein. Without limiting the foregoing, the
Commission may revoke a 2 Gaming License on any of the following
grounds:

a. Evidence of an untrue or misleading statement of, willful omission of,
or concealment of any material fact, in any application, statement, or
notice filed with the Commission or made in connection with any

Isleta Gaming Commission Regulation Revised December 01, 1999


Chapter 5
Licensing Page 35 of 35

RTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo.of Isleta Gaming
Commission Regulations, Chapter 5, Licensing, was duly REVISED, ORDAINED, .
ADOPTED, AND RATIFIED on this the “1st_ day of December, 1999, at a duly called .
meeting of the Gaming Commission of the Pueblo of Isleta, at which a quorum was
present, with 2 voting for, _0_ voting against, and _0_ abstaining.

Vacant

Chairman

Hide. - ~
YATRICIA L. JERON .

Vice-Chairman

. Subscribed and sworn before me on this the _Ist_ day of December, 1999.

Ce) = ODESSA AN MONTOVA Lb L U WV.

Aly commission exes: 2M

_(,

My Commission Expires:

Isleta Gaming Commission Regulation Revised December 01, 1999


NATIONAL
INDIAN
GAMING
Commission

APR 18 2000

Emest C. Jaramillo

Chairman, Pueblo of Isleta

11000 Broadway, SE
Albuquerque, New Mexico 87105

Dear Chairman Jaramillo:

This letter responds to your January 24, 2000, submittal of the Revised Pueblo of Isleta
Regulations (Regulations). This letter constitutes approval of your submission under
the Indian Gaming Regulatory Act (IGRA). It is important to note that the Regulations are
approved for gaming only on Indian lands as defined in the IGRA, over which the
Pueblo of Isleta exercises jurisdiction.

Thank you for submitting the Regulations of the Pueblo of Isleta. The NIGC staff and I
look forward to working with you and the Pueblo in implementing the IGRA. If you have
questions, please contact Ms. Frances Fragua at 202/632-7003.

Sincerely yours.

Menu

Montie R. Deer
Chairman

1441 L_ STREET, NW. _STHFLOOR WASHINGTON, D.C. 20005 TEL: 202-632-7003 FAX: 202-632-7066



Chapter 9
Concession & Restaurant Health Standards Page 2 of 6

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the health and safety of Palace patrons and
employees. The Pueblo of Isleta grants this authority to the Isleta Gaming Commission
pursuant to Resolution 95-03 enacted January 28, 1995 and any ordinance adopted
thereto.

Il. PURPOSE

The purpose of this regulation is to provide a comprehensive guideline of health
and safety standards, which shall be followed by all Isleta Gaming Operations Food and
Beverage Department, i.e. Concessions and/or the Restaurant, management and
employees. Further, this regulation will specifically enumerate the manner in which the
Commission will exercise said authority in its oversight of all Isleta Gaming Operations
Food & Beverage activity. In applying this authority to the Food and Beverage
operations, the Commission shall act in a responsible and consistent manner when
promulgating, adopting, approving, revising, implementing, administering, and enforcing
the rules, regulations, policies, and decisions of the Commission.

I. SCOPE

This regulation applies to all Food and Beverage Operations located within a
Pueblo of Isleta Gaming Operation or on the premises thereof. The Commission retains
jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
resolution adopted thereto, the Indian Gaming Regulatory Act, and the Isleta/State of
New Mexico Indian Gaming Compact. This regulation does not apply to other tribal
entities or agencies within the Pueblo of Isleta Tribal Government.

IV. DEPARTMENT OF HEALTH AND HUMAN SERVICES

Since the Pueblo of Isleta Gaming Palace resides solely within the boundaries of
the Pueblo of Isleta, the State of New Mexico Health Inspectors have limited jurisdiction
within the Isleta Gaming Operation and therefore, have only the authority to inspect the
Concession and Restaurant kitchens per the Pueblo of Isleta/State of New Mexico Indian
Gaming Compact. The Department of Health and Human Services, a federal agency,
does have inspection authority. Working out of the Indian Health Service (IHS) Offices,
located in Albuquerque, New Mexico, federal health inspectors regularly scrutinize the
Food and Beverage/Concession and Restaurant kitchens. Though the Indian Health
Service (IHS) may not have the direct authority to change kitchen conditions through its
findings, there is an abundance of case law, particularly, Blue legs v. United States
Bureau of Indian Affairs 867 F.2nd 1094 (8th Cir. 1989), which suggests IHS may
seek recourse through other federal agencies, i.e., the Department of Justice.

Isleta Gaming Commission Regulation . Revised December 16, 1999


Chapter 17
Notification to the Commission Page 5 of 12

4. Written internal controls and procedures for how the Isleta Gaming
Operation intends to manage, internally and externally, the flow of
construction workers to assure that the security and integrity of
Pueblo assets are not compromised and/or jeopardized in any way.
The aforementioned documents must be, in writing, deemed in
compliance by the Commission prior to commencement of any
construction/modification to any Gaming Facility.

5. The Isleta Gaming Palace must notify all vendors (including, but
not limited to, Architect firms, Contractors, Subcontractors,
Suppliers, etc.) that a license application must be filled out and
received by the Commission thirty (30) days prior to any business
transactions or dealings with the Isleta Gaming Palace or its
subsidiary(s). All Isleta Gaming Commission Licensing
Procedures will be strictly adhered to (See JGCR, Chapter 5,
Licensing).

6. All construction/modification to any Gaming Facility must follow
safety and construction standards at least as stringent as the current
editions of the National Electrical Code, the Uniform Building
Code, the Uniform Mechanical Code, the Uniform Fire Code, and
the Uniform Plumbing Code (See, Pueblo of Isleta/State of New
Mexico Indian Gaming Compact, August 29, 1997 also see,

IGCR, Chapter 3 and Chapter 5, hereto).

7. All individuals and entities involved in the construction/
modification of any Gaming Operation Facility and/or
premises must strictly adhere to all Security Procedures. No
Exceptions (See Isleta Gaming Palace Standard Operating
Procedures Manual, Security Procedures).

Cc. Modification/Alteration of Standard Operating Procedures (SOPs)

It is the responsibility of the Isleta Gaming Operation Management to
notify the Isleta Gaming Commission of any and all modifications and/or
alterations to the Isleta Gaming Operation, Standard Operating Procedures
(SOPs). Prior to the aforementioned modification and/or alteration being
implemented by the Operation, the following procedures must be
completed:

1. Draft the suggested policy/procedure in accordance with the
existing Isleta Gaming Operations Manual/Standard Operation

Isleta Gaming Commission Regulations Revised December 16, 1999


Chapter 12
Marketing & Promotions Page 6 of 6

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 12, Marketing & Promotions, was duly REVISED,
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with _2_ voting for, 0 voting against, and _0_ abstaining.

Vacant

Chairman

(x L. sis

Vice-Chairman

L A Deauubl

Vy
ERNEST C/J. LO
Secretary-

Se EE

Subscribed and sworn before me on this the __16th_ day of December, 1999.

memeworon) ) (yyy #- Mandiele

omnia J¢, 2602. NOTARY

My Commission Expires: ny ik, WINNS

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 15
Race and Sports Book Computerized Page 9 of 16

e. Time of exception.
f. Summary of exception (list sorted by exception type).

5. Results report (daily):

a. Date and time of event per the cutoff time input to the
computer.

b. Team names and team and animal number.

c. Event results and any other relevant payoff date.

6. Daily recap report:

a. Date.
b. Total.
1. Cash write for the day.
2. Futures written for the day.
3. Futures brought back into revenue (today’s
event).
Accrual writ-(1) less (2) plus (3).
_ Cash paid out on prior day’s events.
Cash paid out on today’s event.
Cash payouts for the day.
Unpaid tickets for the day.
. Accrual payouts-(6) plus (8).
10. Unpaid winners brought back into revenue.
11. Taxable revenue-(4) less (7) or (1) less (7).
12. Book (accounting) revenue- (4) less (9) plus

PON AAA

(10).
7. Personnel access listing:
a. Name. :
b. Employee identification number.
c. Listing of functions employee can perform or

equivalent means of identifying same.
XII. ACCOUNTING AND AUDIT FUNCTIONS
A. The race and sports book accounting and audit procedure are

performed by personnel who are. independent of the transaction
being audited/accounted for.

Isleta Gaming Commission Regulation vo :. Revised December 16, 1999


of Isleta Ordinance of Tribal Law: Permitted Gaming, adopted September 23,
1997, including the backgrounding and licensure of all employees and other
persons requiring to be licensed under said ordinances, and shall assure
compliance with such ordinances by the Pueblo of Isleta, its Gaming
enterprise and any and all other persons involved in or associated with Pueblo

Gaming.

. The Isleta Gaming Regulatory Agency shall perform on behalf of the Pueblo
of Isleta any and all gaming regulatory duties required by, and shall assure
compliance with, the Indian Gaming Regulatory Act, the regulations and
authoritative rulings of the National Indian Gaming Commission, and the
minimum internal control standards established by the National Indian
Gaming Commission.

. The Isleta Gaming Regulatory Agency shall act as the Tribal Gaming Agency
described in the Pueblo of Isleta’s Class III Gaming Compact with the State of
New Mexico, shall exercise the authority, carry out the responsibilities and
perform the duties of the Tribal Gaming Agency specified in the Compact,
and shall ensure that Class III Pueblo Gaming is conducted in accordance with
the Compact.

. The Isleta Gaming Regulatory Agency shall exercise the authority, carry out
the responsibilities and perform the duties of the Pueblo of Isleta Gaming
Commission described in the existing regulations of the Pueblo of Isleta
Gaming Commission, Chapters 1-21. Any and all references within said
regulations to the authority, responsibilities and duties of the Gaming
Commission or individual Commissioners shall henceforth be deemed to refer
to the Executive Director. Executive Director may delegate such authority,
responsibilities and duties specified in said regulations to members of the
Isleta Gaming Regulatory Agency staff as necessary and appropriate to carry
out the Isleta Gaming Regulatory Agency’s responsibilities and duties with
respect to the regulation of Pueblo Gaming.

. The Isleta Gaming Regulatory Agency shall ensure that the Pueblo’s Gaming
enterprise establishes internal controls that are at least as restrictive as the
National Indian Gaming Commission minimum internal controls, and shall
provide regulatory oversight to assure compliance with established internal
controls.

. On or before June 30, 2002, the Isleta Gaming Regulatory Agency shall
propose such revisions to the Isleta Gaming Commission Regulations
currently in effect as shall be necessary and appropriate to reflect the
assumption of gaming regulatory responsibilities and duties by the Isleta
Gaming Regulatory Agency and the delegation of gaming regulatory authority
to the Isleta Gaming Regulatory Agency by Tribal Council. The Isleta
Gaming Regulatory Agency may also propose from time to time such
amendments, supplements and deletions from the regulations as the Executive
Director may determine to be necessary or appropriate for the effective
regulation of Pueblo Gaming. All amendments, supplements and deletions

Page 3 of 5


Pueblo of Isleta Gaming Commission’

_ Regulation —©— a
TABLE OF CONTENTS
Chapter 18
Code of Conduct

I. Authority 2
IL. Purpose 2
Ill. Scope 2
IV. _ Definitions 2
V. Code of Conduct and Personal Conduct 4
VI. Conflicts of Interest 5

A. Employee 5

B. Vendor 7

Cc. Commissioner’s, Commission Staff, and Tribal Officials ------------' 8
VII. Outside Employment 9

A. Employees 9

B. Commissioner’s and Commission Staff --------------------------------- 10
VII. Enforcement Activity 11
IX. Notice of Disciplinary Action For Policy Violations ----------------------- --—-11
Xx. Acknowledgments 12

Commission Certification 14



Chapter 19
ID Badges Page 6 of 13

The Pueblo of Isleta Logo;

The words Pueblo of Isleta Gaming Commission;
The words, Temporary Vendor Permit;

The name of the vendor,

Issue Date;

Expiration Date;

Authorized by: (insert Chairman’s name)

mmone op

NOTE: The Commission, in its discretion, may choose not to issue a
Temporary Vendor Permit if the time in processing the
background check is immediate or minimal.

3. All Vendor License Certificates (Permanent ID Badges) will
consist of the following information:

The Pueblo of Isleta Logo;

The words, Pueblo of Isleta Gaming Commission;
The words, Vendor License Certificate;

The name of the vendor;

Issue Date;

Expiration Date;

License Certificate Number;

Authorized by: (insert Chairman’s name)

Poe mono op

4, All vendor ID Badges must be worn on the front torso above the
waist, but no higher than the neck. Vendor ID Badges may not
be worn on arms or attached to short sleeves, etc.

5. All vendors must visibly wear their ID Badge at all times while
on the premises or inside the facility of any Isleta Gaming
Operation (See Number 3 above). This includes, but is not limited
to, working hours, mandatory meetings or training’s taking place
on any Isleta Gaming Operation premises, etc.

6. No vendor is allowed on the premises or in the facility of any Isleta
Gaming Operation without an ID Badge. No exceptions!

7. Vendors shall not wear any ID Badge not issued to that particular
vendor.

8. Only the Isleta Gaming Commission may issue a Vendor ID
Badge.

Isleta Gaming Commission Regulation Revised December 16, 1999


~Chapter 9
Concession & Restaurant Health Standards “~~” Page 3 of 6

Vv. FOOD SERVICE ESTABLISHMENT INSPECTION REPORT

IHS has employed an inspection report during its visits to the Palace. The report
utilizes one-hundred (100) point scale. The closer the facility gets to zero (0) on this
scale, the more serious the health infractions. Through this regulation, the Pueblo of
Isleta Gaming Commission hereby adopts the standards set forth in this inspection report.
The Isleta Gaming Operation Food and Beverage Department, i.e. Concessions and the
Restaurant shall now abide by the following:

A. 75 Points and Below : wey

If in any inspection period the Concessions and/or Restaurant accumulated
points on the Inspection Report are seventy-five (75) points or less, the
Commission shall have the prerogative to immediately close all business
in the Concessions and/or Restaurant until the Commission is satisfied that
Concessions and/or the Restaurant can operate within acceptable health
and safety parameters.

1. Management

If Concessions and/or the Restaurant receives two consecutive
reports totaling seventy-five (75) points or less,

The Commission shall consider revocation of the Kitchen
Manager’s and Assistant Kitchen Manager’s license for failure to
carry out this Regulation and/or Palace Policy.

B. 76 Points and Above

Any other infractions involving seventy-six (76) points or higher shall be
considered on a case-by-case basis by the Commission. The Commission
may implement, but shall not be limited to, the above-mentioned remedies
in responding to any and all health violations within the Palace
Concessions and/or Restaurant.

VI. STATE OF NEW MEXICO DEPARTMENT OF ENVIRONMENT
A. Inspection

1. State of New Mexico Department of Environment Inspectors will be
permitted to inspect any Gaming Facility’s food service operations
during normal Gaming Facility business hours to assure that standards
and requirements equivalent to the State’s Food Service Sanitation Act
are maintained.

Isleta Gaming Commission Regulation . __ Revised December 16, 1999



Chapter 3

Gaming Participation & Operation Page 6 of 7

VO. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management, Employees, and Vendors of any Isleta Gaming
Operation are subject to the following action:

1. Refusal to comply or Fine, denial, suspension,
violation of this policy. revocation, termination
of and/or restrictions on
Gaming License.

VI. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Isleta Gaming Operation(s). Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or any employee, of any employment or any
continued employment whatsoever, nor shall any provisions of this Regulation constitute
or be interpreted by any party or tribunal to constitute any contractual rights of
employment expressed or implied, or any obligation of employment rights created by
covenants of good faith and fair dealings, either expressed or implied.

Vendor compliance with this Regulation is a condition of performing business at
or with the Isleta Gaming Operation(s). Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or vendor, of any business dealings or any
continued business dealings whatsoever, nor shall any provision of this Regulation
constitute or be interpreted by any party or tribunal to constitute any contractual rights of
business expressed or implied, or any obligation of business rights created by covenants
of good faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees and vendors responsibility.

To the fullest reasonable extent possible, confidentiality is to be maintained in all
applications of this Regulation. ;

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, from time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation . .._ Revised December 16, 1999


ID Badges

Chapter 19
Page 8 of 13

10.

11.

12.

All Commission ID Badges must be on the Commissioners or
Commission staff members “person” at all times while on the
premises or inside the facility of any Isleta Gaming Operation.

Commissioners and Commission staff members shall not wear, for
any reason, any ID Badge not issued to that particular individual.

Only the Isleta Gaming Commission may issue a Commission ID
Badge.

In the event a Commissioner or Commission staff member neglects
to bring their ID Badge to work. That individual must be
immediately sent home to obtain and return with their ID Badge.

In the event a Commissioner or Commission staff member is called
into work for an emergency situation and neglects to bring their

ID Badge, identification, in the form of a Drivers License, etc., to
the appropriate Security Department Official shall suffice and a
Visitors Badge will be issued thereto.

The Commissioner’s and their designated agents have unrestricted
access to all areas of any Pueblo of Isleta Gaming Operation.
Therefore, it is imperative that the Security Department verify the
identity of all individuals carrying a Commission ID Badge,
through visual observance or, if necessary, detainment of said
individual before allowing access to such sensitive areas.

In the event a Commissioner or Commission staff member,
voluntarily or involuntarily terminates their employment with the
Isleta Gaming Commission, the issued ID Badge must be returned
to the Isleta Gaming Commission before any final paycheck is
issued to the individual. Thereafter, the issued ID Badge is to be
kept in that staff members individual Commission file.

VI. ISSUING ID BADGES

A. Employee

1.

At the time of application and coinciding with the issuance of a
Temporary Work Permit (See IGCR Chapter 5, Licensing), a
Temporary ninety (90) day Employee ID Badge will be issued to
the applicant, pending the completion of a favorable preliminary
background investigation. (See Section V, A(2), above)

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 6": .
Investigative Procedures Page 6 of 8

3. The person collecting the evidence shall create an evidence log for all
evidence collected during an investigation as follows:

a. This log shall contain a description of the evidence;

b. Date and time evidence was collected;

c. Location evidence was collected from.: If necessary, a photograph
shall be taken to indicate exact location of evidence when
collected.

4. All evidence collected shall be sealed in plastic bags and a chain of
evidence log shall be created for all items collected in the furtherance
of a particular investigation.

5. All evidence shall be secured by the Gaming Commission Investigator
ina locked and safe place.

a. If any of the items is handled or removed from this secured area, the
person handling or removing said item(s) shall sign a log listing the
date, time and reason for handling and/or removing items.

1. The above log shall be maintained and shall be kept in the
custody of the Gaming Commission Investigator at all times
relevant to the investigation. ‘

6. Only persons authorized by the Commission may have access to
evidence in an ongoing or concluded investigation.

C. The Commission Investigation Division shall secure, as necessary and
appropriate, the scene of any crime or suspicious activity.

1. The Investigative Division shall collect any evidence found at the scene
and develop a list of suspects, possible suspects, witnesses, and
possible witnesses to be interviewed at the discretion of the Lead
Investigator.

a. Within a reasonable time, the Lead Investigator or their
designee(s) assigned by the Commission shall interview and/or
interrogate witnesses or suspects.

b. The most likely suspect(s) shall be interrogated last.

D. Within a reasonable time, the Gaming Commission Investigator shall
conclude the investigation and the facts, interviews, and evidence shall be

Isleta Gaming Commission Regulation ; Revised December 16, 1999



Chapter 18

Code of Conduct Page 9 of 14
6. A Commissioner, Commission staff member, or Tribal Official
will not perform, propose to perform, or participate in any business
transaction directly with an immediate family member who is a
vendor to or employed by the Isleta Gaming Operation.
7. All Commissioners, Commission staff members, and Tribal

Officials are strictly prohibited from giving or offering or
proposing to offer any compensation, loan, gift, gratuity, benefit,
or unusual hospitality of any value to another Commission staff
member, Tribal Official; or Isleta Gaming Operation employee,
vendor, or patron with whom they are performing any activity or
transaction.

VII. Outside Employment

A. Employees

1.

In general, outside employment is an approved activity if:

a. it is in a field not directly related to the Isleta Gaming
Operation,

b. it will not interfere with the proper and effective
performance of an individuals duties performed for the Isleta
Gaming Operation,

c. it will not create or appear to create a conflict of interest,
and Doone

d. it will not subject the Isleta Gaming Operation to public
criticism or embarrassment.

When determining whether outside employment should be
approved or disapproved, the Isleta Gaming Operations General
Management should consider the following:

. current and past job performance,

. attendance and tardiness records,

.. the reliability of the employee,

. the appropriateness of the activity,

. possible embarrassment to Isleta; and

. all conflict of interest issues, i.e., Is it a field not directly related
to the worked performed for the Isleta Gaming Organization?

moaogp

Is it for a competitor of the Isleta Gaming Organization? Could —--—~~-———

confidentiality or proprietary information be an issue?

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 6

Investigative Procedures

IL. Authority
IL. Purpose -
I. Scope

IV. Definitions

Vv. Types of Investigations

A. Open Issue Investigation

B. Closed Issue Investigation
VI Confidentiality of Investigations

VII. Release of Investigative Information

VIII. Investigative Procedures
IX. Limitations on Investigations

|

Commission Certification

SCIYUMUARRWWNNNN


Pueblo of Isleta Gaming. Commission

Regulations
TABLE OF CONTENTS

Il. Scope 2
IV. Definitions 2
Vv. Policy ---- 3

A. Casino Games --3

B. Construction/Modification of Gaming Facility --------------------- —- 4

Cc. Modification/Alteration of Standard Operating ] Procedures (SOPs)--5

D. Contracts 7
VI Exception(s) 9

A. Emergencies 9
Vil. Enforcement Activity 10
VII. Notice of Disciplinary Action for Policy Violations --------------------------- 10
IX. Acknowledgments 10
Commission Certification 12

S<35RT

Vil.

ix.
Xx.

Commission Certification

Chapter 18: Code of Conduct -

Authority 2
Purpose 2
Scope 2
Definitions 2
Code of Conduct and Personal Conduct 4
Conflicts of Interest 5
5
7
8
9
9

A. Employee
B. Vendor
Cc. Commissioner’s, Commission Staff, and Tribal Officials ------------
Outside Employment
A. Employees
B. Commissioner’s and Commission Staff --------------------------------- 10
Enforcement Activity
Notice of Disciplinary Action For Policy Violations ----
Acknowledgments

Chapter 19: Identification (ID) Badges

I
I.
Ill.

Authority - : 2
Purpose - --2
Scope . . 2



Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 19

Identification (ID) Badges


Licensing

Chapter 5
Page 7 of 35

for a Gaming License, Temporary Work Permit, etc. Therefore, one of the
following forms of identification are acceptable and must be presented, along
with a Social Security Card when applying for and processing a Gaming
License Application: u

1, Any valid picture ID card issued by aU. 8. Federal Agency, i.e. Resident
Alien Card, Naturalization Certificate, Military ID, etc.

2. A valid Driver’s License or picture ID card issued by the Motor Vehicle
Division of any State of the United States.

3. A membership ID card issued by any Tribal Government of a Federally
recognized Indian Tribe (picture ID preferred).

4. No other ID card is acceptable for the purpose of positive identification.

5. Individuals must present their Social Security Card upon applying for a
Gaming License. Social Security Cards are required to verify an
Applicant’s Social Security Account Number, trace verification, and to
access the motor vehicle division records.

6. In the case of vendor applicants, only the agent signing off on the Gaming
License Application must present a valid ID and Social Security Card.

At any time before the completion of a background investigation under Article
VIII of this Chapter, an applicant may petition, in writing, to amend the
information provided in the application to the Commission.

Each application shall be accompanied by the nonrefundable licensing fee or
an acceptable arrangement for payment of the fee required under Article VI,
herein.

. It is the responsibility of all applicants (employee or vendor) to inform the

Commission, by way of written amendment, of any change(s) to an
application immediately as may occur. This includes, but is not limited to,
name, address, phone number, ownership, other pertinent information asked in
the application, etc. This responsibility shall remain in effect from the time
the license application is submitted to the Commission until such time said
license expires or is otherwise terminated.

. An application is not considered complete until all information requested is

provided to the Gaming Commission. If the application is incomplete or if the
applicant fails to promptly provide any addition material requested, the license

Isleta Gaming Commission Regulation . Revised December 01, 1999



Chapter 16
Gifts, Gratuities, & Solicitations aa Page 4 of 9

Gratuity - A favor, gift, anything of value, or any benefit for which fair market
value is not paid. It can include, but is not limited to, entertainment, meals,
beverages, recreation, hospitality, transportation, discounts, tickets, passes, and
promotional training.

Kickback - A sharp reaction; a repercussion. Including but not limited to a return
of a percentage of a sum of money already received, usually as a result of
coercion or a secret agreement. Payment back by seller of a portion of the
purchase price to buyer or public official to induce Purchase or to improperly
influence future purchases or leases. * © *

Management - The act, manner, or practice of managing; handling, supervision,
or control of the Isleta Gaming Operation(s). The person or persons who control
or direct the Isleta Gaming Palace, its subsidiary(s), or any part of the Gaming
Operation/enterprise.

Patron - one who buys goods and services; a customer, internal or external.

Solicitation - Asking; enticing; urgent request. To seek, to obtain by persuasion,
entreaty, or formal application. To petition persistently; importune. To entice or
incite, to evil or illegal action. To approach or accost (a person) with an offer of
sexual services or encouraging someone to engage in illegal conduct. The crime
solicited need not be committed.

Tribal Official/Government Official - pertains to the Tribal Council member(s),
Tribal Judge(s), Tribal Administrator(s), Governor, Lieutenant Governor(s),
Tribal Treasurer, Commissioners, and Commission agents.

Tribal entities - Tribal Planner, Law enforcement, Emergency Medical
Services/Fire Department, officials and/or inspectors.

Vendor - including but not limited to, a merchant, retail dealer, supplier,
importer, wholesale distributor, corporation, entity; one who buys to sell; a
seller. A seller of goods, products, and services.

Vv. GIFTS AND GRATUITIES
A. General

Any Official (Tribal/Commission/Management/other) or employee or
agent or person or entity acting for or on behalf of the Isleta Gaming
Palace or its subsidiary(s) will not accept any gift and/or gratuity, in any
form whatsoever that might appear to be a solicitation, kickback,
enticement, rebate, refund, “perk”, or any other incentive “under the

hae

Isleta Gaming Commission Regulations . . Revised December 16, 1999


Chapter 7
Patron Dispute Resolution Page 4 of 5

period rule, above. The following will be included in any
such written Request or Notice of Hearing:

1. The Commission shall give each party fifteen (15)
business days from the date of receipt of said notice,
to provide the Commission with all additional
requested information.

2. Interested parties may request, in writing within the
initial fifteen days, that the Commission allow
additional time to submit the requested information.
Any additional time allowed will be at the
Commissions discretion.

3. Ifno Request for additional time is submitted or the
additional time sought by the interested parties has
lapsed and the requested information is not
forthcoming, the Commission shall make a
determination on the dispute/grievance using only
the information in its possession and no other.

B. Formal Hearing by Commission on Patron Dispute

1. If the Commission deems it necessary to grant a formal hearing on
the dispute/grievance, the NOTICE shall include the date, time,
and place of the Hearing. This Hearing date shall transpire no later
than thirty (30) regular days from the U. S. Postmark date on the
notice. :

2. Additionally, the notice shall include information on procedures to
be followed by interested parties during the hearing.

3. The Commission’s decision is final.
VI. Self Identified Problem Gamblers .:

In the interest of protecting the Isleta Gaming Operation from personal
injury litigation, any patron who identifies them self, to Palace employees,
as having a gambling problem shall be permanently banned from all Isleta
Gaming facilities. Isleta Gaming Operation employees and/or managers
shall document every relevant fact pertaining to any such incidents. Any
disputes arising out of this action should be forwarded toth€ Commission
immediately.

Isleta Gaming Commission Regulation cat Revised December 16, 1999


Chapter 17
Notification to the Commission Page 8 of 12

REMINDER: All Contracts must be signed prior to any business
transaction taking place. If the contract is for $25,000.00 or more
it must have a Tribal Council Resolution attached, no exceptions.
(See Subsection 7, herein, below)

2. Any additional pertinent documentation, i.e. subcontract, costs
involved, detailed plans, etc.

3. The Commission, upon receipt, shall have thirty (30) days to
review such contracts or agreements. The Commission shall
inform the Isleta Gaming Operations Management, in writing, as to
whether or not the contract or agreement is in compliance.

4. If the contract or agreement is not in compliance, the Commission
reserves the right to have Isleta Gaming Operation Management
renegotiate said contract or agreement. The Commission reserves
the right to place any contract or agreement on hold pending a
satisfactory and equitable negotiations between the parties. After
negotiations have occurred the contract or agreement must be
resubmitted to the Commission for an additional compliance
review prior to the execution of said contract or agreement.

5. In the event that a contract or agreement contains some sort of
management clause, the Commission must, per NIGC Regulations,
submit any such contract or agreement to the National Indian
Gaming Commission for review, which may take an additional
thirty (30) days to be reviewed and deemed in compliance.

6. Isleta Gaming Operations Management must, after a contract or
agreement has been deemed in compliance and signed, submit a
signed copy to the Commission.. If the contract or agreement was
for an amount of twenty-five thousand dollars ($25,000.00) or
more it must also have a signed copy of the Tribal Council
Resolution attached.

7. All contract in the amount of twenty-five thousand dollars
($25,000.00) or more must have a signed Tribal Council
Resolution attached, authorizing and accepting said contract. Only
the Pueblo of Isleta Governor has the authority to sign such a
contract(s) or agreement(s) in order for it to be valid and
implemented. [See Pueblo of Isleta Tribal Constitution, Article IV,
Section 5, (f)) lee

Isleta Gaming Commission Regulations Revised December 16, 1999


Chapter 16
Gifts, Gratuities, & Solicitations Page 3 of 9

Bribery - The offering, giving, receiving, or soliciting of ‘something of value for
the purpose of influencing the action of an individual or official in the discharge
of his or her public or legal duties pertaining to or within the Gaming Operation.

The corrupt tendering or receiving of a price for official action pertaining to
or within the Gaming Operation.

Any gift, advantage, or emolument offered, given, or promised to, or asked or
accepted by, any official or employee to influence his/her behavior pertaining to
or within the Gaming Operation.

Any officer or employee or person acting for or on behalf of the Isleta Gaming
Palace, or any department or agency or branch of the Isleta Gaming Palace
thereof, in any official function or capacity.

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

Commissioner(s) - means an officer/director (i.e., Chairperson, Vice-Chair,
Secretary-Treasurer) of the Pueblo of Isleta Gaming Commission. A person to
whom a commission is directed by the government or a court. An officer who is
charged with the administration of laws and regulations relating to some particular
subject matter, or the management of some bureau or agency of the government.
Member of a commission or board. Specially appointed officer of a government
or court.

