Mashpee Wampanoag Tribe

In compliance with the Privacy Act of 1974, the following information is
provided: Solicitation of the information on this form is authorized by 25 USC §§
2701 et seg. The purpose of the requested information is to determine the
eligibility of individuals to be granted a gaming license. The information will be
used by the Tribal gaming regulatory authorities and by the National Indian
Gaming Commission members and staff who have need for the information in the
performance of their official duties. The information may be disclosed to
appropriate federal, tribal, state, local or foreign law enforcement and regulatory
agencies when relevant to civil, criminal or regulatory investigations or
prosecutions or when pursuant to a requirement by a tribe or the National Indian
Gaming Commission in connection with the issuance, denial, or revocation of a
gaming license, or investigations of activities while associated with a tribe or a
gaming operation. Failure to consent to the disclosures indicated in this notice
will result in a tribe's being unable to license you for a primary management
official or key employee position. The disclosure of your Social Security Number
(SSN) is voluntary. However, failure to supply a SSN may result in errors in
processing your application.

2. Existing Key Employees and Primary Management Officials shall
be notified in writing that they shall either:

a. complete a new application form that contains a Privacy
Act notice; or

b. sign a statement that contains the Privacy Act notice and
consent to the routine uses described in that notice.

3. The following notice shall be placed on the application form for a
key employee or a primary official before that form is filled out by an applicant:

A false statement on any part of your license application may be grounds
for denying a license or the suspension or revocation of a license. Also, you may
be punished by fine or imprisonment (U.S. Code, Title 18, Section 1001).

4, The Commission shall notify in writing existing Key Employees
and Primary Management officials that they shall either:

a) complete a new application form that contains a notice
regarding false statements; or

b) sign a statement that contains the notice regarding false
statements.
G Background Investigations

The Commissioner shall request from each Primary Management
Official and from each Key Employee all of the following information:

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Mashpee Wampanoag Tribe

4. develop and implement procedures for resolving disputes between the
gaming public and the Mashpee Wampanoag Tribe or the gaming enterprise
management;

5. designate an agent for service of legal notices;
6. develop and implement procedures to take finger-prints;

7. develop and implement procedures for conducting criminal and credit
histories and checks;

8. develop and implement procedures to prevent theft and ensure the
integrity of the gaming enterprises of the Mashpee Wampanoag Tribe;

9. develop and implement procedures for collection of license fees, taxes,
other fees and levies as the same relates to gaming enterprises of the Mashpee

Wampanoag Tribe.
ARTICLE V
REGULATIONS

Section 500 Commission regulatory authority
Section 501 Notice required, changes in regulations
Section 502 Copies of regulations to be available
Section 503 Suspension and hearing regulations
Section 504 Revocation regulations

Section 505 —_ Exclusion

Section 506 Informant identity protected

Section 507 Depositions authorized

Section 508 Service Requirements

Section 509 Gaming Commission Attorney

SECTION 500 COMMISSION REGULATORY AUTHORITY

Any regulations promulgated by the Commission shall have full force and effect from the
date of issuance. The Commission may withdraw, replace or amend any Commission regulation.

SECTION 501 NOTICE REQUIRED, CHANGES IN REGULATIONS

A. In adopting, amending or repealing any regulations under this Act, the
Commission shall give a minimum of ten (10) days notice of proposed regulation changes to the
Tribal Council, all Key Employees, Primary Management Officials, the Chairperson and the
Chief Executive Officer of the Tribe’s Gaming Authority.

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Mashpee Wampanoag Tribe

B. The Commission shall notify the licensee of a time and a place for
a hearing on the proposed revocation of a license.

(on After a revocation hearing, the Commission shall decide to revoke
or to reinstate a gaming license. The Commission shall notify the National Indian
Gaming Commission, the Chairperson and the Tribal Council of the decision.

SECTION 605 FINGERPRINTS ON FILE

A. The Commission shall keep the official fingerprint records for the National Indian
Gaming Commission on file in the office of the Commission.

1. As part of any employment application, fingerprints shall be taken in a
format then currently used by the National Indian Gaming Commission.

2. The Commission shall take such prints in a manner established by
regulation or policy.

J: After fingerprints have been taken, the Commission shall forward them
directly to the National Indian Gaming Commission in the method required by the
National Indian Gaming Commission.

4. Fees charged by the National Indian Gaming Commission for processing
of fingerprints shall be paid by the Mashpee Wampanoag Tribe, excepting those
individuals and organizations which have posted bonds for such reports.

B. The Commission shall request a report from the National Indian Gaming
Commission which shall include a check through the Federal Bureau of Investigation's
National Criminal Information Center.

c Fees charged by the National Indian Gaming Commission for processing such
reports shall be paid by the Tribe excepting those individuals and organizations that have
posted bonds for such reports.

SECTION 606 CRIMINAL BACKGROUND CHECKS.

The Commission shall initiate criminal background checks for each applicant for
employment in a position that requires licensing which shall include a criminal history check,
fingerprinting by the Commission, and submission of the fingerprints to the National Indian
Gaming Commission for a check of criminal history records information maintained by the
Federal Bureau of Investigation.. 7

A. The Commission shall receive the report or a summary of any initial
background check which shall identify any felony, criminal history, or crime of moral
turpitude which is known to any law enforcement entity. The Commission and its
employees shall be considered tribal law enforcement officers for such review.

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Mashpee Wampanoag Tribe

ARTICLE V
REGULATIONS

Section 500 Commission regulatory authority
Section 501 Notice required, changes in regulations
Section 502 Copies of regulations to be available
Section 503 Suspension and hearing regulations
Section 504 Revocation regulations

Section 505 Exclusion

Section 506 Informant identity protected

Section 507 — Depositions authorized

Section 508 Gaming Commission Attorney

ARTICLE VI
LICENSING

Section 601 License regulation

Section 602 Issuance of licenses

Section 603 Appropriate investigation required
Section 604 License suspension

Section 605 Fingerprints on file

Section 606 Criminal background checks
Section 607 Facility Licenses

ARTICLE VII
GAMING DISPUTES WITH MANAGEMENT

Section 701 Filing complaints

Section 702 Hearing date

Section 703 Hearing notice required

Section 704 Legal counsel authorize

Section 705 — Arbitration or mediation authorized

483 Great Neck Rd. South, Mashpee, MA 02649 — (508) 477-0208 (508) 477-1218 fax


Mashpee Wampanoag Tribe

CERTIFICATION

We, the undersigned Chairperson and Secretary of the Mashpee Wampanoag Tribal Council do
hereby certify that the Tribal Council is composed of 13 members of whom 9, constituting a
quorum, were present at a meeting thereof, duly and regularly called, noticed, convened, and
held on the 4" day of June, 2012, and that the foregoing Resolution was duly adopted by the
affirmative vote of 7 members, with 1 opposing, and with Q not voting.