Commission Staff - including but not limited to, a group of employees,
assistants, agents, and clerks to an officer, director, executive, or another person in
authority. The personnel who carry out a specific duty/duties in aide of or on
behalf of a Commissioner(s).

Ethics - Of or relating to moral action, conduct, motive, or character; as, ethical
emotion; also, treating of moral feelings, duties, or conduct; containing precepts
of morality; moral. Professionally right or befitting; conforming to professional
standards of conduct. \

Employee - A person in the service of the Isleta Gaming Industry under any
contract of hire, express or implied, oral or written, where the employer has the
power or right to control and direct the employee in the material details of how
the work is to be performed.

Gift - Anything of value bestowed voluntarily and without compensation.

Isleta Gaming Commission Regulations Revised December 16, 1999


Chapter 5:

Licensing _ Page 28 of 35

Commission for additional information required in any investigation;
m. Failure to follow and complete an issued Commission directive;
n. Circumvention of Commission authority;

o. Circumvention of any Commission Regulation, applicable gaming
laws, Isleta Gaming Operation Standard Operating Procedure,
applicable Federal, Tribal, or State laws;

hiapeee
p. Non-compliance with an Official Commission Investigation;

q. A single severe infraction or violation of any gaming regulation,
applicable gaming law, criminal law, policy, or procedure;

r. Excessive infractions or violations of any gaming regulation,
applicable gaming law, criminal law, policy, or procedure.

3. The Commission may revoke a license if the National Indian
Gaming Commission or the State Gaming Representative provides the
Commission with evidence indicating that the licensee is no longer
eligible to participate in the gaming operations of the Pueblo of Isleta
under the requirements of Article IX, herein, the Indian Gaming
Regulatory Act of 1988, the Pueblo of Isleta/State of New Mexico Indian
Gaming Compact, Isleta Tribal Ordinances, and other applicable Federal
laws.

4. Upon revoking a license, the Commission shall notify, in writing, the
licensee of:

a. the reason(s) for revocation;

b. that the licensee has ten (10) business days from receipt of
said notice in which to request, in writing, a Reconsideration
Review Hearing to be heard by the Commission; and

c. that failure to request the’ Reconsideration Review Hearing by the
tenth business day after receipt will result in the revocation being
final.

5. The Commission shall schedule the Reconsideration Review Hearing
within thirty (30) calendar days upon receipt of a Request for
Reconsideration Review. The Commission shall notify the licensee, in
writing, of:

Isleta Gaming Commission Regulation : «=. ° »* Revised December 01, 1999



Chapter 19
TD Badges Page 13 of 13

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulations, Chapter 19, Identification (ID) Badges was duly REVISED,
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with 2 voting for, _0 voting against, and _Q_ abstaining.

Vacant

Chairman

‘ATRICIA L. JI
Vice-Chairman

RNEST C.
ecretary-Treasurer

ATTEST ° S 2S

Subscribed and sworn before me on this the _16th_ day of December, 1999.

Mya #. 7 ntafe

Ta LETTE OF NOTARY /

J roman enclY ALY O85, ADL
My Commission Expires: TGs / id 202

OFFICAL ZAL

ODESSA A. MONTOYA

Isleta Gaming Commission Regulation Revised December 9g, 1999
eZ


Chapter 4
Gaming Equipment or Devices or Supplies Page 4 of 13

language of the manner in which the device operates,
-signed under penalty of perjury; and

2. A Statement under penalty of perjury that to the best of
the manufacturer’s knowledge, the gaming device
meets the Standards of Nevada, Section 14.040
(attached hereto) adopted by the Isleta Gaming
Commission on August 29, 1997.

3. Acopy of all executable software, including data and
graphic information, and a copy of all source code for
programs that cannot be reasonably demonstrated to
have any use other than in a gaming device, submitted
on electronically readable, unalterable media.

4. All Electronic Gaming Devices must be certified and
verified by Gaming Laboratories International (GLI).

3. Access to Electronic Gaming Device (EGD)

a. Slot Technicians will require the presence of a Security Guard
and/or a Commission Inspector, and Surveillance will be
notified as follows:

1. Removal of a hopper from the Casino floor for any
reason. This requires notification of Surveillance and
the presence of Security only.

2. Accessing the stacker in the bill validator. This
tequires notification of Surveillance and the presence of
Security.

3. Accessing the Logic Box or Logic Board. This requires
the notification of Surveillance and the presence of
Security. (See number 4 below)

4. Accessing Chips on any logic board. This requires the
notification of Surveillance and the presence of Security
and. the Commission. A Commissioner or their
designee must be notified and present prior to any
individual or entity gaining access to the Main Chip,
Personality Chip, and/or the Supplemental Chip(s)
residing on a logic board. No exceptions!

Isleta Gaming Commission Regulation Bi iweiiaee Revised December 16, 1999


Chapter 17

Notification to the Commission Page 4 of 12

All necessary support documentation, i.e., what the game entails,
how the game is played, odds of the game, par sheets, serial
numbers, model numbers, casino floor placement (plan)
schematic(s), machine‘number, and location number.

The Isleta Gaming Operation Management must notify all vendors
that a license application must be filled out and received by the
Commission thirty (30) days prior to any business transaction or
dealings with the Isleta Gaming Operation(s) or its subsidiary(s).
(See IGCR, Chapter 5 Licensing)

For sales of any outdated or unusable Isleta Gaming Operation
property, including, but not limited to, gaming equipment,
supplies, devices, etc., see IGCR, Chapter 13, Surplus Property.

NOTE: Also, see Isleta Gaming Operation, Standard Operating Procedures
Manual, Electronic Gaming Devices, Procedures for Transportation of
EGD’s and IGCR, Chapter 4 Gaming Equipment or Devices or Supplies.

B.

Construction/Modification of Gaming Facility

It is the responsibility of the Isleta Gaming Operation Management to,
notify the Isleta Gaming Commission of any and all construction or
modification to any Gaming Facility and/or the premises. Prior to any
commencement of the aforementioned construction/modification, the
following documentation must be given to the Commission at least thirty
(30) days in advance and on a continuous basis thereafter:

1.

A copy of any and'all proposed Contracts pertaining to the
intended construction/modification of or within the Gaming
Facility and/or the premises. This includes but is not limited to, all
contracts from Architects, Contractors, and/or Subcontractors.

REMINDER: All contracts must be signed prior to any work
taking place. If the contract is for $25,000.00 or more, it must
have a Tribal Council Resolution attached. No exceptions! (See
Section D. Contracts, 7, herein, below)

Copies of original Blueprints. All changes, as may arise during the
construction/modification, to the original blueprints must be given
immediately to the Commission.

All necessary support documentation pertaining to the costs,
contract, blueprints, etc.

Isleta Gaming Commission Regulations ‘ Revised December 16, 1999


Il.
Ill.
Iv.

VI.
VII.
VIII.
x.

X.
XI.

Pueblo of Isleta Gaming Commission
Regulations

TABLE OF CONTENTS

Chapter 20
‘Training Requiremen

Authority =
Purpose
Scope
Definitions
Policy -
A. General Manager
B. Upper Level Management --
Cc. Subordinate Employees
The Role of the Human Resource Department -------------------------~
Procedure for Distribution of Isleta Gaming Commission Regulations -----
Procedure for Distribution of Isleta Gaming Palace

Standard Operating Procedures (SOP’s) --~ 8
Enforcement Activity - 9
Notice of Disciplinary Action for Policy Violations --------------------------- 9
Acknowledgments 9

Commission Certification 10


XVIL

Xi.

Pueblo of Isleta Gam ng Commission
Regulation

TABLE OF CONTENTS
Chapter 5

Licensing
Continued

Exceptions
A Waiver
Enforcement Activity

XIX. Notice of Disciplinary Action for Policy Violations -------------------------=-

XX.
Commi.

Acknowledgments ---.
ssion Certification

ii.

32
32
32
33
33
35


Chapter 10
Alcohol Page 4 of 5

VI. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management, Employees, and Vendors of any Isleta Gaming
Operation are subject to the following action:

1. Refusal to comply or . Fine, denial, suspension,
violation of this policy. revocation, termination
of and/or restrictions on
Gaming License.

VII. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Isleta Gaming Operation(s). Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or any employee, of any employment or any
continued employment whatsoever, nor shall any provisions of this Regulation constitute
or be interpreted by any party or tribunal to constitute any contractual rights of
employment expressed or implied, or any obligation of employment rights created by
covenants of good faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees responsibility to obtain
their Liquor Certification prior to beginning work with the Casino.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, from time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999



Licensing

Chapter 5
en Page 6 of 35

D.

By applying for and obtaining any license, permit, certification, registration,
renewal, finding of suitability, or other approval from the Isleta Gaming
Commission, the holder agrees to abide by all provisions of the Isleta Gaming
Commission Regulations, the IGRA, applicable Federal and Tribal Law, the
Indian Gaming Compact, and any applicable Standard Operating Procedures
of the Isleta Gaming Operation.

Waiver of privilege. An applicant may claim any privilege afforded by the
Constitution of the United States, the State of New Mexico, the Pueblo of
Isleta, or the Indian Civil Rights Act of 1968, in refusing to answer questions
by the Commission. However, a claim of privilege with respect to any
testimony or evidence pertaining to an application may constitute sufficient
grounds for denial.

The required applications for employees, gaming vendors and non-gaming
vendors are available in the Office of the Isleta Gaming Commission. These
applications contain inquiries required by federal law, tribal law and the
Compact. They also contain inquiries required by the Commission. The
Commission, in its discretion, may revise the content of these applications.
However, such revisions must be consistent with the requirements of Federal
law, Tribal law and the Compact.

. All employees shall complete an application for a Gaming License (which

includes but is not limited to, detailed information of all questions asked, a
signed release(s) of information, a background check, fingerprint card, current
photograph, and fee required) and must receive, at least, a Temporary Work
Permit (See Article VII. Temporary Work Permits, herein) before participating
in any Gaming Operations of the Pueblo of Isleta in any way. Employee
license applications must be completed in the Office of the Isleta Gaming
Commission. No exceptions!

. All vendors shall complete an application for a Gaming License (which

includes but is not limited to, detailed information of all questions asked,
signed release(s) of information, background check, business profile report,
and licensing fee) and must receive, at least, a Temporary Vendor Permit (See
Article VII. Temporary/ Work Permit or Vendor Permit, herein) before
participating in the Gaming Operations of the Pueblo of Isleta in any way.

All applicants are expected to provide truthful and accurate information in
their applications. Falsification of or misrepresentation on a Gaming License
Application will result in denial of license.

Identification cards (hereinafter, ID Cards) are required by the Commission
for the purpose of positive identification of all individuals or entities applying

Isleta Gaming Commission Regulation ne Revised December 01, 1999


Chapter 18
Code of Conduct Page 14 of 14

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 18, Code of Conduct, was duly REVISED,
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with 2 voting for, _0_ voting against, and _0_ abstaining.

Vacant

Chairman

ERNEST C.&RAMILLO

Secretary-Treasurer

ge LEG

Subscribed and sworn before me on this the _16th_day of December, 1999.

(OFFICAL SEAL

ODESSA A. MONTOVA

TARY PUBLICSTATE OF 1523 2 ‘
Wty commission 2. NOTARY

My Commission Expires:

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 14

Drug-Free
Workplace


Licensing Page 2 of 35

I AUTHORITY «= ..-,. é

The Isleta Gaming Commission has regulatory authority for all Gaming
Operations of the Pueblo of Isleta to include functions contained in the Indian Gaming
Regulatory Act of 1988, and the regulations promulgated thereunder; any Tribal-State
Compact to which the Pueblo is a party; any procedures instituted by the Secretary of the
Interior; and other regulatory authority as it may be properly assigned from time to time.
The Pueblo of Isleta grants this authority to the Isleta Gaming Commission pursuant to
Resolution 95-03 enacted January 28, 1995 and any ordinance adopted thereto.

I. PURPOSE

The purpose of this regulation is to create a licensing system that will protect the
integrity of all Gaming Operations of the Pueblo of Isleta. This regulation will also serve
as a guide to potential employees and vendors seeking to participate in the regulated
gaming operations of the Pueblo of Isleta. |”

This Regulation shall ensure the following:

1. that the gaming operations of the Pueblo of Isleta remain free of
criminal activity;

2. that investigations are conducted on all vendors and employees who
participate in any Pueblo of Isleta gaming enterprise;

3. that patrons of the gaming operations of the Pueblo of Isleta are
protected from harm; and

4. that the property and assets of the Pueblo of Isleta are protected from
harm.

Iii. SCOPE

This regulation applies to all individuals and entities that are currently
participating or seeking to participate in the Gaming Operations of the Pueblo of Isleta in
any way. A license issued before July 1, 1996 shall be valid only if it meets the
requirements of this regulation.

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural.

Applicant - any employee or vendor who applies to the Isleta Gaming
Commission for a license to participate in the Gaming Operations of the Pueblo of
Isleta. ee

Isleta Gaming Commission Regulation Revised December 01, 1999


ID Badges

Chapter 19
Page 10 of 13

to the Isleta Gaming Commission before any final paycheck is
issued to the individual. Thereafter, the issued ID Badge is to be
kept in that staff members individual Commission file.

VU. ID BADGE FEES

A. Employees

1.

The cost of the initial Temporary ID Badge and the initial
Permanent ID Badge (if applicable) are included in the employee
licensing fee. (See Chapter 5, Licensing)

In the event an employee looses their Commission issued ID
Badge, a new ID Badge may be obtained from the Office of the
Isleta Gaming Commission for a nonrefundable ten dollar ($10.00)
replacement fee, Monday - Friday between the hours of 8:00 AM
and 4:30 PM.

NOTE: This ten dollar ($10.00) replacement fee is for the Commission

issued ID Badge only. This fee does not include any
replacement fee that the Isleta Gaming Palace Human Resource
Department may charge for the Bar Code Badge issued to
employees for time recording purposes.

B. Vendors

1.

The cost of one (1) initial temporary ID Badge (if applicable) and
one (1) initial Permanent ID Badge issued by the Commission are
included in the vendor licensing fee. (See Chapter 5, Licensing)

Vendors requiring more than one (1) initial ID Badge (temporary
or permanent) issued by the Commission must pay a nonrefundable
five dollars ($5.00) fee per additional Badge.

In the event a vendor looses their Commission issued ID Badge
(regardless of type), a new ID Badge may be obtained from the
Office of the Isleta Gaming Commission for a nonrefundable ten
dollar ($10.00) replacement fee, Monday - Friday between the
hours of 8:00 AM and 4:30 PM.

Cc. Commissioners and Commission Staff Members

1.

There will be no fee charged to a Commissioner or Commission
staff member for the initial Commission ID Badge.

Isleta Gaming Commission Regulation Revised December 16, 1999


D Badges

Chapter 19
Page 4 of 13

b. The words, Isleta Gaming Palace;

c. The employees name;

d. Department name

e. Personal Photo.

f. The letter T, meaning temporary badge.
g. The phrase: UNDER 21 (if applicable)

All Permanent Employee ID Badges will consist of the following
information:

The front of this ID Badge will consist of:

a. The Pueblo of Isleta Logo;

b. The words, Isleta Gaming Palace;
c The employees name;

d. Department name;

e. Personal Photo;

f

The phrase: UNDER 21 (if applicable)
The back of this ID Badge will consist of:

a. Pueblo of Isleta Logo;

b. The words, PUEBLO OF ISLETA GAMING
COMMISSION;

The words, EMPLOYEE GAMING LICENSE;
The employees name;

Date of Issue;

License number;

g. Expiration date.

me aoe

All employee ID Badges must be wom on the front torso above
the waist, but no higher than the neck. Employee ID Badges
may not be worn on arms or attached to short sleeves, etc.

All employees must visibly wear their ID Badge at all times

while on the premises or inside the facility of any Isleta Gaming
Operation (See Number 3 above). This includes, but is not limited
to, working hours, mandatory meetings or training’s taking place
on any Isleta Gaming Operation premises, picking up a paycheck,
etc.

No employee is allowed on the premises or in the facility of any
Isleta Gaming Operation without an ID Badge. No exceptions!

Isleta Gaming Commission Regulation Revised December 16, 1999


ID Badges

Chapter 19
Page 11 of 13

In the event a staff member looses their ID Badge, a new ID
Badge may be obtained from the Office of the Isleta Gaming
Commission for a nonrefundable ten dollar ($10.00) replacement
fee, Monday - Friday between the hours of 8:00 AM and 4:30 PM.

VII. ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this policy as follows:

1.

6.

an imposition of a fine of no less than fifty dollars ($50.00) and no
more than five hundred dollars ($500.00) for employees;

an imposition of a fine of no less than five hundred dollars
($500.00) and no more than twenty-five thousand dollars
($25,000.00) for vendors;

disciplinary action up to and including suspension or revocation of
employee gaming license;

disciplinary action up to and including suspension or revocation of
vendor gaming license;

the placing of restrictions or conditions on the licensee’s retention
of their gaming license; and/or

the combination of any of the above.

IX. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management, Employees, and Vendors of the Isleta Gaming Operation
and Commission Staff are subject to the following action:

1.

Refusal to comply or Fine, denial, suspension,

violation of this policy. revocation, termination
of, and/or restrictions on
any Gaming License.

x. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Isleta Gaming Operation. Nothing in this Regulation shall be construed as any
guarantee or promise to any applicant or any employee, of any employment or any
continued employment whatsoever, nor shall any provisions of this Regulation constitute

Isleta Gaming Commission Regulation Revised December 16, 1999


-Chapter 5
Licensing Page 31 of 35

F. After this reconsideration process is complete, the Commission’s decision to
revoke a license is final.

G. The Commission shall not license or re-license any employee or vendor whose
license has been revoked within three (3) years of the date of the action unless
the applicant is determined to be eligible under Article IX of this Chapter.

XV. Method by which all Commission NOTICE’S shall be sent

If practicable, the Notice required under Article XI, B(3, 4, & 6), Article XIV,
A[L()], [2(c & HI, BG, 4, 6), C[2(b)], and Article XV, E shall be sent to the
applicant or licensee via certified United States Mail, return receipt requested,
otherwise, the Notice shall be hand delivered. If the Notice is Hand Delivered, it
shall be accompanied by an official Commission Receipt, which must be signed
by the applicant or licensee and witnessed by a Commissioner or their designee
upon delivery.

1. Applicant/Employee

The Commission shall mail or hand deliver all required Notices to said
applicant or employee within twenty-four (24) hours of the suspension,
denial, or revocation decision or before the beginning of the applicants
next work shift, whichever occurs first.

2. Vendors

The Commission shall mail or. hand deliver all required notices to said

vendor within twenty-four hours of the suspension, denial, or revocation
decision.

XVI. LICENSE RENEWAL
A. Employees

All employees shall renew their license every three (3) years. In order to
renew a license, an employee must resubmit to the entire licensing process
as set forth in Articles V through XI herein. Employees shall pay the
nonrefundable licensing fee required under Article. VI each time they
renew their license. However, the.Commission in its discretion, may
waive an employee’s licensing f fee if the employee has maintained an
exemplary work record. ,

B. Non-gaming Vendors

Isleta Gaming Commission Regulation Revised December 01, 1999



Chapter 6
Investigative Procedures Page 5 of 8

unless otherwise required by law. A third party includes, but not limited to,
outside entities, co-workers, supervisors, managers, the general manager,
family members, relatives, government agencies, etc. Retaliation, in any
form, by an employee or superior toward their co-worker(s) or subordinate(s)
for refusal to breach this confidentiality may result in severe disciplinary
action against the perpetrator.

VI. RELEASE OF INVESTIGATIVE INFORMATION

A. The Isleta Gaming Commission shall not jeopardize any investigation.
Therefore, the Isleta Gaming Commission will not release any investigative
information, to include evidence, to any third party prior to the completion of
the investigation. If, upon the completion of an investigation the Commission
contemplates further disciplinary action against a Gaming License, the
information will not be released until the disciplinary action is complete.

B. Evidence may be released for the following reasons, only upon the approval of
the Commission:

a. to the National Indian Gaming Commission; -

b. to the Federal Bureau of Investigation; or

c. to an authorized representative of federal, tribal, state, local, or foreign
government law enforcement agency(s) or court(s) when the information
sought relates to a civil, criminal, or regulatory investigation or
prosecution.

VIM. INVESTIGATIVE PROCEDURES
A. An allegation of impropriety is made or suspicious activity is observed.
1. The Isleta Gaming Commission is notified.

2. The Commission shall immediately determine whether a further
investigation is necessary.

B. When an investigation is warranted, an investigative unit, headed by a
Commission Investigator, will be assigned by the Commission.

1. The investigative unit shall collect evidence in connection with the
facts and circumstances surrounding the specific investigation.

2. All evidence shall be reviewed, tagged, and cataloged.

Isleta Gaming Commission Regulation . Revised December 16, 1999


Chapter 4~

Gaming Equipment or Devices or Supplies - Page 11 of 13

case basis. All Commissioners are available twenty-four (24)
hours a day seven (7) days.a week and can be contacted via pager,
cellular phone, or home phone number found on the Commission’s
Emergency Contact List.

The above mentioned Commission Emergency Contact List,
especially home phone numbers, may not be given out to any
employee, patron, or entity. In the event of an emergency, it is
the responsibility of the Isleta Gaming Operation Security
Office to contact the appropriate individual listed.

VI. ENFORCEMENT ACTIVITY

A The Commission reserves the right to enforce this policy as follows:

1.

3.

4.

5.

6.

an imposition of a fine of nd'less than fifty dollars ($50.00) and no
more than five hundred dollars ($500.00) for employees,

an imposition of a fine of no less than five hundred dollars
$500.00) and no more than twenty-five thousand dollars
($25,000.00) for vendors,

disciplinary. action up to and including suspension or revocation of
employee gaming license,

disciplinary action up to and including suspension or revocation
of vendor gaming license,

the placing of restrictions or conditions on the licensee’s
tetention of their gaming license, and/or

the combination of any of the above

VII. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

Ali Management, Employees, and Vendors 6f the Isleta Gaming Palace are

subject to the following action:’
1. Refusal to comply or” Fine, denial, suspension,
violation of this policy. ° revocation, termination
~ “of, and/or restriction on a
Gaming License.

Isleta Gaming Commission Regulation Revised December 16, 1999



Chapter 12
Marketing & Promotions Page 4 of 6

2. The winners’ names. ©
3. Amounts or prizes won.
4. Personal information of winner(s):

Address

Drivers License Numbers (Photo Copy)

Social Security Numbers.

Any other information collected in connection with said
promotion.

Bes Pp

IX. A WRITTEN ACCOUNT OF ANY AND ALL REPORTS, ALLEGATIONS,
OR RUMORS OF CHEATING, SCAMS, OR IMPROPER CONDUCT ON
BEHALF OF THE PALACE EMPLOYEES OR PATRONS IN
CONNECTION WITH THE PROMOTION.

x. ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this policy as follows:
1. an imposition of a fine, ‘
2. disciplinary action up to and including suspension or revocation of

any gaming license,

3. the placing of restrictions and/or conditions on the licensee’s
retention of their gaming license, and/or

4. the combination of any of the above.
XI. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management and Employees, of any Isleta Gaming Operation are
subject to the following action:

1. Refusal to comply or Fine, denial, suspension,
violation of this policy. revocation, termination
: of and/or restrictions on
‘Gaming License.

Isleta Gaming Commission Regulation Peopee Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

. Chapter 10

Alcohol


Chapter 11
Variance Reporting Requirements Page 3 of 5

B. Any variance of less than one hundred dollars ($100.00) shall be
immediately reported to the Isleta Gaming Operations Management.
Management must invoke corrective action, to include disciplinary action,
in accordance with Standard Operating Procedures.

Cc. Any unreported variance will result in disciplinary action by the
Commission in accordance with this regulation. (See Section V and VI
below)

Vv. ENFORCEMENT ACTIVITY: #:#1:~. :-

A. The Commission reserves the right to enforce this policy as follows:
1. an imposition of a fine,
2. disciplinary action up to and including suspension or revocation of

employee gaming license,

3. the placing of restrictions or conditions on the licensee’s
retention of their gaming license, and/or

4. the combination of any of the above
VI. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management and Employees, of any Isleta Gaming Operation are
subject to the following action:

1. Refusal to comply or Fine, denial, suspension,
violation of this policy. revocation, termination
of and/or restrictions on
Gaming License.

Vil. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Casino. Nothing in this Regulation shall be construed as any guarantee or
promise to any applicant or any employee, of any employment or any continued
employment whatsoever, not shall any provision of this Regulation constitute or be
interpreted by any party or tribunal to constitute any contractual rights of employment
expressed or implied, or any obligation of employment rights created by convenants of
good faith and fair dealings, either expressed or implied.

wwe aman

Isleta Gaming Commission Regulation Revised December 16, 1999



ID Badges

Chapter 19
Page 5 of 13

10.

11.

12.

Employees shall not wear, for any reason, any ID Badge not
issued to that particular employee.

Only the Isleta Gaming Commission may issue an Employee ID
Badge.

In the event an employee neglects to bring their ID Badge to
work. That employee must be immediately sent home to obtain
and return with their ID Badge.

Tn the event an employee looses their ID Badge and the
Commission Office is closed, Security may issue a Visitors Badge
for that immediate work shift. However, the employee must report
to the Isleta Gaming Palace, Human Resource Department to
obtain an Authorization for Payroll Deduction form, as soon as it
opens on the next business day. With the aforementioned form or
a copy thereof, the employee must then report to the Office of the
Isleta Gaming Commission as soon as possible. This situation will
be written up as a violation of procedure if the employee fails to
appear at the Gaming Commission to obtain a new ID Badge.

Various Isleta Gaming Operation employees have access to highly
sensitive areas of the Casino. Therefore, it is imperative that the
Security Department verify the identity of all individuals carrying a
Employee ID Badge, through visual observance or, if necessary,
detainment of said individual before allowing access to such
sensitive areas.

In the event an employee, voluntarily or involuntarily terminates
their employment with the Isleta Gaming Operation, the issued ID
Badge (regardless of type) must be returned to the Isleta Gaming
Operation Human Resource Department before any final paycheck
is issued to the individual. Thereafter, the issued ID Badge(s) is

to be kept in that employees individual Human Resource file.

B. Vendors

1.

All vendors and/or their agents conducting business, of any nature,
with the Isleta Gaming Operation must possess and wear on their
outer garment, an Identification Badge (herein after, ID Badge)
issued by the Isleta Gaming Commission.

All Temporary Vendor Permits (ID Badges) will consist of the
following information:

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 12
Marketing & Promotions Page 2 of 6

1 AUTHORITY es

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

II. PURPOSE

Henceforth, the Commission sets forth this declaratory order enacted in
consideration for any and all Isleta Gaming Palace promotions, which involve the giving
away of prizes (please see definitions), shall not be conducted without first informing the
Isleta Gaming Commission. This notice shall be forwarded to the Commission at least
one week (five business days) prior to the start of any given promotion.

Tl. SCOPE

This regulation applies to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
ordinance adopted thereto, the Indian Gaming Regulatory Act of 1988, 25 U.S.C. 2701,
and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact. This regulation
does not apply to other Tribal entities or agencies within the Pueblo of Isleta Tribal
Government. a : ,

IV. DEFINITION

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural.

Prizes - shall be defined as money, motor vehicles including motorcycles, boats,
jet skies, any water craft, meals, any and all services (personal or professional), in
short, any item given to a patron upon winning a promotional contest through
voluntary or involuntary entry of said promotional activity which shall include,
but is not limited to, drawings or contests sponsored by.the Isleta Gaming Palace
at the Isleta Gaming Palace, Palace West, or anywhere within the exterior
boundaries of the United States proper.

Isleta Gaming Commission Regulation . Revised December 16, 1999


Chapter 20
Training Requirements Page 3 of 10

Subordinate Employee - includes, but is not limited to, Supervisors, non- exempt
employees, regular employees, full-time employees, part-time employees,
seasonal employees, etc. of any Isleta Gaming Operation.

Training - the process in which all employees, regardless of position, of any
Isleta Gaming Operation will be informed and educated on all Commission
Regulations, Isleta Gaming Palace Standard Operating Procedures (SOP’s), and
made aware of the behavior or performance required by the Palace to adequately
perform in a particular position.

Upper Level Management - includes, but is not limited to, the General
Manager, Department Managers, and Directors (if applicable).

Vv. POLICY

It is imperative that all employees of any Isleta Gaming Operation be fully
informed and aware of all Isleta Gaming Commission Regulations and Isleta
Gaming Palace Standard Operating Procedures to ensure an effective and
productive working environment in any Isleta Gaming Operation.

A. General Manager

1. It is the responsibility of the Isleta Gaming Palace General
Manager to assure that all Upper Level Management employees
are fully trained and aware of all Isleta Gaming Commission
Regulations and Isleta Gaming Palace Standard Operating
Procedures. This shall include but is not limited to, the cross
training of upper level management employees on
interdepartmental Standard Operating Procedures.

2. The Isleta Gaming Palace General Manager shall hold a mandatory
training session(s) for all Upper Level Management employees at
least once a year, or as deemed necessary by circumstances. This
training session(s) shall be sufficient enough in duration to review,
at least, all materials mentioned in this regulation, allow for
questions and answers posed to the provider of said training, and
may provide for a test of said materials, if necessary.

3. Due to the fact that the material(s) to be covered is extensive, the
training session(s) may be held consecutively over a period of days
or even several weeks, but it is not to exceed more than ninety (90)
calendar days in duration.


Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 15

Race and Sports Book
Computerized

I. Authority 2
IL. Purpose 2
Til. Scope 2
IV. System Security Standards 2
Vv. Betting Ticket and Equipment Standards 2
VI. Wagering Standards 4
VII. Wagering Cutoff 5
Vill. Payout Standards 5
IX. Checklist Standards -6
X. -—-Employee Segregation - 7
XI. Computer Reports 7
XII. Accounting and Audit Functions ----9
XII. Accounting Standards 10
XIV. Auditing Standards 10
XV. Statistics 11
XVI. Wagering Accounts 12
XVIL. Telephone (Wire Communication) Wagering (if applicable) ----------------- 13
XVII. Credit Wagering (if applicable) 14
XIX. Write Off Standards 15
XX. Enforcement Activity 15
XXI. Acknowledgments 15
Commission Certification 16



Chapter 15
Race and Sports Book Computerized Page 5 of 16

3. A written reason for the voiding is attached to the voided
ticket.

E. The computer system shall adequately document supervisory
approval for appropriate transactions, as applicable.

Vol. WAGERING CUTOFF

A. A sporting event wager is not accepted after the start of the event
unless “in progress” or a similar notation is written on the original
and each copy of the betting ticket and unless a key employee
other than the ticket writer initials the original and each copy of the
ticket.

B. A race wager is not accepted after the occurrence of post time, as
defined by industry standards.

c. The cutoff time for event wagering will be set up or established in
the computer in accordance with industry standards.