DATED this 4" day of June, 2012 CL Z ML!
CAA Agrte

Cedric Cromwell, CHAIRPERSON
Mashpee Wampanoag Tribal Council

TTEST:

.

Marie A. Stone, SECRETARY
Mashpee Wampanoag Tribal Council
Notary Public, Commission Expires 4-15-2016

CERTIFICATION OF POSTING
This is to certify that the Ordinance titled 2012-ORD-004, “MASHPEE WAMPANOAG FIRST
AMENDMENT TO TRIBAL GAMING AUTHORITY ORDINANCE,” has been posted in
accordance with 2009-ORD-003, Regulating Adoption, Amendment or Repeal of Ordinances
and Resolutions, and 2009-ORD-007, Meetings of the Tribal Council.

DATED this 4" day of June, 2012

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Cedric Cromwell, Chairperson a ‘SF
Mashpee Wampanoag Tribe Lx aS
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Marie A. Stone, Secretary
Mashpee Wampanoag Tribe

483 Great Neck Road South, Mashpee MA 02649 (508) 477-0208 (508) 477-1218 fax


Mashpee Wampanoag Tribe

a) full name, other names used (oral or written), social
security number(s), birth date, place of birth, citizenship, gender, all
languages (spoken or written);

b) currently and for the previous five years: business and
employment positions held, ownership interests in those businesses,
business and residence addresses, and driver’s license numbers;

c) the names and current addresses of at least three personal
references, including one personal reference who was acquainted with the
applicant during each period of residence listed under subsection (1)(b) of
this section;

d) current business and residence telephone numbers;

e) a description of any existing and previous business
relationships with Indian tribes, including ownership interests in those
businesses; :

f). a description and financial disclosure of any existing and

previous business relationships with the gaming industry generally,
including ownership interests in those businesses;

g). the name and address of any licensing or regulatory agency
with which the person has filed an application for a license or permit
related to gaming, whether or not such license or permit was granted;

h) for each felony for which there is an ongoing prosecution
or conviction, the charge, the name and address of the court involved, and
the date and disposition if any;

i) for each misdemeanor conviction or ongoing
misdemeanor prosecution (excluding minor traffic violations), within ten
years of the date of the application, the name and address of the court
involved and the date and disposition;

jp for each criminal charge (excluding minor traffic charges),
whether or not there is a conviction, if such criminal charge is within ten
years of the date of the application and is not otherwise listed pursuant to
subsection C.1(h) and (i) of this section, the criminal charge, the name and
address of the court involved and the date and disposition;

k) the name and address of any licensing or regulatory agency
with which the person has filed an application for an occupational license
or permit, whether or not such license or permit was granted;

483 Great Neck Rd. South, Mashpee, MA 02649 = (508) 477-0208 (508) 477-1218 fax


Mashpee Wampanoag Tribe

Na,
UAL

CERTIFICATION

We, the undersigned duly elected Chairperson and Secretary of the Tribal Council do
hereby certify that the above Resolution was duly adopted by the Mashpee Wampanoag Tribal
Council, which is composed of 13 members, of whom 11 constituting a quorum, were physically
present at a continued meeting thereof, duly held on March 5, 2012, and that the foregoing
Resolution was duly adopted by the affirmative vote of 8 members, with 2 opposing, and with 0
not voting, and that said Resolution has not been rescinded or amended in any way.

Dated this 5" day of March, 2012

Cedric Cromwell, Chairperson and-President
Mashpee Wampanoag Tribal Council

"Wane L Soe.

Marie A. Stone, Secretary, Notary Public
Mashpee Wampanoag Tribal Council

CERTIFICATION OF POSTING

This is to certify that the Ordinance titled 2011-ORD-002, Mashpee Wampanoag Tribal Gaming
Ordinance has been posted in accordance with 2009-ORD-003, Regulating Adoption, Amendment
or Repeal of Ordinances and Resolutions.

DATED this 5" day of March, 2012.

(hd 4, ae” RU

Cedric Cromwell, CHAIRMAN 8 WARIE AN,

‘rues Q Se. Mashpee Wampanoag Tribal Council

Marie A. Stone, SECRETARY
Mashpee Wampanoag Tribal Council

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483 Great Neck Rd. South, Mashpee, MA 02649 — (508) 477-0208 (508) 477-1218 fax


Mashpee Wampanoag Tribe

b) may include copies of the eligibility determination and
investigative report (if any) in the Indian Gaming Individuals Records
System.

F. Retention of applications and reports

With respect to Key Employees and Primary Management Officials, the
Commission shall retain applications for employment and reports (if any) of
background investigations for inspection by the Chairperson of the National
Indian Gaming Commission or his or her delegate for no less than three (3) years
from the date of termination of employment.

G. Granting a Gaming License

1 If, within a 30-day period after the National Indian Gaming
Commission receives a report, the National Indian Gaming Commission notifies
the Commission that it has no objection to the issuance of a license pursuant to a
license application filed by a key employee or a primary management official for
whom the Mashpee Wampanoag Tribe has provided an application and
investigative report to the National Indian Gaming Commission, a license may be
issued to such individual.

2, The Commission shall respond to a request for additional
information from the Chair of the National Indian Gaming Commission
concerning a Key Employee or a Primary Management Official who is the subject
of areport. Such request shall suspend the 30-day period under subsection G.1.
of this section until the Chair of the National Indian Gaming Commission
receives the additional information.

3. If, within the 30 day period described above, the National Indian
Gaming Commission provides the Commission with a statement itemizing
objections to the issuance of a license to a Key Employee or to a Primary
Management Official for whom the Mashpee Wampanoag Tribe has provided an
application and investigative report to the National Indian Gaming Commission,
the Commission shall reconsider the application, taking into account the
objections itemized by the National Indian Gaming Commission. The
Commission shall make the final decision whether to issue a license to such
applicant.

SECTION 604 LICENSE SUSPENSION

A. Tf, after the issuance of a gaming license, the Commissioner
receives information from the National Indian Gaming Commission or other
reliable source indicating that a Key Employee or a Primary Management Official
is not eligible for a license, the Commission shall suspend such license and notify
in writing the licensee and the licensee’s supervisor of the suspension and the
proposed revocation.