D. The computer either is incapable of transacting/accepting a wager
subsequent to the above cutoff times or produces a report which
specifically identifies such wagers.

E. The computer either is incapable of voiding a ticket subsequent to
the cutoff time or produces a report which specifically identifies
such voided tickets.

F. The computer is incapable of establishing or changing a
cutoff/starting time to a time that is earlier than the current time of
day. .

G. Tickets will not be written or voided after the outcome of an event is
known.

Vill. PAYOUT STANDARDS

A. Prior to patrons receiving payouts on winning tickets, results are
input into the computer’s administrative terminal for computerized

grading of all wagers.

Isleta Gaming Commission Regulation Revised December 16, 1999


Regulatory Agency to amend all relevant forms, documents and materials in
an orderly fashion, the Isleta Gaming Regulatory Agency may identify and
refer to itself as the Pueblo of Isleta Gaming Commission until June 30, 2002.

. The Isleta Gaming Regulatory Agency shall be composed of an Executive
Director and such staff as shall be necessary and appropriate to carry out the
duties and responsibilities delegated to the Isleta Gaming Regulatory Agency
by this resolution.

. The Executive Director shall be appointed by the Tribal Council; provided,
however, that the Executive Director may be removed at any time if a
majority of the total number of members of the Pueblo of Isleta Tribal Council
find that such removal is in the interest of effective regulation of Pueblo
Gaming.

. Tribal Council shall annualiy approve a budget for the Isleta Gaming
Regulatory Agency and appropriate such funds as may be necessary to allow
the Agency to effectively regulate Pueblo Gaming.

Article II - Authority and Duties of General Executive Director

. All of the authority, responsibility and duties delegated to the Isleta Gaming
Regulatory Agency by this Resolution shall be exercised by the Executive
Director. Executive Director may delegate any of such authority,
responsibilities and duties to members of the Isleta Gaming Regulatory
Agency staff, provided that the Director shall remain responsible to ensure
that said responsibilities and duties are effectively carried out.

. The Executive Director shall supervise all Isleta Gaming Regulatory Agency
staff in accordance with the Pueblo of Isleta Personnel Policies and
Procedures and such other laws, policies and procedures that may apply to
employees of the Pueblo of Isleta generally or the staff of the Isleta Gaming
Regulatory Agency specifically.

. The Executive Director shall annually propose a budget to Tribal Council for
the Isleta Gaming Regulatory Agency and provide appropriate justification for
all budgeted items and their necessity for the effective regulation of Pueblo
Gaming. The Executive Director shall be responsible for authorizing all
expenditures from the approved budget. The Executive Director may delegate
to staff personnel of the Isleta Gaming Regulatory Agency such authority over
the expenditure of budgeted funds as he or she may determine necessary or
appropriate for the Isleta Gaming Regulatory Agency to carry out its
responsibilities and duties pursuant to this Resolution.

Article III — Authority, Responsibilities and Duties

. The Isleta Gaming Regulatory Agency shall on behalf of the Pueblo of Isleta
exercise any and all regulatory authority and duties of the Tribe specified in
Pueblo of Isleta Ordinance: Permitted Gaming 94-02, as amended, and Pueblo

Page 2 of 5


Drug Free Workplace

Chapter 14
- Page 7 of 11

Post-counseling/rehabilitation testing as a condition of
reinstatement upon completion of a reasonable drug-alcohol
treatment or counseling program.

When an employee returns to work from an extended absence,
illness or reduction-in-force in excess of thirty (30) days.

When an employee’s supervisor or a Commission representative
has a reasonable suspicion that an employee shows signs of
possible intoxication, using or being under the influence of
drugs/alcohol, or other articulable facts that would lead a prudent
supervisor or regulator to be concerned about the employee’s
safety or the safety of others due to an employee’s physical or
emotional condition while at work.

If an employee suffers an on-the-job injury or accident (requiring
treatment from a physician) or contributes to an on-the-job
accident or injury to any other person or them self.

Employees, whom employer reasonably suspects, were involved in
causing a serious or potentially serious accident or incident in
which safety precautions were violated, or who gave unsafe
instructions or orders in which equipment or property was
damaged, or where careless acts were performed or where the
cause was due to the employée’s failure to wear prescribed
personal protective equipment while working at the casino or the
violation of an established work rule.

When an employee or person is found in possession of suspected
illicit or unauthorized drugs and/or alcohol, or when any of these
items are found in an area controlled or used exclusively by
designated employees.

Part of an overall search, inspection and/or screening of an
employee’s work area, department or location of employment
(including the premises of customers or other contractors), to
determine the use or detectable.amounts of any illegal or
unauthorized drugs, alcohol, or chemical:-substances covered by
this policy. noes

Employees will be subject to random testing. All employees (full-
time, part-time, and temporary) subject to testing will be placed in
acommon selection pool for an equal chance of selection on a

Isleta Gaming Commission Regulation _ Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

7°

| Chapter 9

Concession & Restaurant
Health Standards


Chapter 5
Licensing a Page 19 of 35

6. All members of the Commission and all employees required to handle
confidential information shall sign a statement, in which they shall
pledge not to violate the provisions of this section.

IX. ELIGIBILITY DETERMINATION
A. The Commission Investigator or the Commission’s investigative agency shall
review the results of an applicant’s completed background investigation, along
with any criminal history on the applicant provided by the Federal Bureau of
Investigation. The Commission Investigator or the Commission’s
investigative agency shall make written findings with respect to:

1. the applicant’s prior activities;

2. the applicant’s criminai record, if any; and _

3. the applicant’s reputation, habits, and associations.

B. After reviewing the findings of the Commission Investigator or the
Commission’s investigative agency, the Commission shall determine whether
the applicant is eligible to receive a license. The Commission may conduct

further investigations on the applicant before making such a determination.

C. In deciding whether an applicant is eligible to receive a license, the
Commission shall consider:

1. the applicant’s prior activities; .
2. the applicant’s criminal record, if any; and
3. the applicant’s reputation, habits and associations.
D. The Commission shall deny an application if it determines that the applicant:

1. poses a threat to the public interést or to the Gaming Operations of
Pueblo of Isleta; .

2. poses a threat to the effective regulation of the Gaming Operation; or

3. creates or enhances a danger of unsuitable, unfair, or illegal practices,
methods, or activities in the conduct of gaming.

Isleta Gaming Commission Regulation Revised December 01, 1999


Chapter 5
Licensing _Page 5 of 35

a. to hire and fire employees;
b. to set up working policy for the Gaming Operation; or

3. The chief financial officer or other person who has financial management
responsibility.

Revocation - The withdrawal or cancellation or rescission of an individual’s or

entities license privilege of participating in the gaming activities of any Isleta

Gaming Operation.

State Gaming Representative (SGR) - the person designated by the Governor of
the State of New Mexico, who is responsible for the actions of the State as set
forth in the Compact.

Suspension - A temporary cutting off or withdrawal or cessation or debarring an
individual or entity, as from the privileges of participating in the gaming activities
of the Isleta Gaming Operation. :

Vendor - any person or entity who sells goods or services to any Gaming
Operations of the Pueblo of Isleta.

Vv. APPLICATION FOR A LICENSE

A. Any license, permit, certification, registration, renewal, finding of suitability,
or other approval, issued by the Isleta Gaming Commission is deemed a
revocable privilege. No person or entity holding such a license, permit
certification, registration, renewal, finding of suitability, or other approval is
deemed to have any rights therein.

B. Any application submitted under the provisions of this Regulation or this rule
constitutes the seeking of a privilege, and the burden of ‘Proving qualification
is, at all times, on the applicant.

C. Any application for a license, permit, certification, registration, renewal,
finding of suitability, or other approval, from the Isleta Gaming Commission,
will constitute a request to the Isleta Gaming Commission for a decision on
the applicant’s suitability, character, integrity, and ability to engage in, or be
associated with, gaming activity with the Pueblo of Isleta Gaming Operation.
By filing an application with the Isleta Gaming Commission, the applicant
specifically consents to investigation to the extent deemed appropriate by the
Isleta Gaming Commission. Without limiting the foregoing, the investigation
may include background investigation and a credit check of the applicant and
all persons having a substantial interest identified in the application,

Isleta Gaming Commission Regulation oa Revised December 01, 1999


Chapter 16

Gifts, Gratuities, & Solicitations Page 6 of 9

VI. EXCEPTION(S)

A.

Officials (Tribal/Commission/Management/other), employees, agents, and
persons may, at the discretion of Isleta Gaming Palace General
Management, receive small promotional items from the Isleta Gaming
Palace only. Disbursement of small promotional items may only occur
once every three (3) months and shall not exceed the total value of twenty-
five dollars ($25.00) per person per disbursement. In the event that the
total amount of twenty-five ($25.00) per person per disbursement is not
utilized, it may not be applied to any other expenditure of any form. Small
promotional items includes, but is not limited to pens, pins, lapels, cups,
glasses, and other similar small items that are intended as “give away”
products. Isleta Gaming Palace Management will control, record, and
account for the above merchandise prior to disbursement. All established
Accounting and Marketing and Promotion Regulations and Policies shall
apply hereto. a

The Pueblo of Isleta Tribal Council may, at their discretion, authorize an
individual(s) to serve in an official capacity, in representing and accepting
gifts and gratuities, in any form and of any value, at public or private
events on behalf of the Pueblo of Isleta. Any accepted gifts and gratuities
must be immediately given or delivered to the Pueblo of Isleta Tribal
Government.

NOTE: The Pueblo of Isleta Tribal Government Offices are located at 117A Tribal
Road 40, Isleta, New Mexico 87022 or P. O. Box 1270, Isleta, New Mexico
87022.

Vi. SOLICITATIONS

A.

B.

Individual

1. Individuals soliciting money(s), in any form, from the Gaming
Operations of the Pueblo of Isleta for specific items,
circumstances, sponsorships, etc., must be referred to the Pueblo of
Isleta Tribal Council Office. Such solicitations, if approved, must
not be drawn on Gaming Operations accounts.

Employee

1. Employees may not solicit or distribute, in any form, for charities
or causes at, within, and/or on the premises of a Gaming
Operation. —

Isleta Gaming Commission Regulations Revised December 16, 1999


Chapter 8
Employee Grievance Procedures - Page 3 of 7

appeal of their grievances. If that is the intent, it should be made clear in the
Isleta Gaming Palace Human Resource Department’s Standard Operating
Procedures.

Interested Parties - Any person or entity which has a significant interest in the
outcome of any Isleta Gaming Palace or Tribal Council Grievance process
decision or formal hearing.

Vv. STEPS OF FORMAL GRIEVANCE PROCEDURE
A. Step I.

The first step, though not enumerated as such, in the grievance procedure
should be an “informal’ discussion of the concern(s) with the immediate
“Supervisor”. If the concern is about the Supervisor, the immediate
supervisor is skipped and the concern is taken to the Department Manager,
Personnel Director (Human Resources Manager), and then the General
Manager. Though such individuals should be accessible to employees, in
the context of the grievance process, an employee should first seek out
his/her immediate supervisor with the concem(s). If need be, the upper
echelons of management (Department Manager/Human Resource
Manager/General Manager) will come into play at later stages of such
procedures.

B. Step H.

An employee should feel free to informally bring a concern to the
immediate supervisor or upper echelons of management. If no redress is
forthcoming, the employee shall be informed and encouraged by the Isleta
Gaming Palace Human Resource Department to pursue “Step II” of the
grievance procedures which shall be the formal institution of a written
grievance of the concer to the Human Resource Department. Though this
may seem rather cumbersome, it merely poses a minor inconvenience for
an employee. If the employee simply wants to spout off, he/she will have
to invest a little time in doing so. And if an employee has a legitimate
concern, writing out his/her concern will simply serve to make it that
much more credible.

1, Employee’s Responsibility in the Formal Grievance Procedure

If an employee feels aggrieved, it should be up to that employee to
see any such actions to their conclusion. As the policy reads, it is
up to the employee to carry the grievance to the next level. Once
again, this poses a minor inconvenience for the employee, but if

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 3
Gaming Participation & Operation Page 2 of 7

I AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Resolution 95-03 enacted January 28, 1995 and any ordinance
adopted thereto.

i. PURPOSE

The purpose of this regulation is to address an ongoing “perception” problem with
some functions of the Palace. The Commission understands the gaming industry is
perception driven. If the Palace’s games are perceived as fair and legitimate, the Palace
will attract players. To this end, the Gaming Commission shall create, from time-to-time,
regulations which will address such concerns.

I. SCOPE

This regulation applies to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
resolution adopted thereto, the Indian Gaming Regulatory Act, and the Isleta/State of
New Mexico Indian Gaming Compact. This regulation does not apply to other tribal
entities or agencies within the Pueblo of Isleta Tribal Government.

This regulation shall override all previous Palace policies and rules that speak to
the matters enumerated herein.

IV.. GAMING PARTICIPATION
A. Patrons

1. Participation in any Class II or IIT Gaming by any person under the age
of twenty-one (21) is prohibited.

B. Employee
1. Employee Practices
a. Discrimination of the employment of persons to work for the
gaming Enterprise or in the Gaming Facility on the grounds of

race, color, national origin, gender, sexual orientation, age, or
handicap is prohibited.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 20
Training Requirements __ Page 9 of 10

IX. ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this regulation as follows:

1. an imposition of a fine,

2. disciplinary action up to and including suspension or revocation of
employee gaming license,

3. the placing of restrictions or conditions on the licensee’s retention

of their gaming license, and/or
4. the combination of any of the above.
xX. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management and Employees of the Isleta Gaming Operation are
subject to the following action:

1. Refusal to comply or Fine, denial, suspension,
violation of this policy. revocation, termination
of, and/or restrictions on
any Gaming License.

XI. ACKNOWLEDGMENTS

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees responsibility to obtain
training prior to beginning work for or with any Isleta Gaming Operation.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, from time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.


Promulgating

Chapter 2

Internal Procedures & Regulatory Provisions Page 8 of 9

7.

to the Infraction File.

Final determination or action on each Notice of Infraction rests
with the Isleta Gaming Commission.

B. Notice of Violation

1.

In the event Management of any Isleta Gaming Operation fails to
respond or to take adequate corrective action when a Notice of
Infraction is issued by a Commission Agent, the Commission may
issued an outright Notice of Violation. A Notice of Violation shall
also be utilized in the event that an entity, other than a Pueblo of
Isleta Gaming Operation, violates any Commission Regulations,
Standard Operating Procedure, or other applicable gaming laws.

Depending on the severity of any infraction, the Commission
reserves the right to overstep the Notice of Infraction process
above and issue a Notice of Violation or suspend or revoke any
Gaming License. (For details on suspension or revocation of a
Gaming License, see IGCR Chapter 5 Licensing)

Only a Commissioner may sign and issue a Notice of Violation.

All Notices of Violation shall be promulgated on official
Commission letterhead and include at least the following:

A log number,

Name and address of Individual or Entity involved,
The words “NOTICE OF VIOLATION”,

The citation and qualifying criteria,

Penalty assessment, of any type, and due date, as
applicable, that the Commission is imposing,
Commissioner signature.

snoop

m

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 8
Employee Grievance Procedures Page 7 of 7

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 8, Employee Grievance Procedures, was duly
REVISED, ADOPTED, AND RATIFIED on this the _16th_day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with 2 voting for, _0 voting against, and _0_ abstaining.

Vacant

Chairman

(Presa ES Ys
TRICIA L. STROM

Vice-Chairman

Secretary-Treasurer

ATTEST Fe

Subscribed and sworn before me on this the _16th_day of December, 1999.

ty Be) ost A MONTOYA
ee some NOTARY LL,

My Commission Expires: < id 2062

Isleta Gaming Commission Regulation _ Revised December 16, 1999


» Chapter 15
Race and Sports Book Computerized Page 12 of 16

B. This information is presented to and reviewed by management
independent of the race and sports book on at least a monthly
basis.

Cc. The above referenced management investigates any unusual
statistical fluctuations with race and sports book personnel. This
review will be performed by comparing the current period statistics
for each type of event with those of applicable prior periods.

Dz. The results of such investigations are documented in writing and
made available for inspection.

XVI. WAGERING ACCOUNTS

A. Before a book accepts a wager or receives wagering information
from a patron by wire communication:

1. The patron must personally appear at the premises of the
block.

2. An employee of the book examines, in the patron’s
presence, the patron’s valid drivers license or other reliable
identity credential(s).

3. The employee must record:

a. The patron’s name, permanent home address
(other than a post office box number), and
home telephone number.

db. The patron’s mailing address and, if the
mailing address is not a post office box number
and is a residence or place of business of the
patron, the telephone number of the residence
or place of business.

c. The patron’s date of birth and social security
number. :

d. The method used to verify the patron’s identity
and residence, and a description, including the
document number, of the identity credential
examined.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 15
Race and Sports Book Computerized Page 15 of 16

XIX. WRITE OFF STANDARDS
A. Written off wagering accounts are authorized, in writing, by at least
two (2) management officials from departments independent of the
credit transaction.

B. Access to written off wagering account/credit instruments is
restricted to individuals specified by management.

XX. ENFORCEMENT ACTIVITY
A. The Commission reserves the right to enforce this policy as follows:

1. An imposition of a fine;

2. Disciplinary action up to and including revocation of a gaming
license;
3. The placing of conditions and/or restrictions on the licensee’s

retention of their gaming license; and/or,
4. A combination of the above.
XXI. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Casino. Nothing in this Regulation shall be construed as any guarantee or
promise to any applicant or any employee, of any employment or any continued
employment whatsoever, not shall any provision of this Regulation constitute or be
interpreted by any party or tribunal to constitute any contractual rights of employment
expressed or implied, or any obligation of employment rights created by convenants of
good faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, form time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation By Revised December 16, 1999



Chapter 16
Gifts, Gratuities, & Solicitations Page 2 of 9

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

II. PURPOSE

The purpose of this regulation is to provide a code of ethics to be above reproach
regarding any unethical business practices that might result in unusual or favorable
treatment or allow undue influence of employee judgment with regard to daily business
dealings with any vendor or patron or official (Tribal/Commission/Management/other).
This regulation will specifically enumerate the manner in which the Commission will
exercise said authority in its oversight of all Palace Gifts, Gratuities, and Solicitations. In
applying this authority, the Commission will act in a responsible and consistent manner
when promulgating, adopting, approving, revising, implementing, administering, and
enforcing the rules, regulations, policies, and decisions of the Commission.

QI. SCOPE

This regulation pertains to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
Resolution or Tribal Ordinance adopted thereto, the Indian Gaming Regulatory Act of
1988, and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact.

This regulation applies to all Commissioners, Commission staff, Isleta Gaming
Palace; Management, employees, agents, vendors, patrons, and all Pueblo of Isleta Tribal
Officials, elected or appointed.

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural. .

Agent - A person, corporation, or entity authorized by. another to act for or on
behalf of him/her or an agency; « one. entrusted with/another’s business, affairs,
and/or dealings.

Isleta Gaming Commission Regulations Revised December 16, 1999


Chapter 4
Gaming Equipment or Devices or Supplies Page 2 of 13

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Resolution 95-03 enacted January 28, 1995 and any ordinance
adopted thereto.

Il. PURPOSE

The purpose of this regulation is to set forth a comprehensive set of Minimum
Internal Controls Standards (MICS) for Gaming equipment, devices, electronic gaming
devices (EGD), or supplies for all Gaming Operations of the Pueblo of Isleta. In order to
maintain and insure the integrity of all Gaming equipment, devices, or supplies
incorporated into any Gaming Operation, the Commission deems it necessary that
appropriate safeguards be implemented via workable procedures. The following, set of
procedures, are intended to address minimal standards that the Commission requires of all
Gaming Operations of the Pueblo of Isleta. The State of Nevada Standard, Regulation
14, Manufacturers, Distributors, Gaming Devices, New Games and Associated
Equipment (herein after, Nevada Standards) is hereby adopted (copies attached) to aid as
an additional Minimum Internal Control Standard. Any standards; 1) promulgated by the
Isleta Gaming Commission; or 2) practiced by the Pueblo of Isleta Gaming Operations,
Standard Operating Procedures (SOP’s), equal to or more stringent than the Nevada
Standards, shall prevail in that order. * ‘

IW. SCOPE

This regulation applies to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
Resolution or Ordinance adopted thereto, the Indian Gaming Regulatory Act of 1988, and
the Pueblo of Isleta/State of New Mexico Indian Gaming Compact. This regulation does
not apply to other tribal entities or agencies within the Pueblo of Isleta Tribal
Government.

IV. PROCEDURES
A. Authorities

1. The persons authorized to implement the following procedures are
limited to the following:

a. Commissioner or their designee,
Duties: Confirm by their signature or initials what actions
were taken with the respective machine(s).

Isleta Gaming Commission Regulation : Revised December 16, 1999


Chapter 16

Gifts, Gratuities, & Solicitations Page 8 of 9
1. Refusal to comply or Fine, denial, suspension,
violation of this policy. revocation, termination
; of and/or restrictions on
Gaming License; and/or

Banishment, criminal
prosecution, and/or
prohibition of the
particular event.

xX. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Casino. Nothing in this Regulation shall be construed as any guarantee or
promise to any applicant or any employee, of any employment or any continued
employment whatsoever, nor shall any provision of this Regulation constitute or be
interpreted by any party or tribunal to constitute any contractual rights of employment
expressed or implied, or any obligation of employment rights created by convenants of
good faith and fair dealings, either expressed or implied.

Compliance with this Regulation by all Officials is mandatory.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, form time to time. All rights to
further amend, refine, and redefine are spécifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulations Revised December 16, 1999


Chapter 10
Alcohol “ Page 2 of 5

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Resolution 95-03 enacted January 28, 1995 and any ordinance
adopted thereto.

Il. PURPOSE

The purpose of this regulation is to provide a comprehensive guideline of alcohol
serving standards that shall be followed by Palace Food and Beverage Operations
management and employees. Further, this regulation will specifically enumerate the
manner in which the Commission will exercise said authority in its oversight of all Palace
Concession and/or Restaurant activity. In applying this authority to Food and Beverage
operations, the Commission shall act in a responsible and consistent manner when
promulgating, adopting, approving, revising, implementing, administering, and enforcing
the rules, regulations, policies, and decisions of the Commission

Ol. SCOPE

This regulation applies to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
Resolution adopted thereto, the Indian Gaming Regulatory Act of 1988, and the
Isleta/State of New Mexico Indian Gaming Compact. These regulations do not apply to
other Tribal entities or agencies within the Pueblo of Isleta Tribal Government.

IV. ALCOHOL PROCEDURES
A. Sale of Alcohol

1. Alcoholic beverages will not be sold, served, delivered, or consumed
in the part of a Gaming Facility where gaming is allowed.

2. An employee of the Gaming Facility is prohibited from selling,
serving, giving, or delivering an alcoholic beverage to an intoxicated
person or from procuring or aiding in the procurement of any alcoholic
beverage for an intoxicated person at the Gaming Facility.

B. Alcohol Education

1. Gaming Facility employees that dispense, sell, serve, or deliver
alcoholic beverages will attend Alcohol Server Education Classes

Isleta Gaming Commission Regulation Revised December 16, 1999



us I wn rn ences

Chapter 18

Code of Conduct Page 4 of 14

Personal Relationship - Any marriage (past or present), close friendship, or
family relation with any employee, patron, vendor, supplier or any other
organization which it appears could diminish the employee’s impartiality.

Reportable Circumstances - Any financial interest in any vendor, supplier by the
employee or a member of the employee’s immediate family; any personal
relationships with any supplier or any other organization where there may be a
question of propriety; any transactions in which the employee proposes to
participate on behalf of the Isleta Gaming Organization where the individual or
the individuals immediate family has a financial interest or a personal
relationship; any outside or self-employment the employee proposes to undertake.

Tribal Official/Government Official/Official - pertains to a Tribal Council
member(s), Tribal Judge(s), Tribal Administer(s), Governor, Lieutenant
Governor(s), Tribal Treasurer, Gaming Management Board Members,
Commissioner(s), and Commission agents. -

Vv. CODE OF CONDUCT AND PERSONAL CONDUCT

A. The Isleta Gaming Commission, Commission staff, Tribal Official, and
the Isleta Gaming Operation employees, agents, and vendors to the
Gaming Operation are expected to:

1. Conduct business with the highest degree of integrity, honesty,
candor, objectivity, and fairness.

2. Deliver quality products and services that meet commitments made
to sponsors concerning performance, cost, and schedule, and
maintain and promote customers’ confidence in the Isleta Gaming
Operation.

3. Provide an environment that recognizes diversity and demands
respect for the individuals.

4. Comply with both the letter and the spirit of all laws and
regulations that apply: to the Isleta Gaming Operation activities.

Ss. Administer and perform contractual duties and programs ina
manner that satisfies both legal obligations and Isleta’s high
standards of integrity and quality.

6. Handle classified, unclassified controlled access, private,
confidential and proprietary information in a proper manner.

Isleta Gaming Commission Regulation Revised December 16, 1999


Training Requirements

Chapter 20
Page 6 of 10

concluded, it is the responsibility of the Department Manager to
train each new hire on all Isleta Gaming Commission Regulations
and Isleta Gaming Palace Standard Operating Procedures prior to
the new hire being allowed to begin the position or assist patrons at
any Isleta Gaming Operation.

Ignorance of any Commission Regulation or Isleta Gaming Palace
Standard Operating Procedure shall not be acceptable as an excuse
for a violation of any Regulation, policy, or procedure. Ifa
Department Manager does not know a regulation or policy or
procedure, that Department Manager should, at least, know where
to look it up in order to make an informed decision on any
situation or request the assistance of the General Manager.

Cc. Subordinate Employees

1.

It is the responsibility of each Isleta Gaming Palace Employee to
assure and adhere to all Isleta Gaming Commission Regulations
and Isleta Gaming Palace Standard Operating Procedures.
Mandatory training will be provided by the Isleta Gaming Palace
to aide all employees in accomplishing this goal.

Each Isleta Gaming Palace Employee is responsible for attending
any mandatory training session(s) provided by the Isleta Gaming
Palace. This training session(s) shall allow for the review of, at
least, all materials mentioned in this regulation, allow for questions
and answers posed to the provider of said training, and may
provide for a test of said materials in which the Isleta Gaming
Palace may mandate that the employee pass by a certain
percentage, before being allowed to begin the position.

Each Isleta Gaming Palace Employee may review the Isleta
Gaming Commission Regulations and each Departments Standard
Operating Procedures at any time upon request to a Supervisor or
Department Manager.

In the event a new subordinate employee is hired by the Isleta
Gaming Palace and the aforementioned training(s) has been
concluded, it is the responsibility of the Department Manager to
train each new hire on all Isleta Gaming Commission Regulations
and Isleta Gaming Palace Standard Operating Procedures prior to
the new hire being allowed to begin the position or assist patrons at
any Isleta Gaming Operation.


Chapter 13
Surplus Palace Property Page 4 of 5

VIII. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management and Employees, of any Isleta Gaming Operation are
subject to the following action:

1. Refusal to comply or Fine, denial, suspension,
violation of this policy. revocation, termination
of and/or restrictions on
Gaming License.

Ix. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Casino. Nothing in this Regulation shall be construed as any guarantee or
promise to any applicant or any employee, of any employment or any continued
employment whatsoever, not shall any provision of this Regulation constitute or be
interpreted by any party or tribunal to constitute any contractual rights of employment
expressed or implied, or any obligation of employment rights created by convenants of
good faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, form time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation . Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 17

Notification
to the Commission


Chapter 5
Licensing - Faada Page 11 of 35

Vil. TEMPORARY/ WORK PERMITS or VENDOR PERMITS

A. Immediately or within twenty (20) regular days of receiving a completed
application, the Commission may issué a Temporary Work Permit (for
employees) or a Temporary Vendor Permit (for vendors) to an applicant.

B. The Commission shall not issue a Temporary Work Permit or Temporary
Vendor Permit to an applicant if:

1. the background investigation of the applicant reveals that the applicant
has been convicted of a felony, gross misdemeanor, numerous criminal
offenses, excessive amounts of debt (cash handling positions), or other
pertinent information deemed to be derogatory; or

2. it is apparent from the application that the applicant is ineligible to
receive a license under the requirements of Article IX, Eligibility
Determination, of this Chapter.

C. The Temporary Work Permit or Temporary Vendor Permit shall expire upon:

1. the issuance of a license under Article XII of this Chapter;

2. the issuance of a NOTICE OF DENIAL;

3. in the case of vendors, ty (90) regular days after the temporary

vendor permit is issued; or

4. in the case of employees, ninety (90) regular days after the employee
begins work, whichever occurs first.

D. In the event a temporary work permit or a temporary vendor permit expires
due to the ninety (90) day rule, Section C (3) and (4) above, the employee or
vendor will be notified by the Commission to file for an extension of said
permit. _

E. Ifthe employee or vendor are not notified by the Commission to file an
extension of the temporary permit, it is understood that the temporary permit
will automatically continue to apply, extending the life of said permit until the
completion of the background investigation and a Gaming License or a Notice
of Denial is issued.

F. The ninety (90) day rule contained in Section C (3) and (4) above, applies to
gaming license applications only and is not to be construed to coincide or
commingle with the ninety (90) day employee evaluation period undergone

Isleta Gaming Commission Regulation Revised December 01, 1999



Chapter 9°
Concession & Restaurant Health Standards Page 6 of 6

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 9, Concessions & Restaurant Health Standards, was
duly REVISED, ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day
of December, 1999, at a duly called meeting of the Gaming Commission of the Pueblo of
Isleta, at which a quorum was present, with __2_ voting for, 0 voting against, and

_0_ abstaining.

Vacant

Chairman

stead Nour

TRICIA L. JTROM/

Vice-Chairman

me

ATTEST

Subscribed and sworn before me on this the _16th_ day of December, 1999.

2 22. NOTARY

My Commission Expires: 1a

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 5
Licensing Page 29 of 35

a. The date, time, and place of this Reconsideration Review Hearing;

b. That the licensee has the right to bring an advocate of his/her choosing
to this Reconsideration Review Hearing; and

c. That the licensee and/or their advocate may present evidence in the
form of documentation and verbally testify, to refute any allegation
made against their license.

6. The advocate mentioned in Subsection 4(b) above can not be an employee
of or affiliated with the Isleta Gaming Operation in any way.

7. At the Reconsideration Review Hearing, the burden of proof lies, at all
times, upon the person or entity holding said license. At this hearing, the
licensee will have the opportunity to present documentation and verbally
rebut the allegation under which their license was revoked. No license
shall be reinstated unless and until the applicant has satisfied the Gaming
Commission of their good character, honesty, and integrity. (See Article
IX, Eligibility Determination, herein) The licensee may, prior to or at the
Reconsideration Review Hearing, request that the Commission allow
additional time (Request a Continuance) in order for the licensee to obtain
and provide proof to refute allegations. A Continuance, if granted by the
Commission, shall be held'no latter than ten (10) business days after the
Initial Reconsideration Review Hearing.