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Mashpee Wampanoag Tribe

TRIB
SECTION 602 ISSUANCE OF LICENSES.

The Commission shall issue tribal licenses for Primary Management Officials and Key
Employees and others as the Commission may decide by Regulation who are involved in
gaming.

A. Such licenses shall:

1. not be required until background investigations are complete;

2. be issued when the results of background investigations are available to
the Commission and such reports indicate that the individual is of appropriate character

to participate in a tribal gaming enterprise.

B. Pending completion of background investigations, the Commission may issue a
temporary license for a period not to exceed 90 days.

C. The gaming operation shall not employ as a Key Employee or Primary Management
Official a person who does not have a license after 90 days.

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Mashpee Wampanoag Tribe

TRIBE

SECTION 203 SEVERABILITY AND REPEALER

A. The provisions of this Ordinance are severable, and if any part or provision hereof
shall be held void by appropriate judicial authority, the decision of the court so holding shall not
affect or impair any of the remaining parts of provisions of the Ordinance.

B. All titles, chapters, articles and sections of all gaming regulatory Ordinances
previously enacted are hereby repealed, and all other laws or resolutions or parts of laws and
resolutions inconsistent with the provisions of this Ordinance are hereby repealed.

SECTION 204 SERVICE OF PROCESS AND SOVEREIGN IMMUNITY

The Tribe may be served notice of process for official determinations, order or notice of
violation of the Indian Gaming Regulatory Act by the National Indian Gaming Commission or
other federal entity by service upon the Chairperson with a copy to the Commission.

Any document, affidavit, report, fee or payment required to be delivered to or served upon the
Commission shall be deemed to be properly delivered to or served upon the Commission if
delivered to the Chair of the Commission or its Executive Director in a manner directed by
Commission regulation. Nothing herein shall be deemed to waive or impair the Mashpee
Wampanoag Tribe’s sovereign immunity. Nothing herein shall be deemed a grant of jurisdiction
or venue for any court to review cases or controversies if such court is not otherwise empowered
to review.

483 Great Neck Rd. South, Mashpee, MA 02649 — (508) 477-0208 (508) 477-1218 fax


Mashpee Wampanoag Tribe

2012-ORD-005
FIRST AMENDMENT TO
MASHPEE WAMPANOAG TRIBAL GAMING ORDINANCE
TABLE OF CONTENTS
Section 1. Authority
Section 2. Purpose
Section 3. Amendment of Tribal Gaming Ordinance

Section 4. Effective Date

The Mashpee Wampanoag Tribal Council does ordain as follows:
Section 1. AUTHORITY.

The authority for the Amendment of 2012-ORD-002, captioned “Tribal Gaming Ordinance” is
Article V, Section 2, and Article VI, Section 2, A, B, C, and K of the Constitution of the Mashpee
Wampanoag Tribe and Section 9(a) of 2009-ORD-003.

Section 2. PURPOSE.

The purpose of this Ordinance is to make two technical amendments to the Tribal Gaming
Ordinance in response to comments from legal staff of the National Indian Gaming Commission
coming out of its review of the Ordinance pursuant to the Indian Gaming Regulatory Act.

Section 3. AMENDMENT OF TRIBAL GAMING ORDINANCE.

(a) The first sentence of Section 603 D of the Tribal Gaming Ordinance is hereby amended
to read in its entirety:

“The Commission shall review a person's prior activities, criminal record, if
any, and reputation, habits and associations to make a finding concerning the
eligibility of a key employee or primary management official for granting of
a gaming license.”

(b) Section 603 F of the Tribal Gaming Ordinance is hereby amended by adding the
following sentence:

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Mashpee Wampanoag Tribe

NOW, THEREFORE, BE IT RESOLVED BY THE TRIBAL COUNCIL:

Section 1. Findings. The Tribal Council hereby determines and finds that (a)
the Tribal Council is the duly elected and governing body of the Tribe, with full power and
authority to adopt this Resolution, (b) adoption of this Resolution is in the best interest of the
Tribe and its members; (c) at least seven members of the Tribal Council are in physical
attendance at this Continued Meeting and (d) the Recitals above are true and correct.

Section 2. Approval _and_ Ratification of Tribal _Gamin, rdinance_and
Amendment thereof Pursuant to First Amendment Ordinance. The Tribal Council hereby
approves the First Amendment Ordinance, approves and ratifies the Tribal Gaming Ordinance
as amended by the First Amendment Ordinance, and hereby adopts the First Amendment
Ordinance, and instructs the Secretary to fill-in by appropriate reference the ordinance number
of the First Amendment Ordinance.

Section 3. Recording, Attesting and Certification. The Secretary of the Tribe
is hereby instructed in accordance with 2009-ORD-003, Section 8(g) to properly attest to,
certify and record the adoption of the First Amendment Ordinance in accordance with the laws
and the procedures of the Tribe.

Section 4. Submission to NIGC. The Chairperson of the Tribe is hereby
instructed to cause the First Amendment Ordinance to be promptly submitted to the
Chairwoman of the NIGC with a request that the Final Tribal Gaming Ordinance be approved
by the Chairwoman pursuant to IGRA.

Section 5. Determination. The Tribal Council hereby determines that no law,
ordinances, rules, regulations, resolutions or other actions of the Tribal Council or any of the
agencies or instrumentalities of the Tribe, either written or established by custom or tradition:
(a) prohibit the members of the Tribal Council from taking the actions herein set forth, or the
consummation of the transactions contemplated therein or (b) create any obligation of the
Tribal Council to submit these matters for approval by or consent from any officer, body,
agency or instrumentality of the Tribe, or any vote by members of the Tribe, except for such
approvals and consents that have already been obtained and are in full force and effect.

Section 5. Miscellaneous. (a) If any provision of this Resolution or the
application of any provision of this Resolution is held to be invalid, the remainder of this
Resolution shall not be affected with respect to the same.

(b) This Resolution and the actions taken hereby shall become
effective as of the date and time of its passage and approval by seven members of the
Tribal Council in physical attendance at this Continued Meeting.