8. After the Reconsideration Review Hearing is complete, the Commission
has ten (10) business days in which to inform the licensee, in writing via
certified mail, of its final decision. THIS DECISION IS FINAL!

9. Asan alternative to revoking a license, the Commission may impose lesser
penalties on all licensee’s, such as fines. The Commission may also place
conditions or restrictions on the licensee’s retention of a license.

C. Reinstatement
1. The Commission may reinstate a license if it is proven, through sufficient
documentation, that the allegations posed to a licensee, under the
Revocation procedures, are in fact false and the licensee is found eligible
under Article IX, herein. All documentation to this effect must be
contained, in detail, in the Commission file.
2. When reinstating a license the following procedure must be completed:

a. Employee

Isleta Gaming Commission Regulation Revised December 01, 1999


Chapter 3
Gaming Participation & Operation Page 4 of 7

C. Management Contractor(s)

1. Any Management Contract regarding the Tribe’s Class II or II
Gaming Activity will conform to the requirements of Tribal Law, the
IGRA, and the Pueblo of Isleta/State of New Mexico Indian Gaming
Compact and the regulations issued thereunder.

2. All Management Contracts must be submitted to the Isleta Gaming
Commission prior to signing or entering into said contract. In turn, the
Isleta Gaming Commission must submit all Management Contracts to
the NIGC for compliance approval. (Also, see IGCR, Chapter 17,

Notification to the Commission, V, D)

D. Construction Standards
1. Safety and Construction

a. Safety and construction of all Gaming Facilities or additions
thereto shall be minimally regulated by and maintained in

accordance with the Nationgl,Electrical Code, the Uniform comes Fd
Building Code, the UnifornE Meth a nial Code, the Uniform
Fire Code, and the Uniform Plumbing Code.

2. Inspection(s)

a. Inspections will be conducted with respect to the above
construction standard at least annually.

b. Ifthe State Gaming Representative requests sufficiently in
advance of an annual inspection, the State Gaming
Representative may be present during such inspection and must
be escorted by a Representative of the Commission at all times
when inspecting any sensitive area.

c. The Tribe agrees to correct any deficiencies noted in such
inspections within a time agreed upon between the State and
Tribe.

d. The Commission will provide copies of such inspection reports
to the State Gaming Representative, if requested to do so in
writing. :

ati

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 7
Patron Dispute Resolution Page 2 of 5

1 AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Resolution 95-03 enacted January 28, 1995 and any ordinance
adopted thereto.

Ii. PURPOSE

The purpose of this regulation is to provide a comprehensive set of guidelines for
the Isleta Gaming Commission to follow when considering or actually listening to patron
disputes. In accomplishing this, the Commission shall act in a responsible and consistent
manner while always adhering to its charge, of safeguarding the assets, property, and
interests of the Pueblo of Isleta.

lM. SCOPE

This regulation applies to all adjudicatory functions and duties over which the
Commission retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03
and any other resolutions or ordinances adopted thereto, the Indian Gaming Regulatory
Act of 1988 and the Isleta/State of New Mexico Indian Gaming Compact. This
regulation does not apply to other tribal entities or agencies within the Pueblo of Isleta
Tribal Government. :

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural.

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

DISPUTE — A conflict, controversy, or claim met by contrary claims or
allegations that require a resolution. -

GAMBLING PROBLEM - Lack of reasonable personal restraint, which may
lead an individual to serious financial hardship.

INTERESTED PARTIES - Any person or entity, which has a significant interest
in the outcome of any Isleta Gaming Decision or formal hearing.

Isleta Gaming Commission Regulation - Revised December 16, 1999


Pueblo of Isleta Gaming Commission

Regulations
TABLE OF CONTENTS
D. Liability Insurance 3
E. Use of Alcohol/Food/Lodging as Promotional Items ----------------- 3
V. Enforcement Activity. 3
VI. Notice of Disciplinary Action for Policy Violations -------------------------- 4
VII. Acknowledgments 4
Commission Certification 5

Chapter 11: Variance Reporting Requirements

1 Authority 2
TL. Purpose 2
TH. Scope 2
IV. Variance Reporting Requirements 2
Vv. Enforcement Activity - 3

ies.af Disciplinary Action Kor Raliey iolatians ama === Laem
VIL Acknowledgments
Commission Certification - — 3

Chapter 12: Marketing & Promotions

1 Authority 2
I. Purpose 2
Tl. Scope ---~ — 2
IV. Definition ------. 2
V. Description of the Promotion 3
VI. Minimum Controls 3
VII. Gaming Commission Review and Approval of Said Promotion... ---------- 3
VIII. Conclusion of Promotions

IX. Written Report of Said Promotion

X. Enforcement Activity

XI. —_— Notice of Disciplinary Action For Policy Violations --
XII. Acknowledgments
Commission Certification



Licensing

Chapter 5
_ f Page 30 of 35

1. The licensee will first report, as soon as possible, to the Office of
the Isleta Gaming Commission to receive a Reinstatement Letter,
the original Gaming License, if one has not already been
issued, and other pertinent documentation or materials. Copies of
all issued documents will be place in the employee’s file.

2. The licensee will then take the Reinstatement letter to the Human.
Resource Office (HR) as proof of their licensure and the HR
Department will proceed from there.

3. Anemployee may not begin work at the Isleta Gaming Operation
or enter the facility until the above mentioned procedures are
complete.

b. Vendor

1. The Commission will send to the vendor, via U. S. Mail, a
Reinstatement Letter along with an original Vendor Gaming
License, if one has not already been issued. Copies of all issued
documents will be placed in the vendor file.

XIV. Reconsideration Review Hearing Procedures

A. A quorum of at least two (2) Commissioner’s shall be present at all

Reconsideration Review Hearings.

. The licensee involved shall have the right to bring an advocate of his or her

choosing to this Reconsideration Review Hearing.

. At this hearing, the Commission shall aliow the licensee and/or his or her

advocate a reasonable opportunity to present the licensee’s argument against
revocation of their license. The licensee and/or their advocate also have the
right to present documented evidence to testify on the licensee’s behalf.

. The Commission, in its discretion, may; for good cause, postpone this Review

(Grant a Continuance), allowing the licensee additional time to obtain and
submit further evidence on their behalf and/or to review submitted evidence
presented at this Review Hearing.

. The Commission has ten (10) business days after the Reconsideration Review

Hearing to render its final decision as to uphold or overturn the provisional
revocation of said license. The Commission shall, in writing, inform the
applicant or licensee of the final decision, via certified mail, return receipt.

~-~A copy of this decision shall be placed in the official licensee’s file.

Isleta Gaming Commission Regulation . Revised December 01, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 6

Investigative Procedures


Chapter 20

Training Requirements Page 8 of 10

2. the words: Certificate of (insert the name of the type of training),

3. date(s) of training,

4. the signature of the Isleta Gaming Operation General Manager,
and

5. the signature of the provider of the training.

VII. PROCEDURE FOR DISTRIBUTION OF ISLETA GAMING
COMMISSION REGULATIONS

A.

The Isleta Gaming Commission shall have thirty (30) calendar days from
the date of enactment to inform, in writing, the General Manager of any
newly created or amendment to any existing Commission Regulation. A
complete copy of the changes shall be given to the General Manager.

The Isleta Gaming Palace General Manager shall have thirty (30) calendar
days from the date of receipt, to duplicate, disburse, and train all Upper
Level Management on the above mentioned documents. A complete copy
of the changes shall be given to the appropriate Upper Level Management
and it is their responsibility to maintain and insert any new or amended
Commission Regulation in their individual Departments SOP Manual.

The Isleta Gaming Palace Upper Level Management shall have thirty (30)
days from the date of receipt of said documents, to train all subordinate
employees on the new or amended regulation. Thereafter, the Isleta
Gaming Commission will begin checking of compliance and will enforce
said regulation(s) or amendment(s) thereto.

PROCEDURE FOR DISTRIBUTION OF ISLETA GAMING PALACE

STANDARD OPERATING PROCEDURES (SOP’s)

A.

After all appropriate approvals are secured and finalized, the Isleta
Gaming Palace General Manager shall have thirty (30) calendar days from
the date of enactment to duplicate, disburse, and train the appropriate
Upper Level Management of any newly created or amendment to any
existing Isleta Gaming Palace Standard Operating Procedure. A complete
copy of the changes shall be given to the appropriate Upper Level
Management and it is their responsibility to maintain and insert any new
or amended SOP in their individual departments SOP Manual.

The Isleta Gaming Palace Upper Level Management shall have thirty (30)
days from the date of receipt of said documents, to train all subordinate
employees on the new or amended SOP(s). Thereafter, the Isleta Gaming
Commission will begin checking for compliance and will enforce said
Standard Operating Procedure or amendment(s) thereto.


Pueblo of Isleta Gaming Commission

Regulations.
TABLE OF.CONTENTS
1. Employee Practices 2
2. Employee Benefits 3
V. Gaming Operations 3
A. Checks and Credit 3
B. Automatic Teller Machine(s) (ATM) ------------------------see---20-+ 3
Cc. Management Contractor(s) -~ ———- 4
D. Construction Standards --- - 4
E. Political Contributions 5
F. Funding Assistance for Treatment of Support Programs coceseeenee —- 5
VI. — Enforcement Activity 5
VII. Notice of Disciplinary Action For Policy Violations ----------------—------. 6
VIII. Acknowledgments 6
Commission Certification 7
Chapter 4: Gaming Equipment or Devices or Supplies
I Authority -- 2
Il. Purpose 2
If. Scope 2
IV. Procedures -. 2
A. Authorities 2
B. Procedure for the ControLof . .. .;
Electronic Gaming Devices (EGD) 3
1. License required; applications --------------------------------- --3
2. Approval of Gaming Devices; applications and procedures -3
3. Access to Electronic Gaming Devices (EGD) ----------------- 4
Cc. Procedures for Certifying/sealing Kobetron Testing
and Verification of Electronic Gaming Devices (EGD) -------—------ 4
1. Procedures for Certifying/sealing Kobetron
Testing and Verification of EGD’s---—----------------—-- —--- 6
2. Procedure for Certifying and Sealing all EGD’s ------------6
D. Progressive Slot Machines _ 9
E. ... Electronic Gaming Device _ os a
(EGD) Pay-out and Odds Posting — 9
F. Central Computerized Reporting and Auditing System --------- ———- 9
G. Class III Gaming Supplies Purchasing ---------------------------------- 10
V. Exceptions 10
VI. — Enforcement Activity 11
VI.

Notice of Disciplinary Action for Policy Violations --------------------------- 11



Chapter 9 _
Concession & Restaurant Health Standards Page 5 of 6

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate.

To the fullest reasonable extent possible, confidentiality is to be maintained in all
applications of this Regulation.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, from time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission. .

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 5
Licensing Page 34 of 35

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees and vendors responsibility
to obtain a Gaming License prior to beginning work or performing business for or with
the Isleta Gaming Operation.

To the fullest reasonable extent possible, confidentiality is to be maintained in all
applications of this Regulation.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, from time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation Revised December 01, 1999


- Chapter 17.
Notification to the Commission Page 11 of 12

any guarantee or promise to any applicant or vendor, of any business dealings or any
continued business dealings whatsoever, nor shall any provision of this Regulation
constitute or be interpreted by any party or tribunal to constitute any contractual rights of
business expressed or implied, or any obligation of business rights created by covenants
of good faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees and vendors responsibility
to obtain a Gaming License prior to beginning work or performing business for or with
the Isleta Gaming Operation(s).

To the fullest reasonable extent possible, confidentiality is to be maintained in all
application of this policy.

This policy may be amended as necessary to-meet the interests of the objectives of
this policy as may be determined, from time to time. All rights to further amend, refine,
and redefine are specifically reserved to the Isleta Gaming Commission.

Isleta Gaming Commission Regulations Revised December 16, 1999


IL
Til.
Iv.
Vv.

VI.

Vil.

VIII.

IX.

Pueblo of Isleta Gaming Commission

Regulation _
TABLE OF CONTENTS
Chapter 9
Concession & Restaurant Health Standards
Authority - 2
Purpose --- 2
Scope ---- — 2
Department of Health and Human Services 2
Food Service Establishment Inspection Report --------------------------------- 3
A. 75 Points and Below 3
B. 76 Points and Above 3
State of New Mexico Department of Environment ----------------------------- 3
A. Inspection -- 3
Enforcement Activity 4
Notice of Disciplinary Action for Policy Violations --------—--------------- 4
Acknowledgments 4

Commission Certification 6


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 7

Patron .
__.._ Dispute Resolution


Chapter 17
Notification to the Commission Page 3 of 12

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

Gaming Facility - the building(s) or structure(s) or premises in/on which Class
II or II] Gaming is conducted within the exterior boundaries of the Pueblo of
Isleta.

IGCR - abbreviation for Isleta Gaming Commission Regulations.

Tribal Official/Government Official - pertains to the Tribal Council member(s),
Tribal Judge(s), Tribal Administrator(s), Governor, Lieutenant Governor(s),
Tribal Treasurer, Commissioners, and Commission Agents.

v. POLICY
A. Casino Games

It is the responsibility of the Isleta Gaming Operation Management to
notify the Isleta Gaming Commission, prior to any and all (new or old)
purchases of or the placing or utilization of Casino Games on the Gaming
Facility floor. This includes, but is not limited to, the purchase of all new
Casino Games and/or the removal, storage, replacement, and/or relocation
of any existing Casino Games. Prior to the aforementioned
purchase/utilization, the following documentation must be given to the
Commission at least thirty (30) days prior to any implementation or
installation of any Casino Game and on a continuous basis thereafter:

1. A copy of any and all proposed Contracts pertaining to that
specific purchase.or purchases. (See Section D. Contracts, 7,
herein, below)

REMINDER: All Contracts must be signed prior to any business
transaction taking place. If the contract is for $25,000.00 or more
it must have a Tribal Council Resolution attached, no exceptions.
(See Section D. Contracts, 7, herein, below)

2. Internal controls and procedures must be in writing and deemed in
compliance by the Commission, also in writing, prior to any
implementation/installation of any Casino Game(s) on the casino
floor.

Isleta Gaming Commission Regulations Revised December 16, 1999


Notification to the Commission

Chapter 17
at Page 6 of 12

Procedures (SOPs) Manual making sure to adhere to the format,
i.e., Chapters, headings, titles, policy numbers, table of contents,
consistency within the entire document, etc.

Submit the newly drafted policy/procedure (type written only)
along with a copy of the current policy/procedure in use, if one
exists. Using the chain of command submit the draft to the Isleta
Gaming Palace Compliance Department. The Compliance
Department will work with the submitting Department Manager to
rectify any problem areas. Upon approval the Compliance
Department will forward the policy/procedure to the General
Manager who will, upon approval, submit the aforementioned to
the Isleta Gaming Commission. This applies to existing
policy/procedure changes, as well as newly developed or needed
policies/procedures.

The Commission has thirty (30) calendar days from receipt to
review the proposed policy/procedure taking into account all
standards necessary to reach an equitable conclusion;

If the Commission finds the suggested policy/procedure is in
compliance with applicable regulatory requirements, the
Commission will, in writing, inform the Isleta Gaming Operation
Management of this decision. The Isleta Gaming Operation
Management will then have the policy/procedure implemented and
inform all necessary parties, including the Commission, as to when
it will be implemented.

If the Commission finds the suggested policy/procedure is not in
compliance with applicable regulatory requirements, the
Commission will notify Isleta Gaming Operation Management, in
writing, of this decision along with the reasons why the policy was
deemed non-compliant. If such reasons are a matter of
confidentiality, the Commission in its’ discretion, may or may not
divulge any reasoning to Management. *:

The Commission Will inform, in writing, the Isleta Gaming
Operation General Manager of any concerns or objections to any
policy/procedure or portion thereof. Thereafter, Isleta Gaming
Palace Management will have thirty (30) regular days from receipt,
to correct/revise and resubmit the aforementioned policy/procedure
to the Commission. Managertient may request, in writing, that the
Commission grant a hearing to explore Commission concerns or
objections. If such concerns and/or objections are not corrected

Isleta Gaming Commission Regulations . Seances Revised December 16, 1999



Chapter 5
Licensing Page 13 of 35

3) review the criminal record, if any, motor vehicle
division record, social security check, credit history,
and relevant financial records of the applicant; and

4) contact any local, state, federal, tribal, or other
government agency referred to.in the application.

c. If an applicant terminates his or her employment before the
background investigation is complete, the investigation shall
continue to completion. The Commission, in its discretion,
may stop the investigation at the applicants written request, if
the background investigation has not begun. The applicant,
however remains liable for the nonrefundable licensing fee
required under Asticle VI of this regulation, regardless of
whether the Commission continues or stops the investigation.
If the applicant reapplies for a license within one hundred
eighty (180) calendar days after the date of termination, no
additional licensing fee shall be charged. If the applicant
reapplies for a license and the one huiidred eighty (180) days
has expired, the applicant must undergo the entire licensing
process, including all fees set forth in this chapter.

d. Employee applicants and licensees shall have a continuing duty
to provide any facts, materials, assistance, or other information
required by the Isleta Gaming Commission, and to fully
cooperate in any investigation conducted by or on behalf of the
Isleta Gaming Commission. Any information relevant to the
application or to the licensee or applicant’s character, or fitness
to be involved with the Gaming Activity or Gaming Operation,
shall be delivered to the Isleta Gaming Commission promptly,
with or without a formal Tequest from the Isleta Gaming
Commission... 7

e, ALL EMPLOYEE APPLICATIONS MUST BE
COMPLETELY FILLED OUT, REGARDLESS OF HOW
MINIMAL THE INFORMATION MAY SEEM. IF THE
QUESTION IS NOT APPLICABLE, THE WORDS “NOT
APPLICABLE” OR ABBREVIATION “N/A” WILL BE
INSERTED AS AN ANSWER TO THE QUESTION
POSED. IF AN APPLICANT DOES NOT POSSESS THE
INFORMATION TO COMPLETE THE APPLICATION,
HE OR SHE MAY REQUEST ADDITIONAL TIME TO
OBTAIN THAT INFORMATION, BUT THE

Isleta Gaming Commission Regulation Revised December 01, 1999



Chapter5 ~* ~
Licensing Page 9 of 35

($250.00) from the primary management’s official’s wages
over a six month period. 0.2 > 4.2

c. Ifa primary management official terminates his or her
employment, either voluntary or involuntary before paying the
entire fee, Human Resources shall deduct as much of the
unpaid amount as allowed by federal law from the primary
management official’s final paycheck. Thereafter, the
Commission may take legal action against the former primary
management official to recover any portion of the fee, which
remains or refer the matter to a collection agency.

d. Pueblo of Isleta Tribal Members being hired as a primary
management official will not be assessed a licensing fee.
However, if that tribal member leaves the employment of the
Isleta Gaming Operation either voluntarily or involuntarily,
within six (6) months of employment, that employee will be
liable to the Isleta Gaming Palace for the full amount of that
employee’s licensing fee. In this event, the Isleta Gaming
Palace will garnish as much of the requisite amount as possible,
allowed by federal Iaw, from the employee’s remaining
paycheck(s). ~

2. All Other Employees

a. Prior to processing the license application, all other employees
shall pay a nonrefundable licensing fee of two hundred dollars
($200.00) to the Isleta Gaming Paiace.’ However, one half (1/2)
of the amount will be borne by the Isleta Gaming Palace and
one half (1/2) by the applicant.

b. Ifan employee chooses not to pay the entire fee up front,
Human Resources shall deduct ten dollars ($10.00) from the
employee’s wages each pay period until the fee is paid in full.

c. Ifan employee terminates his or her employment either
voluntarily or involuntarily, before paying the entire fee,
Human Resources shall deduct as much of the unpaid amount
as possible, allowed by federal law, from the former
employee’s final paycheck(s).' Thereafter, the Commission
may take legal action against the former employee to recover
any portion of the fee, which remains unpaid or refer the matter
to a collection agency.

Isleta Gaming Commission Regulation . »* ~ vs Revised December 01, 1999



Promulgating .
Internal Procedures & Regulatory Provisions Page 4 of 9

Vv.

Fe emmanmanianaapeiaanel

Chapter 2

PROMULGATING REGULATIONS"

A. Format - The format of any proposed Commission rule, regulation,
amendment, or revision will include a clear and concise statement of:

PENI AWAWNS

Title
Authority

Purpose

Scope

Definition(s) (if applicable)

Policy or procedure will follow herein.

Exception(s) (if applicable)

Enforcement Activity (if applicable)

Notice of Disciplinary Action for Policy Violations (if applicable)

10. Acknowledgments (if applicable).
11. Commission Certification

B. Sponsor - The proposed rule, regulation, amendment, or revision shall be
introduced in a Commission meeting. The individual proposing the rule,
regulation, amendment, or revision shall be prepared to address all questions,
which may arise.

C. The Commission must ensure that all rules, controls, policies, regulations,
amendments, or revisions promulgated by the Commission are within the
confines of tribal law, federal law, and the Indian Gaming Compact (if
applicable) before their approval or implementation. _

PROMULGATING ORDINANCES

A. Format - The format of any proposed ordinance or amendment to an
ordinance will include a clear and concise statement of:

PANIAWPYWNE

Title (a number if applicable)

Authority

Purpose

Scope

Definition(s) (if applicable) |

Body of the Ordinance will follow herein.

Certification Wey

All the above must be in the format prescribed by the Pueblo of Isleta
Tribal Council.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 5
Licensing
Authority
Purpose
Scope
Definitions
Application for License

Licensing Fee
Temporary/ Work Permits or Vendor Licenses

Background Investigations
Eligibility Determination
Reporting Requirements (Key Employees
and Primary Management Officials only) 20
Denial of Application and Denial of a Gaming License ----------------------- 21
Issuing a License - 23
A. Key Employees and Primary Management Officials ----------------- 23
B. Employees other than Key Employees

or Primary Management officials . 24
C. Vendors wanenecen nena 24
Suspension, Revocation, and Reinstatement of Licenses ---—---------------~ 25
A. Suspension - 25
B. Revocation

Cc. Reinstatement
Reconsideration Review Hearing Procedure
Method by which all Commission NOTICE’S shall be Sent -
License Renewal
A. Employees
B. Non-Gaming Vendors
Cc. Gaming Vendors



Chapter 5
Licensing Page 4 of 35

Key Employees mean:
1. aperson who performs one or more of the following functions:

Bingo caller;

Counting Room Supervisor;

Chief of Security;

Custodian of gaming supplies or cash;
Floor Manager;

Pit Boss;

Dealer; :

Croupier (person who collects or pays bets)
Approver of credit ; or

Custodian of gambling devices, including persons with access to cash
and accounting records within such devices.

So Erg mo Ro op

2. any other person whose total cash compensation exceeds fifty thousand dollars
($50,000.00) per year;

3. if not otherwise included, the four most highly paid persons in the gaming
operation.

Licensee - any person or entity, who has received a Gaming License, issued by
the Isleta Gaming Commission, to participate in any gaming operations of the
Pueblo of Isleta.

License Application - an application for a Gaming License to participate in the
Gaming Operation of the Pueblo of Isleta:

Licensing Clerk - a Commission employee charged with the duties of handling
licensing records, correspondence, files, etc.

NIGC — means the National Indian Gaming Commission.

Non-gaming Vendor - any person or entity who sells goods or services, other
than gaming equipment, to any Gaming Operations of the Pueblo of Isleta.

Person - any individual.
Primary management official means:
1. any person who has management responsibility for a management contract: or

2. any person who has the authority:

Isleta Gaming Commission Regulation Revised December 01, 1999


Chapter5. ‘
Licensing : Page 33 of 35 corre

2. an imposition of a fine of no less than five hundred dollars ($500.00)
~-----"" and no more than twenty-five thousand dollars ($25,000.00) for
vendors; . .

3. disciplinary action up to and including suspension or revocation of
employee gaming license;

4. disciplinary action up to and including suspension or revocation of
vendor gaming license;

5. the placing of restrictions or conditions on the licensee’s retention
of their gaming license; and/or

6. the combination of any of the above.
XIX. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management, Employees, and Vendors of the Isleta Gaming Operation
are subject to the following action:

1. Refusal to comply or - Fine, denial, suspension,
violation of this policy. revocation, termination
of, and/or restrictions on
any Gaming License.

XX. ACKNOWLEDGMENTS

Employee compliance with this Licensing Regulation is a condition of
employment at or with any Isleta Gaming Operation. Nothing in this Regulation shall be
construed as any guarantee or promise to any applicant or any employee, of any
employment or any continued employment whatsoever, nor shall any provisions of this
Regulation constitute or be interpreted by any party or tribunal to constitute any
contractual rights of employment expressed or implied, or any obligation of employment
rights created by covenants of good faith and fair dealings, either expressed or implied.

Vendor compliance with this Licensing Regulation is a condition of performing
business at or with any Isleta Gaming Operation. Nothing in this Regulation shall be
construed as any guarantee or promise to any applicant or vendor, of any business
dealings or any continued business dealings whatsoever, nor shall any provision of this
Regulation constitute or be interpreted by any party or tribunal to constitute any
contractual rights of business expressed or implied, or any obligation of business rights
- created by covenants of good faith and fair dealings, either expressed or implied. ------—--—_---

Isleta Gaming Commission Regulation --,, Revised December 01, 1999


Chapter 14
Drug Free Workplace Page 4 of 11

prescription drug products which contain popular substances of abuse and are
regulated under the provisions of the Controlled Substance Act of 1970, as
amended.

Prescribed Drug - Any substance for which a prescription has been written by a
licensed medical practitioner for consumption by the individual for whom it is
written or ordered.

Prohibited Drug - Any drug which the use, possession, transfer, transportation,
sale, or storage thereof is illegal, or any other drug, including but not limited to, a
prescription drug(s) used for any reason other than a legitimate medical purpose
as prescribed by a licensed medical practitioner.

Reasonable Suspicion - A supervisor or management level employee of the Isleta
Gaming Operation, the Gaming Commission, or the Casino Licensee’s belief
based upon objective and articulable facts sufficient to lead a prudent person to
suspect that any employee is using drugs or alcohol, or otherwise, is in

violation of this policy.

Under The Influence - For the purposes of this policy, an employee is affected
by a drug, chemical substance, or alcohol, or the combination of a drug, chemical
substance, or alcohol in any detectable manner. The symptoms or influences are
not confined to those consistent with misbehavior, nor to obvious impairment of
physical or mental ability, such as slurred speech or difficulty in maintaining
balance. A determination of influence can be established by a professional
opinion, a scientifically valid test, and, as in case of alcohol, by a lay person’s
opinion.

Vv. POLICY

A. The Isleta Gaming Commission and the Isleta Gaming Operation is hereby
mandated to practice a zero tolerance policy for illegal drugs. Therefore,
the Isleta Gaming Commission and the Isleta Gaming Operation will not
employ any individual who tests positive for illegal drugs, either in the
initial pre-employment drug test or a random drug test thereafter.

B. The use, abuse, reporting to work with detectable amounts in the system,
bringing into the casino, possession, transfer, storage, concealment,
transportation, promotion or sale of the following substances and other
items as listed below, by employees of the casino or the Gaming
Commission is strictly prohibited.

c. The possession of illegal drugs unauthorized controlled substances, look-
a-like, inhalants of abuse, designer and synthetic drugs, alcohol or
intoxicating beverages (including the possession of any detectable amount

Isleta Gaming Commission Regulation z' .i' -«° Revised December 16, 1999


Chapter 13

Surplus Palace Property cae wet Page 3 of 5

SURPLUS PROPERTY - shall be any and all Palace property or equipment,
which has become obsolete or unusable for Palace purposes and is deemed so by
the Palace General Manager.

Palace - Isleta Gaming Palace or its subsidiary(s).

Vv. PROCEDURES FOR DETERMINING SURPLUS PROPERTY

A.

Palace property that has been rendered obsolete or reasonably unusable for
Palace purposes and is deemed so by Palace Department Managers shall
notify the General Manager or his/her designee and the Isleta Gaming
Commission of their determination.

The General Manager shall inspect said property. Only when the General
Manager determines the property is indeed surplus shall said property be
disposed of.

VI. DISPOSAL OF SURPLUS PROPERTY

A.

When Palace property is deemed surplus by the General Manager, the
Pueblo of Isleta Tribal Governor shall be notified of the surplus property.
The Pueblo of Isleta Tribal Government shall be the sole entity that

shall determine in what manner surplus Palace property shall be disposed
of. Notification of all Surplus Property transactions must be given to the
Commission, Surveillance, and security prior to its’ disposal or
disbursement.

If the surplus property in question is a casino game, the Johnson Act, the
Transportation of Gambling Devices Act, and IGCR, Chapters 4, 17, and
18 shall be strictly adhered to.

VII. ENFORCEMENT ACTIVITY

A.

The Commission reserves the right to enforce this policy as follows:
1. an imposition of a fine,

2. disciplinary action up to and including suspension or revocation of
any gaming license,

3. the placing of restrictions and/or conditions on the licensee’s
retention of their gaming license, and/or

4. the combination of any of the above.

Isleta Gaming Commission Regulation re oon Revised December 16, 1999



Pueblo of Isleta Gaming Commission
Regulations

TABLE OF CONTENTS

IV. Definitions 2
Vv. ID Badge Policy 3
A. Employee 3
B. Vendor 5
Cc. Isleta Gaming Commission and Commission Staff Members ------- 7
VI. Issuing ID Badges 8
A. Employee - 8
B. Vendor 9
Cc. Commissioner’s and Commission Staff -------—-------------------- sd
Vil. ID Badge Fees 10
A. Employees 10
B. Vendors 10
Cc. Commissioners and Commission Staff ----------------—--------------- 11
VII. Enforcement Activity 11
IX. _ Notice of Disciplinary Action For Policy Violations ----------------------- ——-11
Xx. Acknowledgments 11
Commission Certification 13
Chapter 20: Training Requirements
I Authority 2
Il. Purpose 2
Ill. Scope 2
IV. Definitions 2
Vv. Policy 3
A. General Manager 3
B. Upper Level Management 4
c. Subordinate Employees 6
VI. The Role of the Human Resource Department ---------------------------—------ 7
VII. Procedure for Distribution of Isleta Gaming Commission Regulations —--- 8
VII. Procedure for Distribution of Isleta Gaming Palace
Standard Operating Procedures (SOPs) 8
IX. _ Enforcement Activity 9
X. Notice of Disciplinary Action for Policy Violations ------------------------- 9
XI. Acknowledgments 9
Commission Certification 10


Chapter 13
Surplus Palace Property Page 5 of 5

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 13, Surplus Palace Property, was duly REVISED,
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with _2_ voting for, _0 voting against, and _0_ abstaining.

Vacant

Subscribed and sworn before me on this the _16th_ day of December, 1999.

2NOTARY 7 - |

My Commission Expires:

Isleta Gaming Commission Regulation Revised December 16, 1999


Licensing

Chapter 5
Page 8 of 35

may be denied.

. All applicants must cooperate fully with the Commission and any agent of the

Commission with respect to the background investigation of the applicant.

All applicants must adhere to all applicable Isleta Gaming Commission
Regulations and Isleta Gaming Operations, Standard Operating Procedures,
when in the employ of the Isleta Gaming Operation or conducting any
business with or on, any Isleta Gaming Operation premises.

. Employees of the Isleta Gaming Organization are ineligible for a Gaming or

Non-Gaming Vendor License, which would be deemed a conflict of interest
by the Commission. (Also see, IGCR, Chapter 18, Code of Conduct, hereto).

Acceptance of an Isleta Gaming Commission License or Permit or renewal
thereof by a licensee or permit holder constitutes an agreement on the part of
the licensee or permit holder to be bound by all the regulations of the
Commission as the same now are or may hereafter be amended or
promulgated. It is the responsibility of the licensee to keep informed of the
content of all such regulations, and ignorance thereof will not excuse
violations.

VI. LICENSING FEE

A. Licensing grants employees and vendors the privilege of participating in the

regulated gaming operations of the Pueblo of Isleta. In exchange for this
privilege, all applicants shall pay a nonrefundable licensing fee, as set forth in
this Article. :

The Commission shall not issue a license (in any form) to an applicant until
the applicant has paid or made arrangements to pay the licensing fee required
under this Article. ~

1. Primary Management Officials:

a. Prior to processing the license application, Primary
management officials shall pay a nonrefundable licensing fee
of five hundred dollars ($500.00) to the Isleta Gaming Palace.
However, one half (1/2) of the amount will be borne by the
Isleta Gaming Palace and one half (1/2) by the applicant.

b. Ifa primary management official.chooses not to pay the fee up
front, Human Resources shall deduct two hundred fifty dollars

Isleta Gaming Commission Regulation Revised December 01, 1999



Article V — Repeal of Resolutions
1. By adoption of this Resolution, the Tribal Council hereby revokes and

rescinds Resolutions 95-03 and 00-108 effective upon adoption of this
Resolution.

CERTIFICATION

We, the undersigned officials of the Pueblo of Isleta, hereby certify that the

foregoing Resolution was duly adopted by the Pueblo of Isleta Tribal Council at a regular
meeting held on . , 2002, a quorum present, with voting
for, © voting/against, and { abstaining.

y , |
Boo fons e-dof

Afvino Lucero
overnor

“San AE

Ben Lucero
President of the Council

Attest:
GEae
Sécret:

Page 5 of 5


Chapter 16
Gifts, Gratuities, & Solicitations Page 7 of 9

Cc. Non-employees
1. Non-employees are prohibited from soliciting or distributing
products, materials, wares, food, or other merchandise at, in, and/or
on the premises of a Gaming Operation without a vendor license.
(See IGCR, Chapter 5, Licensing)
D. Tribal Government Officials
1. Officials ( Tribal/Commission/Commission staff) may not solicit,
in any form, for charities or causes at, within, and/or on the
premises of any Gaming Operation.
VII. ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this policy as follow:

1. an imposition of a fine of no less than fifty dollars ($50.00) and no
more than five hundred dollars ($500.00) for employees;

2. an imposition of a fine of no less than five hundred dollars
($500.00) and no more than twenty-five thousand dollars
($25,000.00) for vendors;

3. Disciplinary action up to and including suspension or revocation of
any employee gaming license,

4. Disciplinary action up to and including suspension or revocation of
any vendor gaming license,

5. Banishment from the Gaming Operation(s),
6. Prohibition of a particular event,
7. Criminal prosecution, and/or
8. the combination of any of the above.
IX. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS
A. All Management, Employees, and Vendors of any Isleta Gaming

Operation and Pueblo of Isleta Officials are subject to the following
action:

Isleta Gaming Commission Regulations . Revised December 16, 1999


Code of Conduct

Chapter 18
- Page 8 of 14

Cc. Commissioner’s, Commission Staff, and Tribal Officials

1.

A conflict of interest occurs when any Commissioner, Commission
staff member, or Tribal Official is in a situation in which he/she
can gain from information or from personal contact and such gain
or potential gain would not be available except through association
with the Isleta Gaming Operation. Such conflict of interest is to
the benefit of the Commissioner, staff member, or Tribal Official
or to the detriment of the Isleta Gaming Operation, either
monetarily or to its public image. All such situation are strictly
prohibited.

Commissioner’s, Commission Staff, and Tribal Officials must
avoid financial, business, and personal relationships which might
be opposed to Isleta Gaming Operation interests or which might
impair independent judgment related to Isleta Gaming matters.

Each Commissioner, Commission staff member, or Tribal Official
who has an interest in or a relationship with, a vendor, supplier or
an employee of the Isleta Gaming Operation must report this fact
and carefully follow any precautionary steps established by the
Isleta Gaming Commission. The Isleta Gaming Commission
Regulation, Chapter 18, Section C, 4, below, details the policies
and procedures for reporting possible conflicts of interest.

Commissioners, Commission staff members, and Tribal Officials
must report all conflicts of interest or potential conflicts of interest,
in writing, via interoffice memo, letter, etc., to the appropriate
Commissioner or Tribal Official. The Commission will then, if
necessary, address such a potential conflict in writing, via hearing
or other acceptable method.

In the event that a situation arises in which a Commissioner,
Commission staff member, or Tribal Official is related, through
immediate family ties, to a subordinate Commission employee,
Isleta Gaming Operation employee, or business vendor, that
Commissioner, Commission staff member, or Tribal Official will
immediately excuse himself/herself from participating in any
proceeding and/or transaction and advise the other party that this
situation needs to be dealt with by an objective individual(s) either
on the same level or higher in the chain of command of the Isleta
Gaming Commission 6t Isleta Gaming Organization. This may,
from time-to-time, deem it necessary that the Governor or Tribal
Council preside over said situation, proceeding, or transaction.

Isleta Gaming Commission Regulation . Revised December 16, 1999


Chapter 20
Training Requirements Page 2 of 10

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

I. PURPOSE

The purpose of this regulation is to provide a comprehensive set of guidelines to
act as a Minimum Internal Control, in which the Isleta Gaming Operation must meet or
exceed, in providing adequate and timely training to all employees of any Isleta Gaming
Operation.

Ill. SCOPE

This regulation pertains to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
Tribal Resolution or Ordinance adopted thereto, the Indian Gaming Regulatory Act of
1988, and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact.

This regulation applies to all Pueblo of Isleta Gaming Enterprises, Facilities,
and/or Operations which includes but is not limited to the Isleta Gaming Palace and
Palace West. This regulation does not apply to other Tribal entities or agencies within
the Pueblo of Isleta Tribal Government.

Iv. DEFINITIONS

The following definitions are intended to clarify the items covered in this

regulation. Throughout this document the use of these definitions in the singular,

also includes the plural.

Commission - the Isleta Gaming Commission.

IGCR - the Isleta Gaming Commission Regulations.

New Hire - any individual that has been hired for employment purposes by any
Isleta Gaming Operation.

SOP?’s - the Standard Operating Procedures of any Isleta Gaming Operation.


Chapter 15

Race and Sports Book Computerized _- Page 13 of 16

B.

e. The patron’s approved credit limit or the
amount of the patron’s initial front money
deposit.

f. The patron’s account number with the book.

g. The date the patron’s account with the book is
opened.

For each account established-by a book permitting a patron to
wager on credit the book shall:

1. Record and verify such information as is necessary for the
efficient collection of debts, including the name and address
of the patron for whom the book establishes the account.

2. Comply with the requirements for establishing wagering
accounts to Section VI, Wagering Standards of this
document.

XV. TELEPHONE (Wire Communication) WAGERING (if applicable)

A.

Procedures are established to prevent the acceptance of wagers
from persons other than the bettors for whom the wagering
accounts are established, to ensure the proper identity of patrons
making wagers by wire communication/over the telephone (e.g.,
account numbers or codes), and to verify that the patron is calling
from within the authorized gaming jurisdiction.

Prior to accepting a wager over the phone the bettor appears at
the book and has evidence of his identity and residence verified by
a book employee. (See Section XVI, Wagering Accounts)

At the time of establishing the account the employee records the
patron information required by industry standards and prepares a
statement supporting the verification of the information with his/her
signature and a key employee signature. wee

For each account established, the computer shall maintain a
detailed record documenting each wagering transaction and all
deposits/withdrawals for that account as follows:

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter5 |”
Licensing i" ~ Page 25 of 35

any vendor after making a determination that the vendor is or is not
eligible to receive a license under Article IX, herein.

2. Failure to provide any-information required or requested constitutes
sufficient grounds for the Commission to deny or revoke any gaming
license and/or require termination of the applicant’s or licensee’s
gaming contract or agreement between the Isleta Gaming Operation
and any person or entity who failed to provide the required or
requested information. (See IGCR, Chapter 17, Notification to the
Commission V (D). Contracts, hereto)

XUI. SUSPENSION, REVOCATION, AND REINSTATEMENT OF A GAMING
LICENSE

A. Suspension
1. For a Noncompliance Violation °

a. The Commission reserves the right to invoke, as a disciplinary
measure, for any non-compliance violation, a suspension of a Gaming
License. The duration of such a suspension, shall be at the sole
discretion of the Isleta Gaming Commission.

b. Suspended licenses for a noncompliance violation are not entitled to a
hearing.

c. Suspension, in this form, shall be included in the NOTICE OF
VIOLATION to the individual or entity holding said license.

d. As an alternative to suspending a license, the Commission may impose
fines or lesser penalties on all licensees’. The Commission may also
place conditions or restrictions on the retention of any license.

2. For Investigative Purposes after a Gaming License has been issued

a. The Commission reserves the right to suspend a license or permit
pending the results of any investigation.

b. The Commission shall suspend a license, of any form, if there is
reasonable cause indicating that'the licerisee may no longer be eligible
to participate in the gaming operations of the Pueblo of Isleta under the
requirements of Article EX; herein.

c. Upon suspending a license, the Commission shall notify the licensee,

Isleta Gaming Commission Regulation ~ * Revised December 01, 1999


Chapter 3
Gaming Participation & Operation Page 3 of 7

a. The hiring or job assignment of any person under the age of
twenty-one (21) or who has not been licensed in accordance
with tribal law, the Compact, and the IGRA to work in Class II
or III Gaming activities is prohibited.

b. Exception: Food & Beverage employees working in Class II
areas only. Food & Beverage employees may be under twenty-
one (21) years of age, but must be over eighteen (18) years of
age to be employed by any Isleta Gaming Operation.

2. Employee Benefits

a. Standards for the Gaming Operation of the Tribe are at least
equivalent to those contained in the federal Fair Labor
Standards Act of 1938, the federal Occupational, Safety, and
Health Act of 1970, the federal Family and Medical Leave Act,
and the regulations issued pursuant to those acts.

b. Employment benefits will be provided to all employees of a
gaming establishment, including, at a minimum, sick leave, life
insurance, paid annual leave and medical and dental insurance
as well as unemployment insurance and workers’ compensation
insurance through participation in programs offering benefits at
least as favorable as those provided by comparable state
programs.

v. GAMING OPERATIONS
A. Checks and Credit
1. A gaming enterprise will not cash any paycheck or any type of
government assistance check, including Social Security, AFDC,

pension and other similar checks, for any patron.

2. A gaming enterprise will not extend credit by accepting IOU’s to
markers from its patrons.

B. Automatic Teller Machine(s) (ATM)
1. Automatic teller machines on Gaming Facility premises will be

programmed so that the machines will not accept cards issued by the
State to AFDC recipients for access to AFDC benefits.

Isleta Gaming Commission Regulation Revised December 16, 1999


Licensing

Chapter 5
Page 23 of 35

C. An applicant for a Gaming License that has been deemed unsuitable or
ineligible by the Commission has no appeal rights herein. Therefore, the
Commission may deny a Gaming License Application without a hearing
based, in whole or in part, upon Article IX, Eligibility Determination, of this
Chapter.

XII. ISSUING A LICENSE

Only the Commission has the authority to sign a Gaming License of any type,
thereby executing and rendering the License valid and usable. However, the
Commission may designate, from time-to-time, this signatory authority to a
Commission Agent. This designation must be explicitly stated in writing by the
Commission and specify a time limit.

A. Key Employees and Primary Management Officials

1.

After receiving the investigative report required under Article X(B),
the National Indian Gaming Commission and the State Gaming
Representative have thirty (30) regular days to notify the Commission
of any objections to the licensing of the applicant.

Within the thirty (30) day period, The National Indian Gaming
Commission or the State Gaming Representative may request the
Commission to submit additional information on the applicant. Such a
request shall suspend the thirty (30) day period until the National
Indian Gaming Commission or the State of New Mexico Gaming
Representative receives the additional information.

If, within the thirty (30) day period, the National Indian Gaming
Commission and the State Gaming Representative notify the
Commission that there are no objections to the licensing of the
applicant, the Commission may issue a license to the applicant.

If, after the thirty (30) day period has expired, the National Indian
Gaming Commission and the State Gaming Representative have failed
to notify the Commission of any objections to the licensing of the

’ applicant, the Commission may issue a license to the applicant.

. If, within the thirty (30) day period, the National Indian Gaming

Commission or the State Gaming Representative provides the
Commission with a list of objections to the licensing of the applicant,
the Commission shall reconsider the application in light of the
objections. After reconsidering the application, the Isleta Gaming

Isleta Gaming Commission Regulation pwio bee Revised December 01, 1999


Drug Free Workplace

Chapter 14.
es Page 8 of 11

statistically valid basis ‘or the Commission or Casino Management
may choose to do entire departments, at any time, at its discretion.

9. Employees will be tested in order to comply with contractual
agreements, client/customer job site requirements, or
governmental/regulatory regulations and requirements.

Any Contractor licensed by the Commission may, to the extent permitted
by law, conduct a search and inspection of its’ own employees and the
employees of any of its subcontractors performing work for the casino on
casino property, provided that such contractor first notifies the
Commission of such a purposed search and inspection.

Vil. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A.

—

Cc.

D.

No employee search, inspection, or testing procedure (urine, blood/plasma,
saliva/breath) will be conducted without the written consent from the
employee(s) involved. If an employee declines consent to a search,
inspection, or test, the employee shall be terminated.

Entry into the casino or onto the premises constitutes the recognition of
the right of the Commission or its’ authorized representatives to search,
inspect, or test the employees for drugs or alcohol, as well as search their
personal effects, vehicles, tool boxes, desks, lockers, food or beverage
containers, clothing, and any other property of the employee(s) while
entering, on, or departing the casino or premises.

All employees of the Casino, the Casino Management, and the Gaming
Commission are subject to the following action:

1. Refusal to participate in Termination of license and/or
search, provide a urine, termination of employment.
Blood, plasma, saliva, or
breath sample:

2. Positive result: _ Disciplinary action up to and

inchiding termination of

license and/or employment.

Any employee who is found in possession, use, or transportation of any
illegal substances, contraband, or any of the herein mentioned drugs,
chemical substances or property, or unauthorized items, or who has been
convicted of a drug related offense, will be subject to disciplinary action,
up to and including termination of license and or employment. Preliminary

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 5

Licensing Page 16 of 35

1. The Commission may delegate all or any part of its obligation to

conduct background investigations under these regulations to an
outside investigative agency(s).

2. Neither the Isleta Gaming Commission, the Tribe, or any agency with
which the Commission contracts to conduct background
investigations, or the employees of any of the foregoing, may be held
liable for any inaccurate information obtained through such an
investigation.

E. Review by the Commission

1. The Commission shall review the results of all background
investigations.

2. Ifthe Commission finds that the scope of a background investigation
was not adequate or that sufficient information was not obtained, the
Commission shall perform additional investigations on the applicant.

3. When reviewing the results of a background investigation, the
Commission shall document any information that calls into question
whether an applicant meets the eligibility requirements of Article IX,
herein.

4. The Commission shall conduct follow-up investigations on all problem
areas in an application, including but not limited to:

a. information omitted in the initial application, including but not
limited to, information about former employers, criminal
history, previous residences, ownership of businesses, etc.;

b. bad credit or unusually large amounts of debt; or

c. any other item that appears suspicious or unusual.

5. The Commission shall document the results of all follow-up
investigations in detail. ‘--
F. Fingerprinting
The Commission shall collect fingerprints from all applicants and forward

the fingerprints to the Isleta Police Department. The Isleta Police
Department shall then forward the fingerprints to the National Indian

Isleta Gaming Commission Regulation . Revised December 01, 1999


Chapter 2
Promulgating
Internal Procedures & Regulatory Provisions Page 6 of 9

VIII. METHODS OF ENFORCING RULES, CONTROLS, REGULATIONS,
MINIMUM INTERNAL CONTROL STANDARDS, GAMING LAWS,
OTHER APPLICABLE LAWS, POLICIES, OR PROCEDURES

The following methods of enforcement shall be utilized by the Isleta Gaming
Commission or their agents when initially addressing infractions or violations of
any rule, regulation, control, regulation, minimum internal control standard,
gaming law, other applicable law, policies, or procedures:

A. Notice of Infraction

1. A Notice of Infraction form will be completed for all infractions
that are observed within any Isleta Gaming Operation by the
Commission Auditors, Inspectors, and Investigators using form
number GAMO077. All information included on this form must be
legibly hand written or typed allowing it to be easily discernable.
A Notice of Infraction is for internal use with a casino and does not
apply to outside entities such as vendors.

2. The following are guidelines for properly filling out specific
section of the Notice of Infraction:

a. The section ranging from Date of Write Up through Name
of Infraction shall be completed by the Commission Agent
issuing the Infraction except for the Department Lead and
Commissioner Acknowledgment which must be personally
signed off on or initialed by the Commission. Department
Lead and a Commissioner.

b. CITATION: The infraction cited shall be identified in this
section from the proper document citation wherein a law
regulation, policy, or procedure has been violated, e.g.,
IGCR, Department SOP, IGRA, MICS or other written law
or policy. “ :

c. QUALIFYING CRITERIA: Describe the infraction in
specific terms as to what took place.

d. CORRECTIVE ACTION BY DEPARTMENT
MANAGER: This séction is to be filled out by the
Department Manager listed at the top of the “Notice” and a
copy of the completed “Notice” returned to the

_ Commission within the allotted time perimeter listed in

Isleta Gaming Commission Regulation ~ Revised December 16, 1999


Chapter 4

Gaming Equipment or Devices or Supplies = Page 5 of 13

5.

All deliveries of electronic gaming devices, regardless
of origin, type, amount, or manufacturer must have a
Commissioner or their designee present, Security
present, and Surveillance must be notified prior to any
products or merchandise being unloaded at or on the
gaming facilities and/or premises. (Also, see Chapter
17, Notification to the Commission, hereto)

aa. Only a Commissioner or their designee are
authorized to break the seal on delivery
vehicles. In the event a delivery vehicle is
not sealed, it may not be opened until a
Commissioner or their designee is present.

bb. — - It is the responsibility of the Slots Manager
or their designee to inform the Commission,
in writing, at least five (5) days in advance
of all expected deliveries of gaming devices.

b. Technicians will sign the Machine Access Log, including date,
time, and unit number when opening a machine and must
notify Surveillance of all actions being taken to service the
machine. Spot checks will be performed by the Gaming
Commission Inspectors and designees to verify that this
procedure is followed. In the event of an infraction,
disciplinary action(s) will be taken as follows:

1.

1* infraction - written up

2. 2TM infraction - 3 day suspension

3.

4.

3" infraction - termination and possible revocation of
gaming license.

Depending on the severity of the infraction, the
Commission reserves the right to disregard numbers 1
and 2, above and implement number 3. (Also, see
Chapter 5, Licensing)

c. Any action performed within any respective slot machine or
EGD will be recorded by the Slot Technician on the “Isleta
Gaming Palace Slot Security Control Log” as follows:

1. Machine #

2. Slot Serial #

3. Date

4. Time

Isleta Gaming Commission Regulation

Revised December 16, 1999


Chapter 15

Race and Sports Book Computerized Page 7 of 16

The system indicates the amount of cash that should be in a
given drawer. - oo

Writers and cashiers are not permitted access to this
information without supervisory approval.

B. For each writer station a summary report is completed at the
conclusion of each shift including:

1.

2.

3.

Computation of net cash proceeds for the shift.
Computation of cash turned in for the shift.

Signatures of two (2) employees who have verified the cash
tured in for the shift.

x. EMPLOYEE SEGREGATION

A. Employees who write or cash tickets do not perform administrative
or supervisory functions. (Administrative functions included setting
up events, changing event data, and inputting results at any time.
Supervisory functions include approving void tickets, large wagers,
and access to cash information in the computer.)

B. Race and sports book employees are prohibited from wagering on
tace/sports events.

XI. COMPUTER REPORTS

A. At least the following types of reports are maintained (if applicable):

1.

2.

Write transaction reports.
Payout transaction report.
Telephone transaction report.
Credit transaction report.
Results report.

Futures reports.

Unpaid winners report.

Isleta Gaming Commission Regulation . . Revised December 16, 1999


Chapter 5
Licensing Page 10 of 35

d, Pueblo of Isleta Tribal Members will not be assessed a
licensing fee. However, if a tribal member leaves the
employment of the Isleta Gaming Palace either voluntarily or
involuntarily, within six (6) months of employment, that
employee will be liable to the Isleta Gaming Palace for the full
amount of that employee’s licensing fee. In this event, the
Isleta Gaming Operation will garnish as much of the requisite
amount as possible, allowed by federal law, from the
employee’s remaining paycheck(s).

3. Gaming Vendors

Prior to processing a license application, all Gaming Vendors shall
pay, in full, a nonrefundable licensing fee of two thousand five
hundred dollars ($2,500.00), required under this Section, to the
Commission before participating in the gaming operations of the
Pueblo of Isleta. All Gaming Vendors shall renew their license
every two (2) years. In order to renew a license, a gaming vendor
shall undertake the entire licensing process, including fees, as set
forth in this Chapter. (Also, see IGCR, Chapter 17 Notification to
the Commission)

4. Non-Gaming Vendors

a. Prior to processing a license application, all Non-gaming
Vendors shall pay, in full,-a nonrefundable licensing fee of two
hundred dollars ($200.00), required under this section, to the
Commission before participating in the Gaming operation of
the Pueblo of Isleta. All non-gaming vendors shall renew their
license every two (2) years. In order to renew a license, a non-
gaming vendor shall undertake the entire licensing process,
including feés, as set forth in this Chapter. (Also, see IGCR,

‘ Chapter 17, Notification to the Commission)

b. Pueblo of Isleta Tribal Members who own a business, which by
Commission definition, is deemed non-gaming will not be
assessed a licensing fee, but must comply with the entire
licensing process as set forth in this Chapter. (Also, see IGCR,
Chapter 17 Notification to the Commission)

Isleta Gaming Commission Regulation Revised December 01, 1999


Chapter 2
Promulgating
Internal Procedures & Regulatory Provisions Page 9 of 9

CERTIFICATION 2

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulations, Chapter 2, Promulgating Internal Procedures & Regulatory
Provisions, was duly REVISED, ORDAINED, ADOPTED, AND RATIFIED on this
the _16th_day of December, 1999, at a duly called meeting of the Gaming Commission
of the Pueblo of Isleta, at which a quorum was present, with _2_ voting for, 0 voting

against, and _0_ abstaining.

Gi

cretary-Treasurer

a,
ATIEST gee

Subscribed and sworn before me on this the _16th_ day of December, 1999.

ODESSA A. MONTOYA NOTARY
ST wy conmiitn eine
My Commission Expires: Wy Y] J ; ROL
tht
Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 14

Drug Free Workplace Page 6 of 11

6. The employee shall not:consume the prescribed drug or medication
more often than as prescribed by the employee’s physician and as
set out on the label of the vial.

The Gaming Commission reserves the right to have its physician
determine if use of a prescription drug or medication by an employee
produces affects which may increase the risk of injury to employee or
other employees. If such a finding is made, the Commission reserves the
right to place such an employee on leave pending reinstatement of
employment with a written note from the Commission’s physician.

Any employee who is convicted of any criminal drug statute must notify
his/her supervisor or his/her designated representative and the
Commission of the conviction within five (5) days.

VI. ENFORCEMENT ACTIVITY

A.

The Commission or the Management for the casino will enforce this
Regulation by job site searches, urine/substance screening and blood
plasma and/or saliva/breath testing.

The Commission reserves the right to conduct security searches and
inspections independently or through the Casino Management of
employees, persons and their effects (such as, but not limited to, lockers,
baggage, briefcases, lunch boxes, food/beverage containers, desks, tool
boxes, clothing, and vehicles) for the purpose of determining if such
employees are in possession, use, transportation, or concealment of any of
the prohibited items and substances covered by this policy. All searches
that are conducted by authorized outside search and inspection specialties
will be in the presence of a Commission representative. At no time will
employees be touched during a search or inspection by the outside search
and inspection specialists, the Gaming Commission, security personnel, or
any other person(s) representing the Gaming Commission or Gaming
Palace.

The Commission reserves the right to require employees to submit to urine
drug and/or alcohol screens, blood or plasma tests, saliva/breath tests, or
other examinations or tests as deemed appropriate to determine the use of
illegal or unauthorized drug, alcohol, or chemical substance prohibited by
this policy or to establish the employee’s fitness for duty.

Urine drug and/or alcohol screening, blood/and or plasma testing, or
saliva/breath testing may be used by the Commission or the Casino
Management in any of the following situations:

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 6
Investigative Procedures Page 7 of 8

teviewed and a conclusion shall be formulated from said evidence.

E. A timely verbal report of any conclusion(s) shall be given to the Commission
by the investigator.

F. A final written report shall be prepared by the investigator and presented to
the Commission.

IX. LIMITATIONS ON INVESTIGATIONS

If during an investigation evidence is uncovered which implicates improprieties
that go beyond the investigative parameters of the Commission, i.e., beyond mere
regulatory violations, the Commission shall, at its discretion, cease all inquires
and notify the proper authorities (Isleta Tribal Police, Federal authorities, or the
appropriate state, county, or city authorities). The investigator, at the direction of
the Commission, shall relinquish and obtain a receipt prior to releasing all
gathered evidence and turn over the investigation to the appropriate authorities.

Isleta Gaming Commission Regulation . Revised December 16, 1999


Chapter 16

Gifts, Gratuities, & Solicitations Page 5 of 9

table” items from any individual or entity, be it a contractor, vendor,
patron, or other, at any time, at any place within the premises or away
from the premises of any Pueblo of Isleta Gaming Operation(s).

B. Employees

1.

Isleta Gaming Palace employees shall not allow their judgment or
impartiality to be questioned by accepting any gift, gratuity, favor,
or promise of such action, from any individual or vendor or official
with whom the Isleta Gaming Palace is affiliated with or doing
business or proposing to do business with. Gifts or gratuities of
any value shall be returned to its place of origin or delivered to the
Isleta Gaming Palace General Managers Office located at 11000
Broadway SE, Albuquerque, NM 87105.

The offering or giving of gifts, gratuities, or entertainment to Isleta
Gaming Palace employees by any individual or vendor or tribal
officials or personnel is strictly prohibited. The penalties for such
action can be severe for both the giver and the receiver. No offer
of a gift or gratuity or actual gift or gratuity, including meals,
tickets to sporting events, transportation, etc., made to a Isleta
Gaming Palace employee shall be accepted.

Cc. Tribal Government Officials

1.

Pueblo of Isleta Government Officials shall not allow their
judgment or impartiality to be questioned by accepting any gift,
gratuity, favor, or promise of such action, from an Isleta Gaming
Palace employee or individual or vendor or contractor with whom.
the Isleta Gaming Palace or its subsidiary(s) is affiliated with,
doing business with, or proposing to do business with. Gifts or
gratuities of any value shall be returned or delivered to the Pueblo
of Isleta Tribal Government Offices. (See NOTE below for
address) oad ‘

The offering or giving of gifts, gratuities, or entertainment to
Pueblo of Isleta Government Officials by Isleta Gaming Palace
employees or vendors or contractors is strictly prohibited. The
penalties for such action can be severe for both the giver and
receiver. No offer of a gift or gratuity or actual gift or gratuity,
including meals, tickets to sporting events, transportation, etc.,
made to a Government employee shall be accepted.

Isleta Gaming Commission Regulations La . Revised December 16, 1999


Chapter 4
Gaming Equipment or Devices or Supplies Page 12 of 13

VI. ACKNOWLEDGMENTS |

Employee compliance with this Regulation is a condition of employment at or
with the Isleta Gaming Operation(s). Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or any employee, of any employment or any
continued employment whatsoever, nor shall any provisions of this Regulation constitute
or be interpreted by any party or tribunal to constitute any contractual rights of
employment expressed or implied, or any obligation of employment rights created by
covenants of good faith and fair dealings, either expressed or implied.

Vendor compliance with this Regulation is a condition of performing business at
or with the Isleta Gaming Operation(s). Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or vendor, of any business dealings or any
continued business dealings whatsoever, nor shall any provision. of this Regulation
constitute or be interpreted by any party or tribunal to constitute any contractual rights
expressed or implied, or any obligation of business rights created by covenants of good
faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees and vendors responsibility
to obtain a Gaming License prior to beginning work or performing business for or with
the Isleta Gaming Operation(s).

To the fullest reasonable extent possible, confidentiality is to be maintained in all
applications of this Regulation.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, from time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 6
Investigative Procedures Page 2 of 8

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of the all Gaming
Operation of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta
Gaming Commission pursuant to Resolution 95-03 enacted January 28, 1995 and any
ordinances adopted thereto.

I. PURPOSE

The Isleta Gaming Commission shall investigate any and all illegal or suspicious
activities, which occur in the day-to-day operations of the Isleta Gaming Palace or any
other tribal gaming enterprise. This is in order to ensure and protect the integrity of all
gaming operations of the Pueblo of Isleta. The purpose of this regulation is to effectively
regulate the type and extent of investigations, which the Commission shall pursue with
regard to gaming operations as it seeks to carry out its primary duty of safeguarding the
assets to the Pueblo of Isleta.

I. SCOPE

This regulation shall apply to all investigations as the Commission may deem
necessary in the pursuit of its primary duty. The Isleta Gaming Commission, by law, has
unrestricted access to the Gaming Facility during all hours of Gaming Activity, and shall
have immediate and unrestricted access to any and all areas of the gaming facility at any
hour for the purpose of ensuring compliance with the provisions of the Compact, IGRA,
Commission Regulations, Standard Operating Procedures, and all applicable Tribal, and
Federal Laws. (For further detail on unrestricted access see IGCR, Chapter 1,
Commission Regulation Authority, V(B)11)

Iv. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural.