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Mashpee Wampanoag Tribe

TRIBE

SECTION 102 BASIS FOR AUTHORITY

The authority for the Tribal Gaming Ordinance is Article V, Section 2, and Article VI,
Section 2, A, B, C, and K of the Constitution of the Mashpee Wampanoag Tribe and the
approval of the Tribal Council.
SECTION 103 DEFINITIONS

A. For the purpose of this Ordinance:

1. "Chairperson" means the Chairperson of the Tribal Council, as created by
Articles VI and VII of the Constitution of the Mashpee Wampanoag Tribe;

2. "Commission" means the Mashpee Wampanoag Tribal Gaming
Commission, as provided by this Tribal Ordinance;

3. "Constitution" means that document which formally established the
government of the Mashpee Wampanoag Tribe, as ratified by the eligible registered
voters of the Mashpee Wampanoag Tribe on June 26, 2004;

4. "Gaming" shall have the same meanings as applied by and contained in
the Indian Gaming Regulatory Act, Public Law 100-447, 25 U.S.C. §§ 2501 et seq.;

5. “Gaming Authority” means that agency of the Tribe charged with
oversight of the Tribal Gaming business operation.

6. “Key Employee” means:
i. A person who performs one or more of the following
functions:
a. Bingo caller;
b. Counting room supervisor;
c. Chief of security;
d. Custodian of gaming supplies or cash;
e. Floor manager;

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Mashpee Wampanoag Tribe

ARTICLE I
GENERAL PROVISIONS

Section 101 Findings
Section 102 Basis for authority
Section 103 Definitions

SECTION 101 FINDINGS
A. The Mashpee Wampanoag Tribal Council finds that:

i the Mashpee Wampanoag Tribe must promote the public health and
safety, education and welfare that may contribute to the social, physical well-being and
economic advancement of citizens of the Mashpee Wampanoag Tribe;

2. the Mashpee Wampanoag Tribe must create authorities with attendant
powers to achieve objectives allowed under the provisions of the Constitution of the
Mashpee Wampanoag Tribe;

3. the Mashpee Wampanoag Tribe must provide for the employment,
education, training, health, and other services which are not now being met in sufficient
quantity by federal government agencies;

4. the Mashpee Wampanoag Tribe must maintain its self-determination in its
governmental programs;

5. the Tribe must provide a system for regulating gaming activities in and for
the Mashpee Wampanoag Tribe, which is in the best interests of the Mashpee people and
their health and welfare;

6. Mashpee Wampanoag Tribe must generate revenues to support essential
governmental services;

7. the Mashpee Wampanoag Tribe must comply with the provisions of the
Indian Gaming Regulatory Act, as adopted by the Congress of the United States of
America, 25 U.S.C. §§ 2701, et seq. (the “IGRA”) for the conduct of gaming on tribal
lands.

B. Be it enacted by the Mashpee Wampanoag Tribal Council, that this Ordinance
shall be cited as the "Mashpee Wampanoag Tribal Gaming Ordinance."

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Mashpee Wampanoag Tribe

TRIBE

D. Ifa license is not issued to an applicant, the Commission:
1. shall notify the National Indian Gaming Commission; and
2. may forward copies of its eligibility determination and investigative report (if

any) to the National Indian Gaming Commission for inclusion in the Indian
Gaming Individuals Records System.

SECTION 603 APPROPRIATE INVESTIGATION REQUIRED

A. The Commission shall require an appropriate investigation of Key Employees and
Primary Management Officials. An appropriate investigation shall include as a minimum:
1. obtaining and processing fingerprints;
2. establishing the fitness of individual to perform job as set forth in job
description and basis for individual selection for position;
3. performing a credit check;
4, verifying his or her resume;
5. checking the character of the applicant regarding prior activities, criminal

record, reputation, habits and associations, including but not limited to personal
interview summaries with a sufficient number of knowledgeable people such as
former employees, personal references and others to form a basis for character
suitability determination;

6. documenting all potential problems and possible disqualification
information.

B. Application Forms
i. The following notice shall be placed on the application form for a key

employee or a primary management official before that form is filled out by an
applicant:

483 Great Neck Rd. South, Mashpee, MA 02649 — (508) 477-0208 (508) 477-1218 fax


Mashpee Wampanoag Tribe

b. to set up working policy for the gaming operation;
or

c. the chief financial officer or other person who has
financial management responsibility.

3: any other person designated by the Commission as a Primary
Management Official.

11. “Tribal Council" means the Mashpee Wampanoag Tribal Council which is that
body of not more than 13 members, as created by Articles V, VI, VII, VIII and IX of the
Constitution of the Mashpee Wampanoag Tribe;

12. "shall" means imposing an obligation to act;

ARTICLE II
PROCEDURAL AND REPEALER PROVISIONS

Section 201 Ordinance to effect purposes

Section 202 Headings

Section 203 Severability and repealer

Section 204 Service of process and sovereign immunity

SECTION 201 ORDINANCE TO EFFECT PURPOSES

The provisions of this Ordinance, being necessary for the welfare of the Mashpee
Wampanoag Tribe and its Citizens, shall be liberally construed to effect the purpose and object
hereof.

SECTION 202 HEADINGS
The article and section headings contained herein shall not be deemed to govern, limit,

modify or in any manner affect the scope, meaning or intent of the provisions of any article or
section hereof.

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Mashpee Wampanoag Tribe

TRIB

B. The Commission shall review any background check report issued to the
Tribe. The Commission may share any information revealed by such checks to the
manager of gaming facilities which, in the Commission's judgment, affects the
consideration of an individual for employment.

Cc, The Commission shall use the results of any background check to perform
the lawful duties of Commission.

SECTION 607 FACILITY LICENSES

The Commission shall issue a separate license to each place, facility, or location on
Indian lands where gaming is conducted under this ordinance.

ARTICLE VII
GAMING DISPUTES WITH MANAGEMENT

Section 701 Filing complaints

Section 702 Hearing date

Section 703 Hearing notice required

Section 704 Legal counsel authorized

Section 705 — Arbitration or mediation authorized

SECTION 701 FILING COMPLAINTS

Any gaming participant or supplier may file a complaints arising out of operation of the
gaming facility against management with the Commission. The Commission shall establish a
time for hearing, give notice to all parties, hold hearing(s) and rule upon the complaint. This
section shall in no way be construed as a waiver of the sovereign immunity of the Mashpee
Wampanoag Tribe.

SECTION 702 HEARING DATE.

The Commission shall set a date for hearing the complaint within ninety (90) days of the
filing of the same.

SECTION 703 HEARING NOTICE REQUIRED.

The Commission shall give notice of such hearing together with a copy of the complaint
to the Chairperson and to the manager and management of the gaming enterprise facility
involved in the complaint and give notice of the hearing to the person filing the complaint by
electronic communication as well as by regular mail posted not less than ten (10)days in advance
of the hearing.