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

Commission Investigator - an employee of the Isleta Gaming Commission
whose specific duties and responsibilities as specified by the Commission in the
job description for the position of Commission Investigator or a specific
designation delegated by the Commission to an individual to fulfill a specific

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 16
Gifts, Gratuities, & Solicitations Page 9 of 9

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 16, Gifts, Gratuities, & Solicitations was duly
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with 2 voting for, _0_ voting against, and _0_ abstaining.

Vacant

Chairman

Fives AM hen
“ATRICIA L. IRON

Vice-Chairman

RNEST C-FARAMILLO
Secretary-Treasurer

ATTEST

Subscribed and sworn before me on this the _16th_ day of December, 1999.

My Commission Expires: may j t LOZ.

Isleta Gaming Commission Regulations : - Revised December 16, 1999


ID Badges

Chapter 19
Page 7 of 13

10.

11.

12.

In the event a vendor neglects to bring their ID Badge on
premises, that vendor must report to the Isleta Gaming
Commission.

In the event an vendor looses their ID Badge and the Commission
Office is closed, Security may issue a Visitors Badge for that
immediate situation. However, the vendor must report to the
Office of the Isleta Gaming Commission as soon as it opens on the
next business day. This situation will be written up as a violation
of procedure if the vendor fails to appear at the Gaming
Commission to obtain a new ID Badge.

Select vendors have access to highly sensitive areas of the Casino.
Therefore, it is imperative that the Security Department verify the
identity of all individuals carrying a Vendor ID Badge, through
brief detainment of said individual before allowing access to such
sensitive areas.

In the event a vendor, voluntarily or involuntarily terminates
their business dealings with the Isleta Gaming Operation, the
issued ID Badge (regardless of type) must be returned to the
Office of the Isleta Gaming Commission before any final or
outstanding payment is issued to the vendor. Thereafter, the
issued ID Badge(s) is to be kept in that vendors individual
Commission file.

Cc. Isleta Gaming Commission and Commission Staff Members

1

All Commissioners and Commission staff members must, during
normal business hours, possess on their “person”, an Identification
Badge (herein after, ID Badge) issued by the Isleta Gaming
Commission.

All Commission ID Badges will consist of the following
information:

a. The Pueblo of Isleta Logo;

b. The words, ISLETA GAMING COMMISSION;
c. The employees name;

d. Department name;

e. Personal Photo.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 18
Code of Conduct Page 12 of 14

A. All Commissioner’s, Commission staff and any Isleta Gaming Operations
Management, Employees, and Vendors are subject to the following action:

1. Refusal to comply or Fine, denial, suspension,
violation of this pelicy. revocation, termination
of and/or restrictions on
any Gaming License.

Banishment and/or
criminal prosecution
of any individual or
Entity.

X. ACKNOWLEDGMENTS |

Employee compliance with this Regulation is a condition of employment at or
with the Isleta Gaming Operation or Isleta Gaming Commission. Nothing in this
Regulation shall be construed as any guarantee or promise to any applicant or any
employee, of any employment or any continued employment whatsoever, nor shall any
provisions of this Regulation constitute or be interpreted by any party or tribunal to
constitute any contractual rights of employment expressed or implied, or any obligation
of employment rights created by covenants of good faith and fair dealings, either
expressed or implied.

Vendor compliance with this Regulation is a condition of performing business at
or with the Isleta Gaming Operation. Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or vendor, of any business dealings or any
continued business dealings whatsoever, nor shall any provision of this Regulation
constitute or be interpreted by any party or tribunal to constitute any contractual rights of
business expressed or implied, or any obligation of business rights created by covenants
of good faith and fair dealings, either exptessed or implied.

Compliance with this Regulation by all Tribal Officials is mandatory.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees and vendors responsibility
to obtain a Gaming License prior to beginning work or performing business for or with
the Casino. ~

To the fullest reasonable extent possible, confidentiality is to be maintained in all
application of this policy. -

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 5
Licensing Page 15 of 35

under Article VI of this regulation. ‘If the vendor reapplies for a
license within one hundred eighty (180) calendar days, no
additional licensing fee shall be charged. If the vendor
reapplies for a license and the one hundred eighty (180) days
has expired, the applicant must undergo the entire licensing
process, including all fees set forth in this chapter.

d. The Commission requires that all Owner(s) (if proprietorship)
and/or the Officer(s)/Director(s) (if a corporation, partnership,
firm, etc.) and the Designated Agent(s) of the local subsidiary(s)
and the Person signing off on the Vendor License Application,
employed by the vendor, sign an individual Release of
Information form. Through this form the Commission requests
the divulgence of each specific individuals Name, Date of Birth
(DOB), and Social Security Number (SSN) for processing
purposes. Failure to supply the appropriate SSN may result in
errors in processing the application, which may result in denial
of the Vendor Gaming License.

e. Vendor applicants and licensees shall have a continuing duty
to provide any facts, materials, assistance or other information
required by the Isleta Gaming Commission, and to fully
cooperate in any investigation conducted by or on behalf of the
Isleta Gaming Commission. Any information relevant to the
application or to the licensee or applicant’s character, or fitness
to be involved with the Gaming Activity or Gaming Operation,
shall be delivered to the Isleta Gaming Commission promptly,
with or without a formal request from the Isleta Gaming
Commission.

f. ALL VENDOR APPLICATIONS MUST BE
COMPLETELY FILLED OUT, REGARDLESS OF HOW
MINIMAL THE INFORMATION MAY SEEM. IF THE
QUESTION IS NOT APPLICABLE, THE WORDS “NOT
APPLICABLE” OR ABBREVIATION “N/A” WILL BE
INSERTED AS AN ANSWER TO THE QUESTION
POSED. :

C. In conducting a background investigation, the Isleta‘Gaming Commission or
its’ agents will keep confidential the identity of each person or entity
interviewed in the course of the investigation.

D. Delegation of Commission’s Obligation to conduct Background
Investigations.

Isleta Gaming Commission Regulation . * . Revised December 01, 1999


Chapter 6
Investigative Procedures not Page 3 of 8

investigative task on behalf of the Commission. The Commission has direct
supervision over all Commission Investigators.

Open Issue Investigation ~ a detailed overt inquiry or.systematic examination of
the circumstances leading to an infraction, violation, gaming license suspension or
revocation, or dubious or suspicious activity(s) that may occur within any Pueblo
of Isleta Gaming Operation or noncompliance with any applicable laws, to include
gaming laws and regulations.

Closed Issue Investigation — a detailed covert inquiry or systematic examination
of the circumstances leading to an infraction, violation, gaming license suspension
or revocation, or dubious or suspicious activity(s) that may occur within any
Pueblo of Isleta Gaming Operation or noncompliance with any applicable laws to
include gaming laws and regulations.

Vv. TYPES OF INVESTIGATIONS
A. Open Issue Investigation:

1. “Open Issue” shall refer to a case where the facts or issues are readily
apparent or where such facts are common knowledge to some or all of
the Palace management structure. Regardless of the “openness” of
such an investigation, the need for non-disclosure protections of all
uncovered evidence shall be in full effect.

2. An “Open Issue” may be conducted in cooperation with various
departments within the Palace in addition to/or other investigative
agencies.

a. These investigations may occur in conjunction with:

1. Various Palace personnel, as deeded necessary by the
Commission Investigator;

2. Commercial investigative contractors; or

3. Local/municipal/county/state/federal/law enforcement
agencies. “ee

b. All national investigation standards and procedures, as
applicable pursuant to the authority granted the
Commission, are hereby adopted and enacted as the
policies of the Pueblo of Isleta Gaming Commission
[Refer to 18 U.S.C. 1-6001 (1948) as applicable
pursuant to the authority granted the Commission].

Isleta Gaming Commission Regulation Revised December 16, 1999



Chapter 11
Variance Reporting Requirements : Page 2 of 5

I AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

Tl. PURPOSE

The purpose of this regulation is to institute Minimum Internal Control Standards
(MICS) that will safeguard the assets and protect the integrity of all gaming operations of
the Pueblo of Isleta. This regulation also provides for the safekeeping of U. S. currency,
foreign currency, casino chips, and any other such monetary units used and/or exchanged
by all Pueblo of Isleta Gaming Operations. .

I. SCOPE

This Regulation is designed to establish proper reporting procedures dealing with
cash variances that result from any gaming activity, equipment failure, employee
negligence, theft, and any other activities that create shortages or overages in the gaming
operations. This Regulation applies to all gaming activities as defined in Pueblo of Isleta
Ordinance 94-02 (January 20, 1994) and any ordinance or amendment adopted thereto.

IV. VARIANCE REPORTING REQUIREMENTS

A. Any variance (cash shortages and overages) in excess of one hundred
dollars ($100.00) arising during the course of any gaming function, cash
disbursement, or income activity, at any time, will be reported
immediately to the Isleta Gaming Commission Internal Auditors and
Investigators. Reports dealing with the cash shortage and/or overage will
include a detailed written explanation for the shortage or overage, copies
of all related gaming paperwork, and any additional information relevant
to the reported shortage or overage. The Gaming Commission shall be .
responsible for maintaining records of all reports, paperwork, and other
information provided by the Gaming Palace to the Commission as a result
of a cash shortage and/or overage. Isleta Gaming Palace Management
shall invoke corrective action, to include disciplinary action, in accordance
with Standard Operating Procedures. Thereafter, the Commission may
invoke disciplinary action as deemed necessary (See Section V and VI
below). ,

. _— ETI

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 18

Code of Conduct Page 5 of 14

7. Promptly report any suspected violations of laws, regulations, or
standard operating procedures to appropriate Isleta Gaming
personnel or the Commission.

8. Adhere to all standards of confidentiality set forth in all laws,
regulations, and standard operating procedures.

9. Acquire goods and services only as authorized by the management,
operating contract, and standard operating procedures.

10. Carefully avoid any situation, which will compromise Isleta’s

competitive position or result in a potential conflict of interest.

VI. CONFLICTS OF INTEREST

A. Employee

1.

A conflict of interest occurs when any employee is in a situation in
which he/she can gain from information or from personal contact
and such gain or potential gain would not be available except
through employment with Isleta Gaming Operations. Such conflict
of interest is to the benefit of the employee or to the detriment of
the Gaming Operation, either monetarily or to its public image.

All such situations-are strictly prohibited.

Employees must avoid financial, business, and personal
relationships which might be opposed to Isleta Gaming
Operation interests or which might impair independent judgment
related to Isleta Gaming matters.

Every Isleta Gaming Operation employee who has an interest in, or
a personal relationship with, a supplier, vendor, other employee, or
Commission employee must report this fact and carefully follow
any precautionary steps established by management and/or this
regulation. The Isleta Gaming Operation Human Resource
Department Standard Operating Procedure Manual details the
policies and procedures for reporting possible conflicts of interest
and outside employment.

All Isleta Gaming Operation employees are prohibited from
participating or engaging in any business or activity or providing
services outside the Isleta Gaming Operation which are in any way
similar to the work he/she does for Isleta.

Isleta Gaming Commission Regulation . - ~'cis.. Revised December 16, 1999



Chapter 11
Variance Reporting Requirements _ Page 5 of 5

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 11, Variance Reporting Requirements, was duly
REVISED, ORDAINED, ADOPTED, AND RATIFIED on this the _16th day of

. December, 1999, at a duly called meeting of the Gaming Commission of the Pueblo of
Isleta, at which a quorum was present, with _2_ voting for, _0_ voting against, and
_0 abstaining.

Vacant

Chairman

a Pr Ae
TRICIA L. JIRGN

__Nice-Chairman

etn sneer een ctr se - es

Subscribed and sworn before me on this the _16th day of December, 1999.
a

‘OFRCIAL SEAL Fs
cy ay Mua #2 Mnf
| PUBLIC-STATE OF
Dy DMZNOTARY

My Commission Expires: oo ) i202

Isleta Gaming Commission Regulation . Revised December 16, 1999



Chapter 3
Gaming Participation & Operation Page 7 of 7

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 3, Gaming Participation & Operation, was duly
REVISED, ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of

. December, 1999, at a duly called meeting of the Gaming Commission of the Pueblo of
Isleta, at which a quorum was present, with _2_ voting for, _0_ voting against, and
_0_ abstaining. -

Vacant

Chairman

L Z.
TRICIA L. JIRGN
Vice-Chairman

Lb
ST CiI. LO
Secretary-Tréasurer

ATTEST

Subscribed and sworn before me this the _16th_ day of December, 1999.

NOTARY _ :

Isleta Gaming Commission Regulation Revised December 16, 1999

My Commission Expires:



Chapter 15
Race and Sports Book Computerized Page 6 of 16

B. Prior to making payment on a ticket or crediting the winnings to the
patron’s account the cashier inputs the ticket sequence number
into the cashier’s terminal. :

Note: Alternatively, the computer system may automatically
update the patron’s account when the event results are
posted.

Cc. Upon computer authorization of payment the patron is paid, the
patron’s copy is marked “PAID”, noted with the amount of
payment, date stamped, and time noted.

D. For all payouts, which are made without computer authorization,
documentation supporting and explaining such payouts is
maintained.

E. The computer is incapable of authorizing payment on a ticket, which
has been previously paid, a voided ticket, a losing ticket, or an
unissued ticket.

F. For net winnings greater than ten thousand dollars ($10,000.00)
(i.e., payout less initial wager) within 72 hours following payment of
a winning ticket, an employee independent of the ticket verification
confirms the integrity of the patron’s copy by comparing it to,
regrading, and initialing the patron’s copy.

G. If a progressive pool is used for wagers:
1. Adequate documentation is retained regarding the rules,
increment procedures and any reductions in the progressive
amounts.

2. The progressive amount is displayed in the book.
3. The progressive liability is recorded on a daily basis.

4. Audit personnel recalculate the progressive increment on a
sample basis, at least once a week.

IX. CHECKOUT STANDARDS

A. For each writer.and cashi

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 17
Notification to the Commission Page 2 of 12

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

I. PURPOSE

The purpose of this regulation is to provide a set of guidelines for the giving of
sufficient information and timely notice to the Isleta Gaming Commission by any Pueblo
of Isleta Gaming Operation prior to the purchasing of or the utilization of Casino Games,
any construction or modification of any gaming facilities, any alteration/modification of
Standard Operating Procedures (SOPs), and the submission of all contracts being
considered by the Gaming Operation.

I. SCOPE

This regulation pertains to all functioiis and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
Tribal Resolution or Ordinance adopted thereto, the Indian Gaming Regulatory Act of
1988, and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact.

This regulation applies to all Pueblo of Isleta Gaming Enterprises, Facilities,
and/or Operation’s which includes, but is not limited to, the Isleta Gaming Palace and
Palace West. This regulation also applies to the Pueblo of Isleta Tribal Council and
Governor when promulgating any policy or procedure changes or directives to the Isleta
Gaming Operation(s). This regulation does not apply to other Tribal entities or agencies
within the Pueblo of Isleta Tribal Government.

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural.

Casino Games - includes but is not limited to, all Electronic Gaming Devices
(EGD’s), all Table Games; all forms of Poker; Blackjack; Roulette; Craps; Let It
Ride; Keno; Wheel of Fortune; Pai Gow; Bingo; any and all Class II or III games
of chance. ,

Isleta Gaming Commission Regulations Revised December 16, 1999


Pueblo of Isleta. Gaming Commission
Regulations

TABLE OF CONTENTS

Chapter 6: Investigative Procedures

IL
ii.
Iv.
Vv.

VI.
VIL.

VI.

IX.

Commission Certification

Authority 2
Purpose 2
Scope - ——- 2
Definitions , “ 2
Types of Investigations Rshih 3
A. Open Issue Investigation - 3

B. Closed Issue Investigation 4
Confidentiality of Investigations 4
Release of Investigative Information 5
5
7
8

Investigative Procedures
Limitations on Investigations

Chapter 7: Patron Dispute Resolution

1
Il.
ii.
Iv.
Vv.

VI.

Authority -. aoeast
Purpose —
Scope
Definitions -------
Patron Disputes -- - -
A. Procedure for Determination of an Employee Grievance —
B. Formal Hearing by Commission on Grievance
Self Identified Problem Gamblers

WNNNN

Commission Certification --- ann 5

Chapter 8: Employee Grievance Procedures

<2HRTM

idta ons

Authority
Purpose
Scope
Definitions
Steps of Formal Grievance Procedures
A. Step I. -
B. Step I.
1. Employee’s Responsibility in the
Formal Grievance Procedure 3

WWWNNNN



Pueblo of Isleta Gaming Commission’
Regulation

TABLE OF CONTENTS ~

Chapter 19

Identification Bad:

L Authority 2
0. Purpose 2
Il. Scope 2
IV. Definitions 2
Vv. ID Badge Policy 3
A Employee 3
B. Vendor 5
Cc. Isleta Gaming Commission and Commission Staff Members --—--- 7
VI. Issuing ID Badges 8
A. Employee 8
B. Vendor 9
c. Commissioner’s and Commission Staff ~---—------_—_----- 9
VIE. ID Badge Fees 10
A. — Employees . 10
B. Vendors 10
Cc. Commissioners and Commission Staff ——----------------———- 1]
VII. Enforcement Activity . _ : 11
IX. Notice of Disciplinary Action For Policy Violations —----------—-------—- 11
X. Acknowledgments _ - 11

Commission Certification — 13



Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 14

Drug Free Workplace

I. Authority 2
I. Purpose 2
Tl. Scope --- -2
IV. Definitions -- -2
Vv. Policy a 4
Vi. Enforcement Activity 6
VU. Notice of Disciplinary Action for Policy Violations -----------------------—--- 8
VIII. Requirements of Testing Facility - - 9
IX. Acknowledgments 10
Commission Certification ll


Chapter 14 - Bees

Drug Free Workplace Page 9 of 11

findings of a policy violation may require that the employee be suspended,
without pay, pending the results of an investigation.

In the case of alcohol, the Commission requires an employee to enroll and
attend an approved rehabilitation program and re-test before being allowed
reinstatement of employment or a suspended or terminated license.

In the case of illegal drugs, the Commission requires an employee to be
terminated from employment with the Isleta Gaming Operation.

VI. REQUIREMENTS OF TESTING FACILITY

A.

All searches, collection, and testing will be performed with concern for
each employee’s privacy. The results of any drug screening will be
considered a confidential record to be disseminated strictly on a “need-to-
know” basis or as may be legally required.

All collections of urine samples must be supervised by the person making
the collection and the collection person, along with the laboratory, will
insure that a proper chain of custody is executed and the integrity of the
sample is maintained. .

All collections will be performed by an approved third party security
personnel who is familiar with the proper collection procedures of this
policy.

A representative of the Commission, Casino Management, and Security
must be present during all testing.

Testing will be performed by any laboratory chosen by the Tribe or its
testing contractor which is accredited by the College of American
Pathologists or certified by the Department of Health and Human Services.

For drug urinalysis, each specimen may be tested to determine the
presence of (including, but not limited to) amphetamines, cannabinoids
(marijuana, THC, Hashish), cocaine, opiates, phencyclidine, barbiturates,
benzodiazepines, methadone, metnaqualone and propoxyphene.

For cannabinoids, a minimum of 50 NG per ml testing is cut-off for a
positive screen by the laboratory.

All positives reported by the laboratory must be confirmed by Gas
Chromatography/Mass Spectrometry.

Isleta Gaming Commission Regulation : . Revised December 16, 1999


Chapter 15
Race and Sports Book Computerized : Page 3 of 16

1. Date and time of system failure.
2. Reason for failure.
3. Date and time system restored.

B. All manually written and/or paid tickets are entered into the
computer system as soon as possible to verify the accuracy of the
write and the payout (this does not apply to purged, unpaid winning
tickets). All manually-paid tickets must be regraded as part of the
end-of-day audit process should the computer system be
inoperative. ot

Cc. The Time generated by the computer during ticket writing is tested
each day by a supervisor independent of the ticket writing and
cashiering function (this person may also be independent of the
book).

D. The test, and any adjustments necessary due to discrepancies, is
documented in a log (or in another equivalent manner) which
includes the station number, date, time of test, time per computer,
name or signature of the employee performing test, and any other
relevant information.

E. All date, time and numerical sequence stamping machines used
by the book (for parlay cards, voiding cards/tickets, and payouts)
are directly and permanently wired to the electrical supply system
(or in another approved manner).

F. Only maintenance, engineering or security employees/personnel
have access to fuses or fuse-like devices used in connection with
the machines.

G. At least once during each eight (8) hours of operation each book
examines and tests the stamping machines to ensure their date
and time accuracy to the nearest minute.

H. The above test is performed by someone independent of the ticket
writing function. For books with casino operations the above test is
performed at least weekly by someone totally independent of the
book.

L The test, and any adjustments necessary due to discrepancies, is
documented in a log (or in another equivalent manner) which

Isleta Gaming Commission Regulation e Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 01, 1999)

ae

Chapter 5

“Licensing


Chapter 19
TD Badges Page 3 of 13

Commissioner(s) - An individual duly appointed by the Pueblo of Isleta Tribal
Council to serve as one (1) of three (3) members of the Isleta Gaming
Commission.

Commission Staff - including but not limited to, a group of employees,
assistants, agents, and clerks to an officer, director, executive, or another person in
authority. The personnel who carry out a specific duty/duties in aide of or on
behalf of a Commissioner(s).

Employee - A person in the service of the Isleta Gaming Industry under any
contract of hire, expressed or implied, oral or written, where the employer has the
power or right to control and direct the employee in the material details of how
the work is to be performed.

IGCR - abbreviation for the Isleta Gaming Commission Regulations.

Management - The act, manner, or practice of managing; handling, supervision,
or control of the Isleta Gaming Operation(s). The person or persons who control
or direct the Isleta Gaming Palace, its subsidiary(s), or any part of the Gaming
Operation/enterprise.

Patron - one who buys goods and services; a customer, internal or external.

Sensitive Areas - include, but are not limited to, the Vault, Cage, MIS,
Accounting, Internal Audit, Surveillance, Commission, and all non-public
areas of any Isleta Gaming Operation facility or premises.

Vendor - including but not limited to, a merchant, retail dealer, supplier,
importer, wholesale distributor, corporation, entity; one who buys to sell; a
seller. A seller of goods/products and services.

Vv. ID BADGE POLICY
A. Employee

1. All employees of the Isleta Gaming Operation must possess and
wear on their outer garment, an Identification Badge (herein after,
ID Badge) issued by the Commission. The Isleta Gaming Palace
Surveillance Department is the only exception to this policy. All
Surveillance staff must adhere to Section V. (C) herein below.

2. All employee Temporary ID Badges will consist of the following
information:

a. The Pueblo of Isleta Logo;

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 20

Training Requirements Page 7 of 10

5. Although training is provided for each Isleta Gaming Palace
Employee, it is still the responsibility of each employee to know,
be aware of, and adhere to all Isleta Gaming Commission
Regulations and Isleta Gaming Palace Standard Operating
Procedures. No Exceptions!

6. If an Isleta Gaming Palace Employee does not feel comfortable in
the understanding of the newly acquired knowledge, it is the
responsibility of the employee to bring this to the attention of their
Supervisor and/or Department Manager, so that the employee may
receive additional training as necessary.

7. Ignorance of any Commission Regulation or Isleta Gaming Palace
Standard Operating Procedure shall not be acceptable as an excuse
for a violation of any Regulation, policy, or procedure. If an
employee does not know a regulation or policy or procedure, that
employee should, at least, know where to look it up in order to
make an informed decision on any situation or request the presence
of a Supervisor for assistance.

VI. THE ROLE OF THE HUMAN RESOURCE DEPARTMENT

A.

It shall be the responsibility of the Human Resource Department to
develop standardized training form(s), certificate(s) of completion, etc.
for use by all department of the Isleta Gaming Palace. All original
documents, except for an issued certificate, shall be kept in the employees
Official Human Resource File. Any issued certificate, if applicable, is to
be given to the employee with a copy to the Human Resources file. A
copy of all documentation shall be kept and maintained in each
departmental employee training profile folder.

Any standardized training form developed by the Human Resource
Department shall include, but is not limited to:

1. date(s) of training,
. what the training entailed,
3. signature of the Employee.acknowledging that he/she received
said training, and
4. signature of the Department Manager.

Any certificate issued on behalf of the Isleta Gaming Operation shall
include, but is not limited to:

1. the name: Isleta Gaming Palace


Pueblo of Isleta Gaming Commission

Regulations
TABLE OF CONTENTS
VII. Acknowledgments - 12
Commission Ratification 13
Nevada Standards Attachment
Chapter 5: Licensing
L Authority 2
0. Purpose tots 2
Il. Scope 2
IV. Definitions 2
Vv. Application for License 5
VI. Licensing Fee 8
VII. Temporary/ Work Permits or Vendor Licenses ----------------~---------------- al
VIII. Background Investigations - 12
~.s-meIX. . Eligibility Determination- = 19
xX. Reporting Requirements. (Key Employees
and Primary Management Officials only) ---20
XI. Denial of Application and Denial of a Gaming License ----------------------- 21
XII. Issuing a License 23
A. Key Employees and Primary Management Officials --------------~ -- 23
B. Employees other than Key Employees
or Primary Management officials 24
c. Vendors 24
XIII. Suspension, Revocation, and Reinstatement of Licenses -------------------- --25
A. Suspension 25
B. Revocation 26
Cc. Reinstatement -29
XIV. Reconsideration Review Hearing Procedure --------—-------------------------- 30
XV. Method by which all Commission NOTICE’S shall be Sent ---------------- 31
XVI. License Renewal — 31
A. Employees --— — 31
B. Non-Gaming Vendors ------- 32
C. __. Gaming Vendors -- See 32
XVII. Exceptions 32
A. Waiver ~--- 32
XI0. Enforcement Activity 32
XIX. Notice of Disciplinary Action for Policy Violations -------------------------- 33
XX. Acknowledgments 33

Commission Certification 35

iv.


Chapter 4
Gaming Equipment or Devices or Supplies ma aon Page 8 of 13

D. Progressive Slot Machines
1. As used in this section:

a. Progressive jackpot - means a slot machine payoff that
increases automatically over time or as the machine or
another is played.

b. Base amount - means the amount of the progressive jackpot
initially offered before it increases.

c. Incremental amount - means the difference between the
amount of a progressive jackpot and its base amount.

2. A meter that shows the amount of the progressive jackpot must be
conspicuously displayed at or near the machines to which the jackpot
applies. At least once a day each Isleta Gaming Operation shall record
the amount shown on each progressive jackpot meter at that
Operations establishment except for those jackpots that can be paid
directly from the machine’s hopper. Explanations for meter reading
decreases must be maintained with the progressive meter reading
sheets, and where the payment of a jackpot is the explanation for a
decrease, the Isleta Gaming Operation shall record the jackpot payout
form number on the sheet or have the number reasonably available.
Each Isleta Gaming Operation shall record the base amount of each
progressive jackpot the. licensee offers.

3. Any Isleta Gaming Operation may limit a progressive jackpot to an
amount that is equal to or greater than the amount of the jackpot when
the limit is imposed. The Isleta Gaming Operation shall post a
conspicuous notice of the limit at or near the machine or machines to
which the limit applies.

4. Any Isleta Gaming Operation shall not reduce the amount displayed on
a progressive jackpot meter or otherwise reduce or eliminate a
progressive jackpot unless:

a. A player wins the jackpot;

b. The Isleta Gaming Operation adjusts the progressive jackpot meter
to correct a malfunction or to prevent the display of an amount
greater than a limit imposed pursuant to subsection 3, and the Isleta

Gaming Operation documents the adjustment and the reasons for

it; ‘

Isleta Gaming Commission Regulation , Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 11

Variance Reporting Requirements

1 Authority
I. Purpose
Ill. Scope

IV. Variance Reporting Requirements
Vv. Enforcement Activity
VI. Notice of Disciplinary Action For Policy Violations ------------------------- —
VII. Acknowledgments
Commission Certification

MWwWWWNNNN



D Badges

Chapter 19
Page 9 of 13

When the background check is complete and if a favorable
suitability determination is made by the Isleta Gaming
Commission, a Permanent Employee ID Badge (See Section V,
(3), above) shall be issued for a period of three (3) years
coinciding with the valid dates of the newly issued Employee
Gaming License. (See Chapter 5, Licensing)

In the event an employee, voluntarily or involuntarily terminates
their employment with the Isleta Gaming Operation, the issued ID
Badge (regardless of type) must be returned to the Isleta Gaming
Operation Human Resource Department before any final paycheck
is issued to the individual. Thereafter, the issued ID Badge(s) is
to be kept in that employees individual Human Resource file.

B. Vendors

1.

At the time of application, a ninety (90) day Temporary Vendor
Permit (ID Badge) will be issued to a vendor, pending the
completion of a favorable preliminary background investigation.
(See Section V, B(2), above and IGCR Chapter 5, Licensing,
hereto)

When the background check is complete and if a favorable
suitability determination is made by the Isleta Gaming
Commission, a permanent ID Badge (See Section V, B(3), above)
shall be issued for a period of two (2) years coinciding with the
valid dates of the newly issued Vendor Gaming License. (See
Chapter 5, Licensing)

In the event a vendor, voluntarily or involuntarily terminates their
business transactions with the Isleta Gaming Operation, the issued
ID Badge(s), regardless of type, must be returned to the Office of
the Isleta Gaming Commission before any final or outstanding
payment is issued to the vendor. Thereafter, the issued ID
Badge(s) is to be kept in that vendors individual Commission file.

Cc. Commissioners and Commission Staff Members

1.

At the time of hire, a Commission ID Badge will be issued to a
Commissioner and Commission staff Members.

In the event a Commissioner or Commission staff member,
voluntarily or involuntarily terminates their employment with the
Isleta Gaming Commission, the issued ID Badge must be returned

Isleta Gaming Commission Regulation Revised December 16, 1999


Promulgating

Chapter 2

Internal Procedures & Regulatory Provisions _‘-._* ares Page 5 of 9

B. Sponsor — An existing Commissioner of good standing must introduce the
proposed ordinance or amendment at Council. Good Standing provisions are
contained in the Pueblo of Isleta Gaming Ordinance Article 4, Section 3 and
Article 7, Section 1. In an executive session, the sponsor shall motion to open
the floor for discussion regarding the proposed ordinance or amendment. The
Commissioner proposing the ordinance or amendment shall be prepared to
address all questions that may arise.

VII. PROMULGATING POLICIES, PROCEDURES, and CONTROLS for the
PUEBLO of ISLETA GAMING OPERATIONS

A.

The Commission has the authority to promulgate, review, implement,
adopt, and carry out rules, controls, policies, procedures, amendments, or
revisions in its’ regulatory oversight of all Isleta Gaming Operations.