483 Great Neck Rd. South, Mashpee, MA 02649 — (508) 477-0208 (508) 477-1218 fax


June 5, 2012

Honorable Cedric Cromwell
Chairperson and President
Mashpee Wampanoag Tribe
483 Great Neck Road South
Mashpee, MA 02649

Re: Mashpee Wampanoag Tribe Class II and III Gaming Ordinance
Dear Chairperson Cromwell:

This letter is in response to your request to review and approve the amended
Mashpee Wampanoag Tribe Class II and III Gaming Ordinance. The Ordinance was
enacted on March 5, 2012, by the Mashpee Wampanoag Tribal Council Resolution 2012-
RES-021. On June 4, 2012, the Tribal Council amended two sections of the Ordinance to
bring it into full compliance with the Indian Gaming Regulatory Act (IGRA).

The Ordinance as amended is consistent with the requirements of the Indian
Gaming Regulatory Act and the NIGC’s implementing regulations and accordingly, is
approved. As required by § 301 of the Ordinance, any Class III gaming must be must be
conducted pursuant to a gaming compact entered into with the Commonwealth of
Massachusetts, or pursuant to Class III gaming procedures approved by the Secretary of
the Interior. It is also my understanding that the Tribe has not yet acquired Indian lands as
defined by IGRA. It is therefore important to note that approval is granted for gaming
only on Indian lands, as defined in IGRA, over which the Tribe has jurisdiction.

If you have any questions or require further assistance, please contact NIGC
Senior Attorney Michael Hoenig at (202) 632-0049.

Sincerely,

Tracie L. Stevens
Chairwoman

NATIONAL HEADQUARTERS 1441 L St. NW, Suite 9100, Washington, DC 20005 Tel: 202.632.7003 Fax: 202.632.7066 + WWW.NIGC.Gov

REGIONAL OFFICES Portland, OR; Sacramento, CA; Phoenix, AZ; St. Paul, MN; Tulsa, OK


Mashpee Wampanoag Tribe

ARTICLE IV
GAMING COMMISSION

Section 401 Gaming Commission office created
Section 402 Appointment

Section 403 Interim Commissioner

Section 404 Continuation of Term

Section 405 Removal for Cause

Section 406 Background investigation required
Section 407 Power and authority

SECTION 401 GAMING COMMISSION OFFICE CREATED

The Mashpee Wampanoag Tribal Gaming Commission is hereby created under the
authority of the Tribal Council. As determined by the Tribal Council, the Commission shall
consist of up to five Commissioners, who shall each take an oath of office similar to that of
elected officials and shall be sworn to service. A Commissioner shall serve a term of three years
from the date of such oath of office.

SECTION 402 APPOINTMENT

Upon the initial establishment of the Commission, and thereafter, at any time when a vacancy
occurs in the office of Commissioner, so that no Commissioner is available to serve, the office
shall be filled by appointment by the Chairperson, by and with the approval of the Tribal
Council.

A. The Chairperson shall, within 60 days of any vacancy, nominate an appointee to
fill the position and shall so notify the Council. Once that notification is
made or before, the Chairperson shall cause the process to be initiated to clear
that person as Commissioner through the requirements and provisions
contained in this Ordinance.

B. The Chairperson or his designee shall cause the required background
investigation to be conducted.

C. Should the nominee clear the required background check and investigations,
the appointment shall be presented for the approval of the Tribal Council to
serve as Commissioner.

D. If the nominee does not clear the background checks or is not approved by the
Tribal Council, the Chairperson shall, within 60 days, submit the name of
another candidate to be considered. Each nominee must undergo the same
process. This procedure shall be continued until a person is nominated,
cleared, and the Tribal Council approves the appointment.

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Mashpee Wampanoag Tribe

ARTICLE III
MISCELLANEOUS PROVISIONS

Section 301 Class I and Class III gaming authorized
Section 302 Ownership of gaming

Section 303 Use of gaming revenue

Section 304 Audit

Section 305 Protection of environment and public safety

SECTION 301 CLASS IL AND CLASS Ii] GAMING AUTHORIZED

Class II gaming as defined in the Indian Gaming Regulatory Act, Public Law 100-447,
25 USC § 2703(7) is hereby authorized. Class III gaming as defined in the Indian Gaming
Regulatory Act, Public Law 100-447, 25 USC §2703(8), is authorized only to the extent allowed
by such law and pursuant to an approved tribal/state compact.

SECTION 302 OWNERSHIP OF GAMING

The Mashpee Wampanoag Tribe shall have the sole proprietary interest in and
responsibility for the conduct of any gaming operation authorized by this Act.

SECTION 303 USE OF GAMING REVENUE

Net revenues from gaming shall be used only for the following purposes: To fund tribal
government operations and programs; to provide for the general welfare of the Mashpee
Wampanoag Tribe and its citizens; to promote tribal economic development; to donate to
charitable organizations; or to help fund operations of local government agencies, and for such
other purposes as allowed by IGRA and authorized by the Tribal Council.

SECTION 304 AUDIT

A. The Chairperson shall cause to be conducted annually an independent audit of
gaming operations and shall submit the resulting audit reports to the National Indian Gaming
Commission.

B. All gaming related contracts which result in the purchase of supplies, services or
concessions in excess of $25,000.00 annually, except contracts for professional, legal and
accounting services, shall be specifically included within the scope of the audit which is
described in subsection (a) of this section.

SECTION 305 PROTECTION OF ENVIRONMENT AND PUBLIC SAFETY

All gaming facilities shall be constructed, maintained and operated in a manner that
adequately protects the environment and the public health and safety.

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Mashpee Wampanoag Tribe

CERTIFICATION

We, the undersigned Chairperson and Secretary of the Mashpee Wampanoag Tribal Council do
hereby certify that the Tribal Council is composed of 13 members of whom 9, constituting a
quorum, were present at a meeting thereof, duly and regularly called, noticed, convened, and
held on the 4" day of June, 2012, and that the foregoing Resolution was duly adopted by the
affirmative vote of 7 members, with 1 opposing, and with 0 not voting.

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DATED this 4" day of June, 2012 fy z A
Cedric Cromwell, CHAIRPERSON

Mashpee Wampanoag Tribal Council
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Mashpee Wampanoag Tribe

(c) To the extent lawful, all resolutions or actions of the Tribal
Council heretofore taken, other than with respect to the enactment of Ordinances, are
hereby modified to the extent required to be consistent with the provisions of this
Resolution.

(Remainder of Page Intentionally Blank)

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Mashpee Wampanoag Tribe

f. Pit boss;
Dealer;
Croupier;
i. Approver of credit; or

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

ie If not otherwise included, any other person whose total
cash compensation is in excess of $50,000 per year;

3. If not otherwise included, the four most highly
compensated persons in the gaming operation; and

4. Any member or employee of the Mashpee Wampanoag
Tribal Gaming Commission.

Ds Any other person designated by the Commission as a Key
Employee.

Ts "License" means the written permission by authority of the Mashpee
Wampanoag Tribe to do an act or fulfill, which without permission would be illegal, and
is a document granted by the Commission of the Mashpee Wampanoag Tribe for a
consideration to a person or to a location to pursue business subject to regulation under
the jurisdiction of the Mashpee Wampanoag Tribe;

8. “Licensee” means one who has applied for and obtained a License in
accord with rules of the Commission;

9. "The Mashpee Wampanoag Tribe" means the government instituted in the
Constitution of the Mashpee Wampanoag Tribe.

10. “Primary Management Official” means:

1. The person having management responsibility for a
management contract, including but not limited to, officers, directors and
persons having five (5) percent or greater financial interest in the entity
that holds a management contract;

2. any person who has authority:

a. to hire and fire employees; or

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Mashpee Wampanoag Tribe

iD) a current photograph with notarized affidavit as to date
taken and person depicted;

m) any other information the Commission deems relevant; and

n) fingerprints consistent with procedures adopted by the
Mashpee Wampanoag Tribe according to 25 C.F.R. § 522.2(h).

2. The Commission shall conduct an investigation sufficient to make
an eligibility determination under subsection D, below. In conducting a
background investigation, the identity of each person interviewed in the course of
the investigation shall be kept confidential.

D. Eligibility determination
The Commission shall review a person's prior activities, criminal record, if any,
and reputation, habits and associations to make a finding concerning the eligibility of
a key employee or primary management official for employment in a gaming
operation. If it is determined that employment of the person poses a threat to the
public interest or to the effective regulation of gaming, or creates or enhances dangers
of unsuitable, unfair or illegal practices and methods and activities in the conduct of
gaming, the Commission shall not license and a tribal gaming operation shall not
employ that person.
E. Report to the National Indian Gaming Commission
1. The Commission shall prepare and forward to the National Indian
Gaming Commission, within 60 days after the employee begins work, an
investigative report on each background investigation. An investigative report
shall include all of the following:
a) steps taken in conducting a background investigation;
b) results obtained;
c) conclusions reached; and
d) the bases for those conclusions.

2. With the report shall be submitted a copy of the eligibility
determination made under this section.

3. If a license is not issued to an applicant, the Commission:

a) shall notify the National Indian Gaming Commission; and

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Mashpee Wampanoag Tribe

2012-RES-056

APPROVING AMENDMENT TO TRIBAL GAMING
ORDINANCE AND SUBMISSION OF SUCH AMENDMENT TO
NATIONAL INDIAN GAMING COMMISSION FOR APPROVAL

WHEREAS, This is a meeting of the Tribal Council, the governing body of the Mashpee
Wampanoag Tribe (the “Tribe”), that is open to tribal members, spouses and
invited guests of the Tribal Council in accordance with Section 4(b) of 2009-
ORD-007 (the “Meeting Ordinance”); and

WHEREAS, This meeting (this “Continued Meeting”) is a continuation of a regular meeting of
the Tribal Council, duly called, convened and held on April 11, 2012 (the “Initial
Meeting”), that was duly continued successively to April 18, 2012, May 2, 2012
May 16, 2012, May 21, 2012 and May 30, 2012 (each, continuation a “Previous

Continued Meeting”); and

WHEREAS, A quorum was physically present and acting throughout the Initial Meeting, and
each Previous Continued Meeting in compliance with the Tribe’s Constitution and
By-Laws approved by the members of the Tribe on June 26, 2004, and certified
by the members of the Tribal Council of the Tribe on June 28, 2004 (the
“Constitution”) and the Meeting Ordinance; and

WHEREAS, Notice of the time, date and location of this Continued Meeting and each Previous
Continued Meeting was publicly announced at the Initial Meeting or a preceding
Previous Continued Meeting; and

WHEREAS, Article VI of the Constitution establishes a Tribal Council of the Tribe as the
governing body of the Tribe, composed of thirteen voting members of the Tribe,
including a Chairperson, a Vice-Chairperson, a Secretary, and a Treasurer, and
Article V, Section 2 of the Constitution provides that the Tribal Council shall be
vested with all executive and legislative powers of the Tribe; and

WHEREAS, Article VI, Section 2(C) of the Constitution authorizes the Tribal Council to
establish procedures and ordinances for the conduct of all tribal government
business; and

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Mashpee Wampanoag Tribe

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Up
MASHPEE WAMPANOAG TRIBE
2012-ORD-002

TRIBAL GAMING ORDINANCE

ARTICLEI
GENERAL PROVISIONS
Section 101 Findings
Section 102 Basis for authority
Section 103 Definitions
ARTICLE I

PROCEDURAL AND REPEALER PROVISIONS

Section 201 Ordinance to effect purposes

Section 202 Headings

Section 203 Severability and repealer

Section 204 Service of process and sovereign immunity

ARTICLE II
MISCELLANEOUS PROVISIONS

Section 301 — Class II and Class III gaming authorized
Section 302 Ownership of gaming

Section 303 Use of gaming revenue

Section 304 Audit

Section 305 Protection of environment and public safety

ARTICLE IV
GAMING COMMISSION

Section 401 Gaming Commission office created
Section 402 Appointment

Section 403 Interim Commissioner

Section 404 Continuation of Term

Section 405 Removal for Cause

Section 406 Background investigation required
Section 407 Power and authority

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Mashpee Wampanoag Tribe

B. Notice shall be deemed made to Key Employees and Primary Management
Officials by posting such notice in the gaming facility, the Gaming Commission Office(s), and
the Tribal Office and by hand delivery and/or electronic communication to the Tribal Council,
Chairperson and his designees and individually to such Key Employees and Primary
Management Officials as the Commission deems appropriate.

SECTION 502 COPIES OF REGULATIONS TO BE AVAILABLE

A. A copy of all adopted regulations shall be maintained at the Tribal Office,
Gaming Commission office(s), and at each gaming facility.