Through the Isleta Gaming Commission Regulations (IGCR), the Isleta
Gaming Commission encompasses numerous gaming laws and other
applicable laws required by the Pueblo of Isleta, the Federal Government,
and the Indian Gaming Compact. However, the Isleta Gaming
Commission also requires all Pueblo of Isleta Gaming Operations to
incorporate certain applicable gaming laws directly into their Standard
Operating Procedures. Therefore, the Isleta Gaming Commission reserves
the right to regulate any Gaming Operation based not only on Commission
Regulations or applicable laws, but also on the Standard Operating
Procedures. :

The Isleta Gaming Commission will allow the Management of any Pueblo
of Isleta Gaming Operation a reasonable opportunity to develop Standard
Operating Procedures

The Isleta Gaming Commission must render a compliance approval over
all Standard Operating Procedures (SOPs), new, amended, revised, or
otherwise, for all Pueblo of Isleta Gaming Operations. For more detail on
the development or processing of Standard Operating Procedures, see
IGCR, Chapter 17 Notification to the

Commission V(C) Modification/ Alteration of Standard Operating
Procedures :

Isleta Gaming Commission Regulation Revised December 16, 1999


Jan 4

Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 2

Promulgating
Internal Procedures
Regulatory Provisions



Pueblo of Isleta —

Regulations

of the

Isleta Gaming Commission

Isleta, New Mexico

As Revised December, 1999 and Current as of January 03, 2000

These Regulations supersede all prior Gaming Regulations


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 13

Surplus Palace Property


Chapter 9
Concession & Restaurant Health Standards Page 4 of 6

2. In the event that the Palace Concessions and/or Restaurant do not pass
the State Department of Environment inspections, only the
Commission shall have the prerogative to immediately close all
business in the Concessions and/or Restaurant until the Commission is
satisfied that Concessions and/or the Restaurant can operate within
acceptable parameters. - oo

Vil. ENFORCEMENT ACTIVITY
A. The Commission reserves the right to enforce this policy as follows:
1. an imposition of a fine,

2. disciplinary action up.to and including suspension or revocation of
employee gaming license,

3. disciplinary action up to and including suspension or revocation
of vendor gaming license,

4, —-the placing of restrictions or conditions-on the licensee’s — ———---
retention of their gaming license, and/or

5. the combination of any of the above
VIII. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management, Employees, and Vendors of any Isleta Gaming
Operation are subject to the following action:

1. Refusal to comply or ~ Fine, denial, suspension,
violation of this policy. revocation, termination
of and/or restrictions on
Gaming License.

Ix. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with any Isleta Gaming Operation. Nothing in this Regulation shall be construed as any
guarantee or promise to any applicant or any employee, of any employment or any
continued employment whatsoever, nor shall any provisions of this Regulation constitute
or be interpreted by any party or tribunal to constitute any contractual rights of
employment expressed or implied, or any obligation of employment rights created by
covenants of good faith and fair dealings, either expressed or implied.

Isleta Gaming Commission Regulation Revised December 16, 1999


_ Licensing

“, . wees

Chapter 5
: Page 22 of 35

i.

12.

13.

14.

15.

16.

17.

the type of activity for which application is made;

Failure to demonstrate adequate. financing for the operation proposed in
the application;

Failure to satisfy any requirement for application or to timely respond to
any request by the Commission for additional information;

Inconclusive results of an applicants background investigation or
unverifiable information pertaining to a material fact contained in a
Gaming License Application;

Approval of the application would otherwise be contrary to Pueblo of
Isleta Tribal Law, Federal Law, the Indian Gaming Compact between the
State of New Mexico and the Pueblo of Isleta, or public policy;

Circumvention of Commission authority;

Circumvention of any Commission Regulation, applicable gaming laws,
Isleta Gaming Operation Standard Operating Procedure, or applicable
Federal, Tribal, or State laws;

Concealment or refusal to disclose any material fact in any Commission
Investigation. oS

. Denial of a Gaming License Application constitutes a denial of a Gaming

License by the Isleta Gaming Commission.

1.

The Commission shall deny a Gaming License if there is evidence
indicating that the applicant is not eligible to participate in the gaming
operation of the Pueblo of Isleta under the requirements of Article IX,
Eligibility Detérmination, herein.

The Commission may deny a Gaming License if the National Indian
Gaming Commission or the State Gaming Representative provides the
Commission with evidence indicating that the applicant is not eligible to
participate in the gaming operation of the Pueblo of Isleta under the
requirements of Article IX, herein, the Indian Gaming Regulatory Act of
1988, the Pueblo of Isleta/State of New Mexico Indian Gaming Compact,
Isleta Tribal Law, and other applicable Federal Laws.

Upon denying a license, the Commission shall notify, in writing, the
applicant of the DENIAL and the reason(s) thereof.

Isleta Gaming Commission Regulation ‘ ane Revised December 01, 1999



Chapter 19
DD Badges Page 2 of 13

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

Tl. PURPOSE

The purpose of this regulation is to provide a comprehensive set of guidelines for
the identification of each employee or vendor, to ascertain the immediate status of each
employee or vendor, and to control access to sensitive areas of any Pueblo of Isleta
Gaming Operation.

I. SCOPE

This regulation pertains to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
Tribal Resolution or Ordinance adopted thereto, the Indian Gaming Regulatory Act of
1988, and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact.

This regulation applies to all employees and vendors of all Pueblo of Isleta
Gaming Enterprises, Facilities, and/or Operation’s which includes but is not limited to the
Isleta Gaming Palace and Palace West. This regulation does not apply to other Tribal
entities or agencies within the Pueblo of Isleta Tribal Government.

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural.

Agent - A person, corporation, or entity authorized by another to act for or on
behalf of him/her or an agency; one entrusted with another’s business, affairs,
and/or dealings. .

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 3

Gaming
Participation & Operation


Chapter 14
Drug Free Workplace Page 5 of 11

in the employee’s body while working), and any other drugs or substances
which may affect a person’s perception, performance, judgment, reactions,
or senses while working or while on casino or Gaming Commission
business, including any and all drugs declared to be illegal under any
Federal, State, or Tribal law is prohibited.

D. The possession or the reporting to work or working with detectable
amounts in the system of alcohol or intoxicating beverages on the casino
property which may affect an employee’s mood, senses, responses, motor
functions, or alter or affect a person’s perception, performance, judgment,
reactions, or senses while working or while on the casino premises, the
bringing onto the property, or the possession, transfer, storage,
concealment, transportation, promotion, or sale of alcoholic or intoxicating
beverages is prohibited.

E. The possession or the reporting to work or working with drug-related
paraphernalia, including any material or equipment used or designed for
use in testing, packaging, storing, injecting, ingesting, inhaling, or
otherwise introducing into the human body an illegal, unauthorized
controlled or dangerous substance as defined by this policy is prohibited.

F. The legal use of prescription drugs (Legally Controlled Substances)
prescribed by a licensed physician are permitted, however:

1. Employee shall immediately inform the supervisor prior to using
prescribed drugs or medication on the job.

2. Medication shall be in its original vial or be in a vial provided by
the pharmacist commonly referred to as “day carriers” and shall be
in the employee’s name and shall have the doctor’s name, phone
number, and prescription number on the label, as well as the date
of issuance. : _

3. Each prescription shall not be older than one (1) year of the date of
issue, unless specified by a Doctor.

4. Employees shall only possess a reasonable amount of medication
for a normal work shift.

5. The employee whose name appears on the label of the vial shall
not allow any other employee, visitor, guest, subcontractor, or any
other person to consume the prescribed drug or medication.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulations

TABLE OF CONTENTS

Chapter 13: Surplus Palace Property

L Authority - 2
I. Purpose -- - 2
Ill. Scope - 2
IV. _ Definitions --- 2
Vv. Procedures for Determining Surplus Property ----------------------------------- 3
VI. Disposal of Surplus Property 3
VII. Enforcement Activity . 3
VIII. Notice of Disciplinary Action for Policy Violations --------------------------- 4
IX. Acknowledgments 4
Commission Certification - 4
Chapter 14: Drug Free Workplace

ne
L Authority 2
Il. Purpose 2
il. Scope --- - 2
IV. Definitions 2
V. Policy : - 4
VI. Enforcement Activity 6
VII. Notice of Disciplinary Action for Policy Violations -------------------------- 8
VIII. Requirements of Testing Facility — -9
IX. Acknowledgments — 10
Commission Certification --- ll
Chapter 15: Race and Sports Book Computerized
I. Authority 2
I. Purpose 2
Ill. Scope 2
IV. — System Security Standards 2
V. Betting Ticket and Equipment Standards 2
VI. Wagering Standards 4
Vil. Wagering Cutoff 5
VIM. Payout Standards — 5
IX. Checklist Standards 6
XxX. Employee Segregation 7

viii


Chapter 14-.
Drug Free Workplace erence “ Page 3 of 11

Casino — pertains to any Pueblo of Isleta Gaming Operation, i.e., the Isleta
Gaming Palace, Palace West, etc.

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

Controlled Drug - Those drugs or chemical substances placed on a schedule or in
special categories to prevent, curtail or limit their distribution and manufacture as
defined by the Controlled Substance Act of 1970, as amended.

Designer (Synthetic) Drugs - Those chemical substances that are made in
clandestine laboratories where the molecular structure of both legal and illegal
drugs is altered to create a drug that is not explicitly banned by Federal law.

Drug - Any chemical substance, including alcohol, that either produces physical,
mental, or emotional changes to the user, or one that is capable of altering the
mood, perception, pain level, or judgment of the individual consuming it.

Drug Abuse - Drug abuse is the use of a drug or chemical substance for other
than medical purposes which results in the impaired physical, mental, emotional
well-being of the user.

Drug Misuse - The unintentional or inappropriate use of prescription or over-the-
counter drugs or chemical substances, which results in impaired physical, mental,
or emotional well-being of the user.

Drug-Related Paraphernalia - Any material, equipment, or items used or
designed for use in testing, packaging, storing, injecting, ingesting, inhaling, or
otherwise introducing into the human body an illegal, unauthorized controlled or
dangerous substance.

Illegal Drug - Any drug; (a), which is not legally obtainable; or (b), which is
legally obtainable but has not been legally obtained. The term includes prescribed
drugs not legally obtained and prescribed drugs not being used for prescribed

purposes.

Legal Drug - Any prescribed drug or over-the-counter drug or medication, which
has been legally obtained and is being used for which it was prescribed or
manufactured.

Look-Alike Drugs - A tablet, capsule, powder or liquid containing controlled
over-the-counter ingredients whose physical appearance resembles various

Isleta Gaming Commission Regulation ” Revised December 16, 1999


Chapter 17
Notification to the Commission Page 7 of 12

within the time allotted, the Commission reserves the right to
prohibit the implementation of said policy/procedure and
Management must start this compliance process again.

7. The Commission reserves the right to voice or hear concerns
on any policy/procedure or portion thereof, new or old, via a
written format (i.e. letter, memo, other), hearing (formal or
informal), and/or both.

8. All newly developed or alterations/amendments to existing Isleta
Gaming Operation, Standard Operating Procedures will not be
made or implemented without the above process being completed
and approved, in writing, by the Isleta Gaming Operation General
Manager and the Isleta Gaming Commission. No exceptions!

9. If a situation occurs that does ‘not have any governing policy or
procedure, that situation will be handled on an, “as is” basis, but no
later than thirty (30) days thereafter, Isleta Gaming Operation
Management must set down in writing a policy and procedure to
govern a future occurrence and submit the policy through this
approval process.

10. No less than annually, Department Managers within any Isleta
Gaming Operation must review and revise the Standard Operating
Procedures for each department.

11. All decisions by the Commission are final.
D. CONTRACTS

It is the responsibility of the Isleta Gaming Operations Management to
submit and receive compliance approval of all contracts or agreements, in
the amount of ten thousand dollars ($10,000.00) or more, to the Isleta
Gaming Commission, prior to signing said contract, for a compliance
review. All contract or agreements that accumulate to ten thousand dollars
($10,000.00) or more in a three (3) month period must also be submitted to
the Isleta Gaming Commission, prior to signing, for a compliance review.
The following documentation must be submitted to the Commission at
least thirty (30) days i in advance:

1. A copy of any and all purposed contracts or agreements prior to
the Operation entering into the contract or agreement.

Isleta Gaming Commission Regulations Bobs Revised December 16, 1999


Chapter 3

Gaming Participation & Operation Page 5 of 7

3.

Federal Funding and Wages

a. On any construction project involving any Gaming Facility or
related structure that is funded in whole or in part by federal
funds, all workers will be paid wages meeting the standards
established for New Mexico under the federal Davis-Bacon
Act.

E. Political Contributions

1.

The Tribe, the Tribal Gaming Agency, or a Management Contractor is
prohibited from contributing directly, or through an agent,
representative, or employee, revenue from the Gaming Enterprise
owned by the Tribe, or anything of value acquired with that revenue, to
a candidate, political committee, person holding an office elected or to
be elected at an election covered by the State’s Campaign Reporting
Act.

G. Funding Assistance for Treatment Support Programs

1.

The Gaming Enterprise will spend an amount that is no less than one-
quarter of one percent (0.25%) of its net win annually to fund or
support programs for the treatment and assistance of compulsive
gamblers and for the prevention of compulsive gambling.

VI. © ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this policy as follows:

1.

2.

an imposition of a fine,

disciplinary action up to and including suspension or revocation of
employee gaming license,

disciplinary action up to arid including suspension or revocation
of vendor gaming license,

the placing of restrictions or conditions on the licensee’s
retention of their gaming license, and/or

the combination of any of the above

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 15
Race and Sports Book Computerized Page 16 of 16

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 15, Race and Sports Book (Computerized), was duly
REVISED, ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of

- December, 1999, at a duly called meeting of the Gaming Commission of the Pueblo of
Isleta, at which a quorum was present, with __2_ voting for, _0_ voting against, and
_0_ abstaining.

Absent

Chairman

Yi
TRICIA L. JIRO

Vice-Chairman

-RNEST LO
etary-Treasurer

Sai MEG Ee

Subscribed and sworn before me on this the _16th_ day of December, 1999.

OFFICIAL SEAL

SF ee eo ; KYA
omnis 2 NOTARY

My Commission Expires: fade b , L807.

Isleta Gaming Commission Regulation Revised December 16, 1999



Chapter 17
Notification to the Commission Page 9 of 12

8. Failure to provide any information required or requested
constitutes sufficient grounds for the Commission to deny or
revoke any gaming license and/or to require termination of the
applicant’s or licensee’s gaming contract or agreement between the
Isleta Gaming Operation and any person or entity who failed to
provide the required or requested information. (See IGCR,

Chapter 5, Licensing)

9. In the event a vendor license is denied or revoked in accordance
with IGCR, Chapter 5, Licensing, by the Isleta Gaming
Commission, any antecedent, pending, or future contract or
agreement with the Isleta Gaming Operation shall be deemed null
and void, terminating said contract with out penalty to either party.

10. Effective upon the adoption date of this regulation (January 20,
1999), no future contract(s) between the Isleta Gaming Operation
and another party, may exceed two years in duration and are
subject to renewal in accordance with IGCRs and Isleta Gaming
Palace, Purchasing, Standard Operating Procedures (SOPs). Also,
all contracts with any vendor should coincide with or within the
valid Commission licensing date(s) issued on the vendors License.
The Commission understands that it may be necessary, from time
to time, that the duration of a contract exceed this two year rule.
Therefore, such contract(s) will be regulated on a case-by-case
basis.

VI EXCEPTIONS
A. Emergencies

1. All emergency situations must be immediately brought before the
Isleta Gaming Commission and will be considered on a case-by-
case basis.

7 NOTE: All Commissioner’s and their agents are available twenty-four (24)
hours a day, seven (7) days a week and can be reached via pager,
home phone number, and/or cellular phone through the
Commission Emergency Contact List located in the Isleta Gaming
Palace Security Office. These numbers are confidential and may not
be released or dispersed to vendors, patrons, other employees, or
any person or entity for any reason. It is the responsibility of the
Isleta Gaming Palace Security Office to contact the appropriate
individual listed.

Isleta Gaming Commission Regulations : Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter 8

Employee
Grievance Procedures


Chapter 14
Drug Free Workplace Page 2 of 11

IL AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance adopted thereto.

Tl. PURPOSE

The Commission intends to establish a Drug-Free Workplace, and to provide a
safe and healthful environment for all licensed employees of the Pueblo of Isleta Gaming
Operations to work in and to prevent accidents and casualties in casino operations that
result from impairment of employees who use alcohol or other drugs. The Commission
has determined that a uniform and effective drug policy is essential to establish that
objective. The Commission has determined that such a policy should, not only protect
the well being and property of the casino employees, but should provide the same
protection to all persons coming on to the casino premises.

I. SCOPE

This regulation pertains to drugs, alcohol, and chemical substances. This
regulation applies to all functions and duties over which the Commission retains
jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
resolution adopted thereto, the Indian Gaming Regulatory Act of 1988, 25 U.S.C. 2701,
and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact. This regulation
does not apply to other entities or agencies Within the Pueblo of Isleta Tribal
Government. :

IV. DEFINITIONS

The following definitions are intended to clarify the prohibited substances and
items covered in this regulation. Throughout this document the use of these definitions in
the singular, also includes the plural. The term “drug” is used interchangeably with the
term’s chemical or chemical substance or alcohol for the purposes of this policy.

Act-Alike Drugs - Those chemicals not manufactured to closely resemble
controlled substances, but which are promoted i in the same way and which contain
the same ingredients as look- alike drugs. :

Alcohol or Intoxicating Beverage - Any liquid that may be legally sold and
consumed, and that has an alcohol content in excess of one-half (1/2) of one
percent (1%) by volume.

Isleta Gaming Commission Regulation : Revised December 16, 1999


Chapter 6
Investigative Procedures Page 8 of 8

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 6, Investigative Procedures, was duly REVISED,
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with _2_ voting for, 0 voting against, and _0 abstaining.

Vacant

Chairman

((g4tiee L Vom
ATRICIA L. ROX”

Vice-Chairman a : : - ee

Subscribed and sworn before me on this the _16th_ day of December, 1999.

fea wanon ”) 0) (Win B21)

2 DSROTARY 7

My Commission Expires: zp if WD.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission

Regulation
(Adopted March 05, 1999)

Chapter 20

Training
Requirements


Chapter 18
Code of Conduct Page 3 of 14

patrons which directly or indirectly relatés to,the Isleta Gaming Operation, and
could: ea TS

a. diminish the employee’s impartiality,

b. diminish a Commissioner’s or Commission staff member’s
impartiality,

c. result in a Commissioner, Commission staff member, or their
immediate family, being given an unfair personal or financial
advantage,

d. result in the employee, or a member of the employee’s immediate
family, being given an unfair personal or financial advantage, or

e. result in the vendor, patron, or agent being given an unfair personal
or financial advantage.

Consultant - One who, while acting in other than an employment role, receives
any form of compensation (except reimbursed travel expenses) for expert advise.

Financial Interest - Any right to some part of the profits, assets or other interests
of a business or business entity, or in the case of a corporation, any interest in
more than 1/10 of 1% of the outstanding shares.

Immediate family - an individual’s spouse or any person residing with the
individual, and the children, parents, siblings, grandparents, or grandchildren of
the individual or the individual’s spouse.

Outside Employment - Includes:

a. self employment :

b. employment by another, and

c. membership in a partnership, corporation, company, firm, etc.

d consultancy to, with, or for a partnership, corporation, company, firm,
etc. for compensation.

Participate - Employees may consider that they participate in a transaction on
behalf of the Isleta Gaming Operation when the employee acts directly for the
Isleta Gaming Operation, or directs, recommends, authorizes, approves, or
nullifies the action of another who acts for the Isleta Gaming Operation in a
transaction, or is involved in the source selection, specification development, or
technical evaluation of proposals for property or services to be procured, even
though the employee may not be involved in the actual negotiation or transaction
constitutes participation.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulations ©

TABLE OF CONTENTS

XI. = Computer Reports 7

XI. Accounting and Audit Functions 9

XII. Accounting Standards ---10
XIV. Auditing Standards 10
XV. Statistics - 11
XVI. Wagering Accounts --12
XVII. Telephone (Wire Communication) Wagering (if applicable) ---------------. -- 13
XVIII. Credit Wagering (if applicable) 14
XIX. Write Off Standards 15
XX. Enforcement Activity aoonnnnnee 15
XXI. Acknowledgments -. ----15
Commission Certification --- 16

Chapter 16: Gifts, Gratuities, & Solicitations

1 Authority 2
I. Purpose 2
In. Scope 2
IV. Definitions 2
Vv. Gifts and Gratuities -- 4
A. General 4
B. Employees 5
Cc. Tribal Government Officials 5
VI. — Exception(s) 5
VII. Solicitations 6
A. Individual 6
B. Employee 6
Cc. Non-Employees 7
D. Tribal Government Officials 7
VII. Enforcement Activity 7 7
IX. Notice of Disciplinary Action For Policy Violations womens 7
Xx. Acknowledgments 8
Commission Certification 8
Chapter 17: Notification to the Commission
I. Authority 2
I. ——- Purpose - 2


Chapter 7
Patron Dispute Resolution Page 5 of 5

CERTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 7, Patron Dispute Resolution, was duly REVISED,
ORDAINED, ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999,
at a duly called meeting of the Gaming Commission of the Pueblo of Isleta, at which a
quorum was present, with _2_ voting for, _0_ voting against, and _0_ abstaining.

Vacant

Chairman

(ATRICIA L. IN
Vice-Chairman

(AD getre

ecretary: STC JABAMIL

ATTEST

Subscribed and sworn before me on this the _16th_ day of December, 1999.

Spa 4.1m CQ

(NOTARY

My Commission Expires: / i wae walt 2002.

Isleta Gaming Commission Regulation Revised December 16, 1999


Notification to the Commission

"Chapter 17
: Page 10 of 12

VI. ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this policy as follows:

1.

6.

an imposition of a fine of no less than fifty dollars ($50.00) and no
more than five hundred dollars ($500.00) for employees;

an imposition of a fine of no less than five hundred dollars
($500.00) and no more than twenty-five thousand dollars
($25,000.00) for vendors;

disciplinary action up to and including suspension or revocation of
employee gaming license,

disciplinary action up to and including suspension or revocation of
vendor gaming license;

the placing of restrictions or conditions on the licensee’s retention
of their gaming license, and/or

the combination of any of the above

VIM. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

A. All Management, Employees, and Vendors of any Isleta Gaming
Operation are subject to the following action:

1.

Refusal to comply’ or. Fine, denial, suspension,

violation of this policy. revocation, termination
of and/or restrictions on
Gaming License.

IX. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Isleta Gaming Operation(s). Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or any employee, of any employment or any
continued employment whatsoever, nor shall any provisions of this Regulation constitute
or be interpreted by any party or tribunal to constitute‘any contractual rights of
employment expressed or implied, or any obligation of employment rights created by
covenants of good faith and fair dealings, either expressed or implied.

Vendor compliance with this Regulation is a condition of performing business at
or with the Isleta Gaming Operation(s). Nothing in this Regulation shall be construed as

Isleta Gaming Commission Regulations Revised December 16, 1999


Chapter 8
Employee Grievance Procedures Page 4 of 7

the employee wants redress, the responsibility should be placed
squarely on his/her shoulders to carry this through to the next level.
An aggrieved employee shall be responsible for submitting his
grievance form to the Isleta Gaming Palace Human Resource
Department.

2. Grievance Form

The grievance form should be filled out by the aggrieved person(s)
and should contain:

a. Name of immediate supervisor. Unless this is a patron, in
which case, the patron may fill in the name of the Palace
personnel they dealt with.

b. Name of aggrieved person or persons.

Reasons, in detail, for filing the grievance. Must be

2

supported by facts.
d. Date of incident(s).
e. Action(s) sought by formal filing of grievance form.
f£ The employees signature.
g. The signature of the person accepting the grievance form.

C. Step M1.

The next step in the procedure shall finally be the upper echelons of Palace
Management. If no redress is forthcoming at the immediate Supervisory
and Department Managers levels, the General Manager and/or his assistant
shall become involved. Once again,.it should be the employee’s
responsibility to forward his/her grievance form to this level.

Now, there are three (3) levels of grievance procedures in place within the
Palace. This should be sufficient to handle most employee or patron
grievances without involving the Gaming Management Board or any
Tribal entity beyond that. Unless there is a managerial conspiracy afoot,
most disputes should receive a-fair and equitable solution at one or all
levels of Palace Management.

D. Step IV.

“Step IV” should be a grievance appeal to the Gaming Management

Board. Any employee grievance appeal beyond the General Manager must
be of an extremely serious nature and must have infringed, gregariously;——~
on the employee’s rights. The Gaming Management Board shall

determine and promulgate procedures for entertaining, hearing, and

Isleta Gaming Commission Regulation . : , Revised December 16, 1999


Training Requirements

Chapter 20
Page 4 of 10

The Isleta Gaming Palace General Manager shall be responsible
for documenting all training received by each Upper Level
Management employee in order to maintain a record of job
knowledge, training received by the management employee, the
results of the training, if applicable, and forward said
documentation to the Human Resource Department to be place in
the Upper Level Management employees official file. (For
information on training forms see Section VI, The Role of the
Human Resource Department, below)

The Isleta Gaming Palace General Manager will keep one (1) copy
of the Isleta Gaming Commission Regulations and one (1) copy of
each Departments Standard Operating Procedures in his/her
administrative office or the general vicinity thereof.

In the event a new member of upper level management is hired by
the Isleta Gaming Palace and the aforementioned training(s) has
been concluded, it is the responsibility of the General Manager to
train each new hire on all Isleta Gaming Commission Regulations
and Isleta Gaming Palace Standard Operating Procedures prior to
the new hire being allowed to take authority and begin the newly
acquired position with any Isleta Gaming Operation.

Ignorance of any Commission Regulation or Isleta Gaming Palace
Standard Operating Procedure shall not be acceptable as an excuse
for a violation of any Regulation, policy, or procedure. If the
General Manager does not know a regulation or policy or
procedure, the General Manager should, at least, know where to
look it up in order to make an informed decision on any situation.

B. Upper Level Management

1,

It is the responsibility of the Isleta Gaming Palace Upper Level
Management to assure that all subordinate employees are fully
trained and aware of all Isleta Gaming Commission Regulations
and Isleta Gaming Palace Standard Operating Procedures. This
shall include but is not limited to, the cross training of subordinate
employees on interdepartmental Standard Operating Procedures, as
applicable.

Each Isleta Gaming Palace Department Manager shall hold a
mandatory training session(s) for all subordinate employees at least
once a year, or as deemed necessary by circumstances. This
training session(s) shall be sufficient enough in duration to review,


Code of Conduct.

Chapter 18
Page 11 of 14

a. creates, or appears to create, a conflict of interest

b. in any manner interferes with the proper and effective
performance of Isleta Gaming Commission duties.

c. is ina field directly related to Gaming.

Commissioners or Commission staff members must disclose, in
advance, all consulting or other outside employment, including
self-employment, that the employee proposes to undertake. The
proposed consulting or other outside employment shall not begin
prior to approval by both the employee’s supervisor and the Tribal
Govemor. (For complete details see Pueblo of Isleta Personnel
Policies and Procedures Manual, Policy No. 216, Outside
Employment)

VOI. ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this policy as follows:

1.

7.

an imposition of a fine of no less than fifty dollars ($50.00) and no
more than five hundred dollars ($500.00) for employees;

an imposition of a fine of no less than five hundred dollars
($500.00) and no more than twenty-five thousand dollars
($25,000.00) for vendors;

disciplinary action up to and including suspension or revocation of
any employee gaming license;

disciplinary action up to and including suspension or revocation of
any vendor gaming license. This includes, but is not limited to,
suppliers, corporations, partnerships, companies, firms,
contractors, subcontractors, etc. and their employees. Not
allowing the aforementioned entities on premises (banishment);

the placing of restriction and/or conditions on any gaming license;
banishment from the Gaming Operation(s);
criminal prosecution; and/or

the combination of any of the above.

IX. NOTICE OF DISCIPLINARY ACTION FOR POLICY VIOLATIONS

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 18
Code of Conduct Page 2 of 14

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to Tribal Resolution 95-03 enacted January 28, 1995 and any
ordinance(s) adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Pueblo
of Isleta/State of New Mexico Indian Gaming Compact.

I. PURPOSE

The purpose of this regulation is to provide a code of conduct to be above
reproach regarding any unethical business practices that might result in unusual or
favorable treatment or allow undue influence of employee judgment with regard to daily
business dealings with any vendor or patron or other employee.

This regulation will specifically enumerate the manner in which the Commission will
exercise said authority in its’ oversight of all Conflicts of Interest within the Pueblo of
Isleta Gaming Operation. In applying this authority, the Commission will act ina
responsible and consistent manner when promulgating, adopting, approving, revising,
implementing, administering, and enforcing the rules, regulations, policies, and decisions
of the Commission.

Id. SCOPE

This regulation pertains to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
Resolution or Tribal Ordinance adopted thereto, the Indian Gaming Regulatory Act of
1988, and the Pueblo of Isleta/State of New Mexico Indian Gaming Compact.

This regulation applies to all Commissioners, Commission staff, Tribal
Government Officials, and Isleta Gaming Palace; Management, employees, agents,
vendors, and patrons.

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural. :

Conflict of Interest - A relationship or situation that exists or may appear to exist
concerning any Commissioner, Commission staff, their immediate family, Isleta
Gaming Palace employees, the employee’s immediate family, agents, vendors, or

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 10
Alcohol. Page 5 of 5

RTIFICATION

We, the undersigned, do hereby certify that the foregoing Pueblo of Isleta Gaming
Commission Regulation, Chapter 10, Alcohol, was duly REVISED, ORDAINED,
ADOPTED, AND RATIFIED on this the _16th_ day of December, 1999, at a duly
called meeting of the Gaming Commission of the Pueblo of Isleta, at which a quorum
was present, with 2 voting for, _0_ voting against, and_0_ abstaining.

Vacant

Chairman

(sas2 ds Vins
”ATRICIA LSIRON

Vice-Chairman

ing Ae
ATTEST

Subscribe and sworn before me on this the _16th_ day of December, 1999.

ODESSA A. MONTOYA TARY <
‘NOTARY PUBLIC-STATE OF |
aula me

My Commission Expires: 6 Z

Isleta Gaming Commission Regulation Revised December 16, 1999


Licensing

Chapter 5
Page 18 of 35

I. Confidentiality of Commission Information

1.

The Commission, Commission agents, and all employees who have
access to or handle confidential information shall not reveal any
information contained in an application, file, report, or investigation to
any third party, including, but not limited to, immediate family
members, relatives, or sources outside of the Commission.

Confidential information may be released for the following reasons,
only upon the approval of the Commission:

a. to an investigative agency charged with conducting background
investigations on applications pursuant to a delegation made
under Article VIII ( C ), herein;

b. to the National Indian Gaming Commission;

to the Federal Bureau of Investigation; or

d. to an authorized representative of federal, tribal, state, local, or
foreign government or a regulatory agency, when the
information sought relates to a civil, criminal, or regulatory
investigation or prosecution; provided, that the receiving
representative/agency has entered into a written agreement with
the Commission and/or submits a Release of Information,
signed by the individual in question, to the Isleta Gaming
Commission.