B. Copies will be available to the public for copy at a per-page rate set by the
Commission.

SECTION 503 SUSPENSION AND HEARING REGULATIONS

The Commission shall have the right to suspend any license location, licensee, employee
or gaming participant for violation of any tribal regulations, tribal compact, tribal ordinances,
federal regulations or federal laws. Suspension shall be for a period of not more than ninety (90)
days for licensees and not more than two (2) years for gaming participants and others. Prior to
any such suspension the person reviewed shall:

A. Be given notice of specific facts concerning the violation alleged. Such
allegation shall describe in writing the offense and be given ten (10) days prior to any
hearing.

B. Such notice of proceedings shall be accomplished by regular mail to the

last known address and by publicly posting the same within the affected gaming
enterprise facility. Service by mail is not necessary if the Commission has no address for
the person or entity.

Cc. At the hearing, the Commission shall state its understanding of the facts
and allow the person or entity subject to the hearing the opportunity to be heard and to
present evidence.

Dz. At the hearing the subject shall show cause that specific facts alleged are
inaccurate or that special conditions exist which should mitigate suspension.

E. Following the hearing, the Commission shall issue in writing an order
regarding the subject within seven (7) days, or the matter shall be deemed dismissed. If a
suspension order is made, it shall state:

1. The specific violation of law or regulation of the subject, and

2. the suspension period imposed, stating beginning date and
concluding date of suspension.

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Mashpee Wampanoag Tribe

TRIBE

B. The Commission shall develop and implement procedures for others to be excluded
from the gaming facility which may include, but is not limited to, persons whose
licenses were suspended or revoked by other gaming enterprises, known felons or
members of organized crime and their associates who pose a threat to the integrity of
the gaming enterprise, problem gamblers who have requested to be placed on the list
of those to be excluded and such other persons as the Commission determines, in its
discretion, pose a threat to the integrity of the gaming enterprise.

C. Exclusions may be issued for one (1) year, five (5) years, or for life by the
Commission. Upon proper application, exclusions may be lifted.

SECTION 506 INFORMANT IDENTITY PROTECTED

Absent compulsion by a court of competent jurisdiction, the Commission may refuse to
reveal the identity of any informant.

SECTION 507 DEPOSITIONS AUTHORIZED

The Commission shall have authority upon three (3) days written notice to depose any
licensee, tribal employee or gaming participant or patron.

SECTION 508 GAMING COMMISSION ATTORNEY

The Commissioner shall have the authority to hire attorney(s) to advise the Commission,
subject to annual budgetary funding approved by the Tribal Council.

ARTICLE VI
LICENSING

Section 601 License regulation

Section 602 Issuance of licenses

Section 603 Appropriate investigation required
Section 604 License suspension

Section 605 _ Fingerprints on file

Section 606 Criminal background checks
Section 607 Facility Licenses

SECTION 601 LICENSE REGULATION

The Commission shall ensure that the policies and procedures set out in this section are
implemented with respect to Key Employees and Primary Management Officials employed at
any gaming facility located on tribal lands.

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Mashpee Wampanoag Tribe

CERTIFICATION

We, the undersigned duly elected Chairperson and Secretary of the Tribal Council do
hereby certify that the above Resolution was duly adopted by the Mashpee Wampanoag Tribal
Council, which is composed of 13 members, of whom 11 constituting a quorum, were physically
present at a continued meeting thereof, duly held on March 5, 2012, and that the foregoing
Resolution was duly adopted by the affirmative vote of 8 members, with 2 opposing, and with 0
not voting, and that said Resolution has not been rescinded or amended in any way.

Dated this 5" day of March, 2012

Cedric Cromwell, Chairperson and President
Mashpee Wampanoag Tribal Council

ATTEST:

Dre. Store

Marie A. Stone, Secretary, Notary Public
Mashpee Wampanoag Tribal Council

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Mashpee Wampanoag Tribe

SECTION 704 LEGAL COUNSEL AUTHORIZED.

Ata hearing on any complaint, the person filing the same, manager and management
shall be entitled to legal counsel. The person filing the complaint must be present for hearing of
the same and shall be responsible to present a prima facie case for relief before response by the
manager is required. The Commission shall be free to question any person present, continue the
hearing from time to time and conduct independent investigation of facts. Upon conclusion of
the hearing, the Commission shall have forty-five (45) days to issue a written opinion or extend
the time for the issuance of such opinion with the agreement of the person filing the complaint.
In the absence of a written opinion by the Commission within the time specified, the matter shall
be deemed dismissed.

SECTION 705 ARBITRATION OR MEDIATION AUTHORIZED.
The Commission shall at any time prior to decision of any complaint, have the authority

to suspend proceedings and to direct arbitration or mediation of the complaint under such terms
as the Commission may direct.

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Mashpee Wampanoag Tribe

Mp _.
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2012-RES-021 we

RESOLUTION TO APPROVE THE MASHPEE WAMPANOAG
TRIBAL CLASS II AND CLASS III GAMING ORDINANCE

WHEREAS, the Mashpee Wampanoag Tribe (the “Tribe”) is a federally-recognized Indian tribe
with a duly-enacted Constitution;

WHEREAS, the governing body of the Tribe is known as the Mashpee Wampanoag Tribal
Council (the “Tribal Council”);

WHEREAS, Article VI, § 2.A. of the Constitution of the Mashpee Wampanoag Tribe (the
“Constitution”), provides that the Tribal Council is empowered to promote and protect the
health, peace, morals, education, political integrity, economic security and general welfare of the
Tribe and its members;

WHEREAS, Article VI, § 2.C. of the Constitution provides that the Tribal Council is
empowered to establish procedures and ordinances for the conduct of Tribal business operations;

WHEREAS, the Tribal Council, in accordance with its powers under Article VI of the
Constitution, finds it in the best interests of the Tribe and its Tribal members to enact an
ordinance to set the terms for Class II and Class III gaming on Tribal lands;

NOW, THEREFORE, BE IT RESOLVED, that the Tribal Council hereby approves the
Mashpee Wampanoag Tribal Class II and Class IIT Gaming Ordinance, attached hereto, and
authorizes the same to be submitted to the National Indian Gaming Commission for approval
pursuant to 25 U.S.C. § 2710.

All resolutions or parts of resolutions inconsistent with this resolution are repealed. This
resolution is effective immediately and shall continue pursuant to the authority vested in the
Tribal Council pursuant to Article VI, §§ 2.A. and C. of the Constitution.

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Mashpee Wampanoag Tribe

“When a Key Employee or a Primary Management Official begins work at
the gaming operation, there shall be forwarded to the Commission a
completed application for employment that contains the notices and
information listed in 25 CFR §§$556.2, 556.3 and 556.4.”

Section 4. EFFECTIVE DATE.

This ordinance shall take effect immediately and be enforced from and after its passage in
accordance with the Constitution and laws of the Tribe.

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ao Mashpee Wampanoag Tribe

Lehios

TRIBE

WHEREAS Article VI, Section 2 (K) of the Constitution authorizes the Tribal Council to
create or provide by ordinance for “organizations” for any lawful purpose and to
regulate the activities of such organizations by ordinance; and

WHEREAS, Article IX, Section 1(e)(1) of the Constitution authorizes the Tribal Council to
adopt ordinances of the Tribe at a regular meeting, which ordinances shall,
together with the Constitution, constitute the supreme law of the Tribe under
Article V, Section 2 of the Constitution; and

WHEREAS, On March 12, 2012, the Tribal Council duly adopted as the law of the Tribe,
2012-ORD-002, captioned “Tribal Gaming Ordinance;” in accordance with all
laws of the Tribe and the Constitution; and

WHEREAS, The Tribal Gaming Ordinance was submitted to the Chairwoman of the National
Indian Gaming Commission (“NIGC”) for approval thereof pursuant to the Indian
Gaming Regulatory Act of 1988, as amended (“IGRA”);

WHEREAS, Legal staff of the NIGC has requested certain technical amendments to the Tribal
Gaming Ordinance to comply with IGRA and regulations thereunder; and

WHEREAS, On May 23, 2012, the Tribal Council considered and approved posting of a
proposed ordinance that would amend the Tribal Gaming Ordinance to implement
the requested technical amendments (the “First Amendment Ordinance”); and

WHEREAS, On May 25, 2012, in accordance with 2009-ORD-003, Section 6(b) and 2009-
ORD-007, Section 8, the First Amendment Ordinance was posted on the website
of the Tribe and at the offices of the Tribe, together with a synopsis thereof (the
“Posting”); and

WHEREAS, At least 12 days have passed since the date of the Posting as required by 2009-
ORD-003, Section 6(b);

WHEREAS, The First Amendment Ordinance has been deliberated on by the Tribal Council;
and

WHEREAS, The Tribal Council desires to amend the Tribal Gaming Commission by adopting
as a law of the Tribe the First Amendment Ordinance, and to submit the First
Amendment Ordinance requesting that the Chairwoman of the NIGC the Tribal
Gaming Ordinance, as amended by the First Amendment Ordinance (the

“Amended Tribal Gaming Ordinance”);

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Mashpee Wampanoag Tribe

E. If the Tribal Council determines to fill additional Commissioner positions
beyond a single Commissioner, additional Commission appointments shall be
made by appointment by the Chairperson with the approval of the Tribal
Council, and following the same background and clearance requirements.

SECTION 403 INTERIM COMMISSIONER

An interim Commissioner may be selected by the Chairperson if no Commissioner is
serving. Such an interim gaming commissioner shall fill the position until the Council acts to
approve the appointment of a person to fill the Commissioner's position. An interim
Commissioner shall serve at the pleasure of the Chairperson.

SECTION 404 CONTINUATION OF TERM

Absent objection by the Tribal Council, a Commissioner may serve after the expiration
of his term of office, absent resignation, removal, replacement or reappointment.

SECTION 405 REMOVAL FOR CAUSE

A Commissioner may be removed from office by the Tribal Council prior to the end of
any term for neglect of duty, or malfeasance in office, or for other good cause shown.

SECTION 406 BACKGROUND INVESTIGATION REQUIRED

Prior to the Tribal Council approval of an appointment of a Commissioner, such person
shall have passed a background investigation, examination and check of the same nature as any
other Key Employee of a gaming enterprise pursuant to this Ordinance. Nothing in this section
shall prohibit such person from serving as interim Commissioner for 90 days pending the
outcome of Key Employee review. The Commissioners or Commission staff who cannot meet
the minimum requirements for licensing under this Act shall not be employed by the Mashpee
Wampanoag Tribe Gaming Commission in such capacity.

SECTION 407 POWER AND AUTHORITY

A. Subject to amendment of this Ordinance by the Tribal Council, the Commission
shall have the authority and responsibility to assure that this Ordinance is followed and may
exercise any proper power and authority necessary to perform the duties of the office. The
Commission shall issue regulations which shall include but not be limited to:

1. develop and implement forms for background checks and employee

applications;
2. develop and implement procedures for conducting background checks;
3. develop and implement procedures for issuance of tribal licenses to

Primary Management Officials and Key Employees;

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Mashpee Wampanoag Tribe

F. Notice of order shall be accomplished in the same manner as notice of
proceedings.

SECTION 504 REVOCATION REGULATIONS
The Commission shall have the right to revoke any license location, licensee, employee or

gaming participant for violation of any tribal regulations, tribal compact, tribal ordinances,
federal regulations or federal laws. Prior to any such revocation the person reviewed shall:

A. Be given notice of specific facts concerning the violation alleged. Such
allegation shall describe in writing the offense and be given ten (10) days prior to any
hearing.

B. Such notice of proceedings shall be accomplished by regular mail to the

last known address and by publicly posting the same within the affected gaming
enterprise facility. Service by mail is not necessary if the Commission has no address for
the person or entity.

Cc. At the hearing, the Commission shall state its understanding of the facts
and allow the person or entity subject to the hearing the opportunity to be heard and to
present evidence.

Dz. At the hearing the subject shall show cause that specific facts alleged are
inaccurate or that special conditions exist which should mitigate revocation.

E. Following the hearing, the Commission shall issue in writing an order
regarding the subject within seven (7) days, or the matter shall be deemed dismissed. If a
revocation order is made, it shall state:

1. The specific violation of law or regulation of the subject, and

2. the revocation period imposed, stating beginning date and
concluding date of revocation.

F. Notice of order shall be accomplished in the same manner as notice of
proceedings.

SECTION 505 EXCLUSION

A. All persons or entities subject to a suspension or revocation order shall be excluded
from the gaming facility during the suspension or revocation and preceding the
hearing establishing such suspension or revocation. The Commission shall have
authority to direct enforcement of the exclusion of any person suspended or revoked
under the terms of sections 503 and 504 immediately.

483 Great Neck Rd. South, Mashpee, MA 02649 — (508) 477-0208 (508) 477-1218 fax