°

If any Commission agent or employee required to handle confidential
information violates any of the provisions of this section, he or she
shall be subject to immediate termination. If a member of the
Commission violates any of the provisions of this section, he or she
shall be subject to immediate removal from the Commission, as set
forth in Article III of the Pueblo of Isleta Gaming Commission By-
laws (Enacted, April 27, 1998).

The Commission shall hold training sessions on the handling of
confidential information. Attendance at the training session shall be
mandatory for all members of the Commission, as well as for all
agents and employees who are required to handle confidential
information. Training sessions shall be held annually, or whenever the
Commission, in its discretion, deems it necessary.

. The Commission retains the right to further restrict disclosure of

confidential information and to enact regulations to ensure compliance
with the provisions of this section. (See. IGCR Chapter 21 Confidential
and Proprietary Information).

Isleta Gaming Commission Regulation Revised December 01, 1999


Licensing

Chapter 5
Page 24 of 35

Commission shall make the final decision to issue or not to issue a
license to the applicant.

No gaming operation of the Pueblo of Isleta shall employ a key
employee or primary management official who has not been issued a
license under this Chapter after ninety (90) regular days of
employment. For further detail, see Article VIII. (D, E, and F) herein.

B. Employees other than Key Employees or Primary Management Officials

1.

The Commission may issue a license to any employee (other than a
key employee or primary management official) after making a
determination that the employee is eligible to receive a license under
Article IX of this Chapter.

In the event that an employee with the Isleta Gaming Operation
receives a promotion to a Primary Management Official or Key
Employee position, that employee must immediately report to the
Isleta Gaming Palace Human Resource Office to obtain transition
documentation. Along with the said documentation, the employee
must report to the Office of the Isleta Gaming Commission to
complete any additional licensing forms and obtain a new ID Badge.
This process must be completed prior to said employee beginning their
new position. No exceptions! The employees retention of this new
position shall depend on their capability to surpass an additional
eligibility determination and be deemed suitable under all articles of
this Chapter: No additional Licensing Fee is required.

In the event that any employee of the Isleta Gaming Operation
transfers from one position to another, regardless of department, that
employee must immediately report to the Isleta Gaming Palace Human
Resource Office to obtain transition documentation. Along with the
said documentation, the employee must report to the Office of the
Isleta Gaming Commission to complete any additional licensing forms
and obtain a new ID Badge. This process must be completed prior to
said employee beginning their new position. No exceptions! The
employees retention of this new position shall depend on their
capability to surpass an additional eligibility determination and be
deemed suitable under all articles of this Chapter. No additional
Licensing Fee is required.

C. Vendors

1.

The Commission, in its sole discretion, may grant or deny a license to

Isleta Gaming Commission Regulation Revised December 01, 1999


Code of Conduct

Chapter 18“
Page 10 of 14

Employees shall not engage in outside employment, that is,
perform work for pay or other compensation if such employment:

a. creates, or appears to create, a conflict of interest

b. in any manner interferes with the proper and effective
performance of Isleta Gaming Operation duties.

c. is ina field directly related to the Gaming industry.

Employees of the Isleta Gaming Operation must disclose, in
advance and in writing, all consulting or other outside
employment, including self-employment, that the employee
proposes to undertake. [he proposed consulting or other outside
employment shall not begin prior to approval by the employee’s
Department Manager and the General Manager. This approval
must be in writing and a copy placed in the employee’s Human
Resource file.

All employees are required to report and obtain approval, in
writing, for any outside employment, consulting, or other
comparable employment services prior to participating or engaging
in the activity.

In the event outside employment is approved, it is the employees
responsibility to continuously keep the Isleta Gaming Operation
informed of any and all changes in that outside employment
throughout their tenure with the Isleta Gaming Operation.

Outside employment being approved for a particular occupation
does not constitute approval for another occupation. Each time an
employee changes outside employment he/she must report and
obtain approval in accordance with this regulation and applicable
SOP. (See Subsection 5, herein, above)

Outside employment that is not related to the Isleta Gaming
Operation is generally acceptable as long as the activity does not
interfere with the employee’ s effective performance of their jobs,
and the employee does not use Isleta Gaming Operation resources
or time to accomplish the tasks.

Commissioner’s and Commission Staff

Employees shall not engage in outside employment, that is,
perform work for pay or other compensation if such employment:

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 2

Promulgating
Internal Procedures & Regulatory Provisions Page 2 of 9

I AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta. The Pueblo of Isleta grants this authority to the Isleta Gaming
Commission pursuant to resolution 95-03 enacted January 28, 1995 and any ordinance
adopted thereto.

I. PURPOSE

The purpose of this Regulation is to provide a functional set of administrative
guidelines in order for the Commission to ensure comprehensive and consistent
regulatory oversight of all Pueblo of Isleta Gaming Operations. In overseeing the gaming
operations, the Commission shall act in a responsible and consistent manner when
promulgating, adopting, approving, revising, implementing, administering and enforcing
the rules, regulations, policies, procedures, and decisions of the Commission. In carrying
out its’ responsibilities, the Commission shall operate under the following:

A. Fundamental faimess, justice and common’ sensé.

B. Responsible and organized record keeping. Some records may contain
confidential information, which shall not be accessible to the public.

Ti. SCOPE

This regulation applies to all functions and duties over which the Commission
retains jurisdiction and authority pursuant to Isleta Tribal Resolution 95-03 and any other
resolution adopted thereto, the Indian Gaming Regulatory Act of 1988 25 U.S.C. 2701,
and the Pueblo of Isleta/State of New Mexico Indian Compact. This regulation does not
apply to other tribal entities or agencies within the Pueblo of Isleta Tribal Government.

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural. :

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See.the Pueblo of Isleta Gaming Commission
By-laws enacted April 27,1998.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 15

Race and Sports Book Computerized Page 10 of 16

XI. ACCOUNTING STANDARDS

Note: An adequate software analysis may result in reducing the

A.

following two (2) requirements.

For a minimum of two (2) writer stations per shift per month (rotated
among writers and between race and sports) accounting personnel:

1. Foot the sequentially connected copy of written tickets and
trace the totals to those produced by the system.

2. Review the connected copies for sequential numbering and
document follow-up on missing numbers or blank tickets.

Accounting personnel foot the customer copy of paid tickets for a
minimum of one (1) cashier station per month and trace the totals
to those produced by the system.

The write and payouts are compared to the cash
proceeds/disbursements with a documented investigation being
performed on all large variances (i.e., overages or shortages
greater than one hundred dollars/$100.00 per writer/cashier).

XIV. AUDITING STANDARDS

A.

For all winning and voided sports book tickets and parlay card
tickets in excess of ten thousand dollars ($10,000.00), for all
winning and voided race book tickets in excess of one thousand
dollars ($1,000.00), and for a random sample of .2% (two tenths of
one percent) of all other winning race book and sports book tickets:

1. The tickets are recalculated and regraded using the
computer record of event results.

2. The date and starting time of the event/race per the results
report are compared to the date and time stamp on the ticket
and in the computer sales/transaction report.

3. The terms of the wager (e.g., point spreads, money-lines,
etc.) per the computer sales/transaction report or per the
results report (if that summary lists all point spreads and
money lines at which wagers were written or if a equivalent
report satisfying this requirement is produced) are reviewed.

Isleta Gaming Commission Regulation Revised December 16, 1999


Commission Certification

<25RO

Authority

Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 8

Employee Grievance Procedures

Purpose 7

Scope

Definitions
Steps of Formal Grievance Procedures

A.
B.

E.
NOTE

Step I.

Step II. —
1. Employee’s Responsibility in the
Formal Grievance Procedure

WWWNNNN

2. Grievance Form ----

Step III.
Step IV.

1. Petition

Contents of a Formal Petition ------------------------------

Aah Sp HW

2.
3. Hearing
4. Minimum Procedural Requirements

of a Formal Hearing -
5 Final Determination

Step V.

IDAAU


Chapter 2

Promulgating
Internal Procedures & Regulatory Provisions Page 7 of 9

bold/Corrective Action Date section, immediately below
this section. Managers are subject to disciplinary action by
the Commission for not returning the completed “Notice”
within the time allotted. In this Section, managers must,
fully describe the corrective action taken by the responsible
supervisor and/or the manager and include any preventive
measures to be implemented to prevent recurrence,
including any disciplinary action taken and a copy thereof
for verification.

CORRECTIVE ACTION DATE: The Commission agent
shall specify the date and/or time when corrective action
responses are expected from the Department Manager.

FOLLOW-UP OF CORRECTIVE ACTION: It is the
responsibility of the issuing Commission Agent to follow-
up no later than one (1) day after the Corrective Action
Date.

Requires furthier follow-up, shall be marked by the issuing
Commission Agent.

A Xerox copy shall be sent to the General Manager of the
Casino.

The back of the original form issued by a Commission
Agent is for COMMISSION USE ONLY and shall not be
copied to any individual or entity out side the Commission
Office.

INFRACTION FILE: Commission Auditors, Inspectors, and
Investigators will establish and maintain the issued Notice of
Infractions in an Infraction file in alphabetical order by last name.

After corrective action has been completed, the Notice of
Infraction will be filed in the Infraction file for future reference.

Issued Notices of Infraction that have been concluded shall be
stored for no less than three (3) years and then properly shredded
and disposed of.

The Commission, in the process of suitability determinations, or in
the process of license suspension or revocation actions, may refer

Isleta Gaming Commission Regulation pee ated Revised December 16, 1999


,, Chapter 5°
Licensing . i Page 3 of 35

Commission/Gaming Commission/Isleta Gaming Commission — pertains to
the Chairman, Vice-Chairman, or Secretary-Treasurer, in whole or individually,
of the Isleta Gaming Commission. See the Pueblo of Isleta 2 Gaming Commission
By-laws enacted April 27,1998. as oe

Commission Investigator/Agent - an employee of the Isleta Gaming
Commission, who performs the duties and responsibilities as specified by the
Commission in the job description for the Commission Investigator or Agent.
The Commission has direct supervision over the Commission Investigator or
Agent(s).

Compact - the Indian Gaming Compact between the Pueblo of Isleta and the
State of New Mexico providing for the conduct of Class III Gaming.

Confidential Information - any information whose unauthorized disclosure
could be prejudicial to the Isleta Gaming Commission, the Pueblo of Isleta
Gaming Operations, or other interested parties. The Commission has the
discretion to determine what constitutes “confidential information.” Confidential
information may include information governed by the Privacy Act or information
that affects the proprietary integrity of the Pueblo of Isleta Gaming Operation(s).

Employee - any person/individual employed by any Gaming Operation of the
Pueblo of Isleta.

Employment Application -an application for employment to work in any
Gaming Operation of the Pueblo of Tsleta.

Entity - any partnership, corporation, trust, association, company, firm, joint
venture, syndicate, vendor, or other organization.

Gaming Equipment - any device; equipment, machine, or material used in a
game of chance.

Gaming Vendor - any person or entity who manufactures, distributes, or sells
gaming equipment to any Gaming Operation of the Pueblo of Isleta.

Human Resources - the personnel department at any Gaming Operation of the
Pueblo of Isleta.

IGCR - Isleta Gaming Commission Regulation..,

Isleta Gaming Commission Regulation Revised December 01, 1999



‘Chapter 7
Patron Dispute Resolution Page 3 of 5

PATRON - A customer of any Pueblo of Isleta Gaming Operation.

PROBLEM GAMBLER - An individual who knowingly and recklessly places a
wager or puts up a stake on any game of chance to his/her serious financial
detriment.

V. PATRON DISPUTES -

The Commission derives its authority over patron disputes from Isleta Tribal
Resolution 95-03 and any subsequent resolutions or ordinances thereto and from
the Pueblo of Isleta/State of New Mexico Indian Gaming Compact.

A. Procedure for Determination of a Patron Dispute/Grievance

The Isleta Gaming Commission has the authority to hear any and all
patron disputes. However, a dispute will be heard solely at the discretion
of the Commission. Any dispute, which is brought before the
Commission, must have first exhausted any existing Isleta Gaming
Operation procedures before appealing to the Commission.

1. If after the General Manager has rendered a decision in a patron
dispute, the patron shall have ten (10) business days from the U.S.
Postmark date of the unfavorable decision to appeal it to the
Commission. .

2. Not withstanding Palace procedures, the Isleta Gaming Commission
shall have ten (10) working days from receipt of a patron grievance to
review and make an official written determination on said grievance.

a. No later than the terith (10th) business day after this
review/determination period, the Commission will notify,
by certified mail, the interested parties of its determination.

b. The notice shall include the Commission’s reasoning for its
determination and the determination itself. Each notice
shall be delivered to interested parties by certified mail,
return receipt.or hand delivered.

c. The Commission, at its discretion, may deem it necessary
to gather additional information from the interested parties.
This may be accomplished, in written form or by formal
hearing, Any request by the Commission for additional
information shall nullify the ten- (10) day determination

Isleta Gaming Commission Regulation - ae Revised December 16, 1999



Pueblo of-Isleta Gaming Commission
‘~ Regulation

TABLE OF CONTENTS

Chapter 4

Gaming Equipment or Devices or Supplies

I. Authority 2
IL. Purpose 2
Ill. Scope 2
IV. Procedures 2
A. Authorities 2
B. Procedure for the Control of
Electronic Gaming Devices (EGD) -- 3
1. License required; applications -----------------------------—----- 3
2. Approval of Gaming Devices; applications and procedures -3
3. Access to Electronic Gaming Devices (EGD) ----------------- 4
Cc. Procedures for Certifying/sealing Kobetron Testing
and Verification of Electronic Gaming Devices (EGD) -------------- 4
1. Procedures for Certifying/sealing Kobetron
Testing and Verification of EGD’ s------------------------------ 6
2. Procedure for Certifying and Sealing all EGD’s --------------6
D. __ Progressive Slot Machines ~ 9
E. Electronic Gaming Device... _ ;
(EGD) Pay-out and Odds Posting - : 9
F. Central Computerized Reporting and Auditing System -------------- 9
G. Class III Gaming Supplies Purchasing ---------------------------------- 10
Vv. Exceptions 10
VI. — Enforcement Activity 11
Vil. Notice of Disciplinary Action for Policy Violations --------------------------- ll
VIII. Acknowledgments 12
Commission Ratification 13

Nevada Standards - Attachment



<2HRO

Vill.
IX.
X.

Commission Certification

Pueblo of Isleta Gaming Commission

Regulation

TABLE OF CONTENTS
Chapter 16

Gifts, Gratuities, & Solicitations

Authority —

Purpose
Scope ----

Definitions

Gifts and Gratuities

A. General ----

B. Employees
c. Tribal Government Officials

Exception(s) -~
Solicitations

A. Individual ----

B. Employee
Cc. Non-Employees

D. Tribal Government Officials

Enforcement Activity —
Notice of Disciplinary Action For Policy Violations ---------
Acknowledgments

MCOIIYVADADANUUNUUNURANNNN


Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 13

Surplus Palace Property

I. Authority 2
Il. Purpose 2
Tl. Scope - 2
IV. Definitions oe 2
V. Procedures for Determining Surplus Property -------------------------------- ---3
VI. Disposal of Surplus Property 3
VII. Enforcement Activity 3
VIII. Notice of Disciplinary Action for Policy Violations ------------------------- ~- 4
IX.. Acknowledgments 4
Commission Certification 4



Chapter 2
Promulgating
Internal Procedures & Regulatory Provisions Page 3 of 9

Commissioner - An individual duly appointed by the Pueblo of Isleta Tribal
Council to serve as one (1) of three (3) members of the Isleta Gaming
Commission.

Confidential Information- Internal information, records, or documents not
accessible by or to the public.

Decision/Directive/Interim Directive/Order - A written ruling made by the
Commission on any matter within the scope of Commission authority.

Notice - The method of bringing the proposed Commission regulations or
decisions to the attention of interested parties and the public.

Policy - The general principles by which the Commission is guided in its
regulatory oversite of gaming affairs. ©

Procedure - Regulations or decisions that define the method or process used by
the Commission in its regulatory oversite of gaming affairs.

Quorum - The presence of two (2) Commissioners and the affirmative vote of
two (2) of the Commissioners for the purpose of conducting Commission
business.

Regulation — The general rules, controls, policies, or procedures incorporated,
implemented, and enforced by the Isleta Gaming Commission in relation to
Gaming on the Pueblo of Isleta. Any rule, control, policy, procedure, order, or
directive officially adopted or issued by the Isleta Gaming Commission and
prescribed to management of any Isleta Gaming Operation including but not
limited to the following:

1. The violation of which may result in a fine, penalty, or other civil
administrative sanction;

2. May establish, revise, amend, alter, or nullify a rule, policy, procedure,
practice, or requirement of any Pueblo of Isleta Gaming Operation’s
Standard Operating Procedure (SOP);

3. May establish, revise, amend, alter, or revoke a rule, control, policy,

procedure, practice, or requirement of administrative hearings;

May establish, change, or revoke requirements relating to benefits;

May establish, change, or revoke standards for assistance, suspension,

or revocation of Gaming Licerises; :

6. The amendment or repeal of a prior ‘segulation' or decision.

WP

Isleta Gaming Commission Regulation Revised December 16, 1999


- Chapter 5 =
Licensing - ea Page 14 of 35

APPLICATION SHALL NOT LEAVE THE OFFICE OF
THE ISLETA GAMING.COMMISSION.

2. Vendors

a. The Commission shall provide applications to all potential
vendors upon request. To expedite a vendor application,
vendors may take this application, if necessary, to their place of
business for completion and return it, via fax, to the Office of
the Isleta Gaming Commission, but the Original application
with all original signatures, releases, etc. must be hand
delivered and/or mailed to the Office of the Isleta Gaming
Commission. A vendor application can not be completely
processed without the Original documents. Failure to return
the Original application to the Commission will result in denial
of application. (Also, see Article VI, Licensing Fee, B, 3, 4, or
5, herein.)

b. Upon receiving a completed application and the appropriate
licensing fee, the Commission shall conduct a background
investigation on the applicant. The Commission shall:

1) contact all persons or entities identified in the
application either by telephone or in writing, in order to
verify that the information in the application is truthful
and accurate;

2) interview a sufficient number of knowledgeable people,
such as references, former employers, partners, business
associates and others referred to in the application;

3) review the credit history and relevant financial records
of the applicant for at least three (3) years preceding the
application; and

4) contact any local, state, federal, tribal or other
government agency referred to in the application.

c. Ifa vendor chooses to withdraw their License application before
the background investigation is complete, the investigation shall
continue to completion. The Commission, in its discretion may
stop the investigation at the applicants written request, if the
background investigation has not begun. The vendor however,
remains liable for the nonrefundable licensing fee required

Isleta Gaming Commission Regulation Revised December 01, 1999


Chapter 19
TD Badges Page 12 of 13

or be interpreted by any party or tribunal to constitute any contractual rights of
employment expressed or implied, or any obligation of employment rights created by
covenants of good faith and fair dealings, either expressed or implied.

_ Vendor compliance with this Regulation is a condition of performing business at
or with the Isleta Gaming Operation. Nothing in this Regulation shall be construed as
any guarantee or promise to any applicant or vendor, of any business dealings or any
continued business dealings whatsoever, nor shall any provision of this Regulation
constitute or be interpreted by any party or tribunal to constitute any contractual rights of
business expressed or implied, or any obligation of business rights created by covenants
of good faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate nor
shall it constitute any waiver of or limitation on all employees and vendors responsibility
to obtain an I.D. Badge prior to beginning work or performing business for or with any
Isleta Gaming Operation.

To the fullest reasonable extent possible, confidentiality is to be maintained in all
applications of this Regulation.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, from time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 12
Marketing & Promotions Page 5 of 6

Xl. ACKNOWLEDGMENTS

Employee compliance with this Regulation is a condition of employment at or
with the Casino. Nothing in this Regulation shall be construed as any guarantee or
promise to any applicant or any employee, of any employment or any continued
employment whatsoever, not shall any provision of this Regulation constitute or be
interpreted by any party or tribunal to constitute any contractual rights of employment
expressed or implied, or any obligation of employment rights created by convenants of
good faith and fair dealings, either expressed or implied.

Nothing in this Regulation shall be interpreted as constituting any waiver of or
limitation on the Tribe’s right to invoke disciplinary measures as may be appropriate.

This Regulation may be amended as necessary to meet the interests of the
objectives of this Regulation as may be determined, form time to time. All rights to
further amend, refine, and redefine are specifically reserved to the Isleta Gaming
Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999


Pueblo of Isleta Gaming Commission

Regulation
TABLE OF CONTENTS
Chapter 10
Alcohol
I Authority 2
Il. Purpose 2
I. Scope 2
IV. Alcohol Procedures ---- 2
A. Sale of Alcohol 2
B. Alcohol Education 2
Cc Certification 3
D. Liability Insurance ----3
E. Use of Alcohol/Food/Lodging as Promotional Items ----------------- 3

Vv. Enforcement Activity:
VI. Notice of Disciplinary Action for Policy Violations ——
VII. Acknowledgments ----
Commission Certification



Chapter 10
Alcohol Page 3 of 5

similar to those classes provided for the New Mexico Liquor Control
Act.

C. Certification

1. Gaming Facility employees that dispense, sell, serve, or deliver
alcoholic beverages must be Liquor Certified and must carry their
Certification Card at all times when working.

D. Liability Insurance

A liquor liability insurance policy that will provide, at a minimum,
personal injury coverage of one million dollars ($1,000,000.00) per
incident and two million dollars ($2,000,000.00) aggregate per policy year
will be purchased and maintained.

E. Use of Alcohol/Food/Lodging as Promotional Items

A Tribal Gaming Enterprise and the Tribe are prohibited from
providing, allowing, contracting to provide, or arranging to provide
alcoholic beverages, food, or lodging for no charge or at reduced prices
at a Gaming Facility or lodging facility as an incentive or enticement
for patrons to game.

Vv. ENFORCEMENT ACTIVITY

A. The Commission reserves the right to enforce this policy as follows:
1. an imposition of a fine,
2. disciplinary action up to and including suspension or revocation of

employee gaming license,

3. the placing of restrictions or conditions on the licensee’s
retention of their gaming license, and/or

4. the combination of any of the above

Isleta Gaming Commission Regulation . . Revised December 16, 1999



Pueblo of Isleta Gaming Commission

Regulations

TABLE OF CONTENTS

Chapter 1: Commission Regulation Authority

< 2887

Authority

Purpose

Scope -- none

Definitions -

Authority of the Isleta Gaming Commission
A. Isleta Tribal Resolution 95-03

The Pueblo of Isleta/State of New Mexico

Class II] Gaming Compact -

B.
C. The Indian Gaming Regulatory Act of 1988 -----------—--------------- 9
D.

Minimum Internal Control Standards (MICS)

of the National Indian Gaming Commission ------------------------- 9
Commission Certification —— -

11

Chapter 2: Promulgating Internal Procedures & Regulatory Provisions

I

I
Il
Iv.
Vv.
VI
Vil

vil.

Commission Certification

Authority

Purpose

Scope
Definitions

Promulgating Regulations
Promulgating Ordinances

BFNNNN

Promulgating Policies, Procedures, and Controls

an

for the Pueblo of Isleta Gaming Operation ‘
Methods of Enforcing Rules, Controls, Regulations, Minimum
Internal Control Standards, Gaming Laws, Other Applicable

Laws, Policies, and Procedures

Chapter 3: Gaming Participation & Operation

On

SBR

Authority

Purpose
Scope

Gaming Participation

A. Patrons:
B. Employee



<28eO

VI.

Commission Certification

Pueblo of Isleta Gaming Commission
Regulation

TABLE OF CONTENTS

Chapter 7
Patron Dispute Resolution

Authority
Purpose
Scope ~
Definitions
Patron Disputes
A. Procedure for Determination of an Employee Grievance -
B. Formal Hearing by Commission on Grievance ------------
Self Identified Problem Gamblers



Chapter4 ~
Gaming Equipment or Devices or Supplies a Page 6 of 13

- «5. Signature of Slot Technician
6. Brief notation of action taken.

d. The above is continuously subject to inspection, audit, and
investigation by the Pueblo of Isleta Gaming Commission.

C. Procedures for Certifying/sealing, Kobetron Testing, and Verification of
Electronic Gaming Devices (EGD)

1. Procedure for Sealing Logic Board

a. Each Electronic Gaming Device in the inventory of any Isleta
Gaming Operation and its’ subsidiary operations must have its
master program logic board sealed by a Commission Inspector
with the Commissions sequentially numbered seal tape,
hereinafter known as, Commission Seal.

b. Each seal tape affixed onto the program/logic board must be
confirmed by the signature of the Commissioner or their
designee listed in Subsection A., 1., a. above. The title of each
seal tape must have sequential numbering and read as follows:

ISLETA GAMING COMMISSION
By: No. 000001 Date:

c. The Slot Security Control Log placed in the machine must
contain the signature of the Slot Tech when entering an EGD.
(See Section IV, A., 1., b., herein).

2. Procedures for Certifying and Sealing all EGD

a. The Slot Technician will remove the Logic Board from the
machine and write the Asset number and/or Serial number from
the board.

b. The Main Chip, Personality Chip and Supplemental Chip(s)
must be removed from the Logic Board, tested (Kobetroned),
witnessed, and recorded by a Commission Inspector, to verify
EPROM signatures and GLI approval. This must occur prior
to an electronic gaming device being utilized or depending on
circumstances, at.the discretion of the Commission.

Isleta Gaming Commission Regulation Revised December 16, 1999



. Chapter 15
Race and Sports Book Computerized Page 8 of 16

8. Exception report (e.g., past-post voids, past-post write,
voids, odds changes).

9. Daily recap report.
10. Personnel access listing.
B. The reports contain at least the following information:

1. Write, payout, telephone, and credit transaction reports

daily):

a. Ticket number.

b. Date/time written/paid.

c. Type/amount of wager.

d. Animal/team identification.

e. Amount of payout.

f. Telephone identification.

g. Total telephone account, writer/cashier and day.

2. Futures report (daily or when applicable):

a Ticket number.

b. Date/time written.
c. Amount of wager.
d.

Future wagers for the day by total and broken out by
dates of events.

e. Summary of future wagers by dates of events and in
total at the time of revenue recognition.

3. Unpaid winners report (daily)

a. Ticket number.

b. Date/time written.

c. Amount of wager/payout.
d. Totals.

4. Exception report (daily):

a. Ticket number.

b. Date/time written.

c. Type/amount of wager.
d.

Exception. ‘

Isleta Gaming Commission Regulation . Revised December 16, 1999


Pueblo of Isleta Gaming Commission
Regulation

(Revised December 16, 1999)

Chapter Dn

Marketing & Promotions

pe pn ae ese enc ame


Chapter 8
Employee Grievance Procedures Page 2 of 7

L AUTHORITY

The Isleta Gaming Commission has the authority and jurisdiction to promulgate
regulations in order to ensure and protect the integrity and assets of all gaming operations
of the Pueblo of Isleta and to provide for the safety and protection of Palace employees.
The Pueblo of Isleta grants this authority to the Isleta Gaming Commission pursuant to
Resolution 95-03 enacted January 28, 1995 and any ordinance adopted thereto.

I. PURPOSE

It has come to the attention of the Commission that a strong framework and, to
some degree, employee grievances must be established to control the number of disputes
that will be making their way through the formal process. However, the present process
is just too broad to be effective. As the procedures are written, any employee with any
grievance may appeal a Palace decision through all channels of the Palace including to
the Tribal Council. In accordance with énacted tribal ordinances, such grievances may, if
decided against an employee and if the circumstances meet the proscribed criteria, be
appealed to higher levels of Tribal Government. The Commission understands that such
procedures are necessary for fair and equitable adjudication of individual rights.
However, with such a comprehensive grievance procedure, it is imperative that only
appeals of gregarious infringements of individuals rights be entertained beyond Palace
Management. The framework outlined below shall ensure this desirable process.

WW. SCOPE

This regulation shall insure that the Gaming Operations of the Pueblo of Isleta
equally apply and afford to all employees, a Grievance process at least as stringent as set
forth herein, without exception. No such grievance shall travel beyond the boundaries set
within this document. The Commission retains jurisdiction and authority over such
matters pursuant to Isleta Tribal Resolution 95-03 and any other resolutions or ordinances
adopted thereto, the Indian Gaming Regulatory Act of 1988, and the Isleta/State of New
Mexico Indian Gaming Compact. This Regulation does not apply to other tribal entities
or agencies within the Pueblo of Isleta Tribal Government.

IV. DEFINITIONS

The following definitions are intended to clarify the items covered in this
regulation. Throughout this document the use of these definitions in the singular,
also includes the plural. . °

Regular Employees - The policy reads “regular employees.” This should be
further defined as “regular full-time employees” who have satisfied the ninety
(90) day probationary period, if that is the intent. Otherwise, as it reads, part-time
regular employees (as defined by the employee handbook) may undertake an

Isleta Gaming Commission Regulation Revised December 16, 1999


Chapter 4
Gaming Equipment or Devices or Supplies Page 9 of 13

c. The Isleta Gaming Operation may distribute the increment amount
to another progressive jackpot at the Operation’s establishment
and:

1. Must document the distribution;

2. Any machine offering the jackpot to which the Isleta Gaming
Operation distributes the incremental amount does not require
that more money be played on a single play to win the jackpot
than the machine from which the incremental amount is
distributed;

3. Any machine offering the jackpot to which the incremental
amount is distributed complies with the minimum theoretical
payout requirement of the Pueblo of Isleta/State of New
Mexico Indian Gaming Compact or the Nevada Standards,
Regulation 14.040(1); and

4. The distribution is completed within thirty (30) calendar days
after the progressive jackpot is removed from play or within
such longer period as the Commission Chairman or his/her
designee may for good cause approve; or

d. The Commission Chairman or his/her designee, upon showing of
exceptional circumstances, approves a reduction, elimination,
distribution, or procedure not otherwise described in this
subsection, which approval is confirmed in writing.

E. Electronic Gaming Device (EGD) Pay-out and Odds Posting

1. Each electronic or electromechanical gaming device in use at the
Gaming Facility will pay out a mathematically demonstrable
percentage of all amounts. wagered, which must not be less than eighty
percent (80%); .

2. Odds will be posted on each electronic and electromechanical gaming
device.

F. Central Computerized Reporting and Auditing System

1. All Gaming machines on the premises of the Gaming Facility will be
connected to a central computerized reporting and auditing system on
the Gaming Facility premises, which shall collect on a continual basis
the activity of each gaming machine in use at the Gaming Facility, and

Isleta Gaming Commission Regulation . bon Revised December 16, 1999