.; 

SEP 7 I999 

Gary J. Montana, Tribal Attorney 

Ho-Chunk Nation 

W98 14 Airport Road 

P.O. Box 667 

Black River Falls, WI 546 15 

Dear Mr. Montana: 

This letter responds to your request of June 1, 1999, as modified by your letter of July 6, 1999, to 

review amendments to the Ho-Chunk Nation's Amended and Restated Gaming Ordinance, 

adopted by Resolution No. 5-1 1-99L, and amendments to the Nation's Internal Control Manual 

which were adopted by Resolution No. 5-1 1-99M. As to the amendments to the Nation's 

Amended and Restated Gaming Ordinance, this letter constitutes approval of those amendments 

under the Indian Gaming Regulatory Act (IGRA). 

Although NIGC regulations require that all tribal gaming operations adopt internal control 

systems which are at least as stringent as the NIGC's Minimum Internal Control Standards, the 

Commission has not established a requirement that tribal internal control'manuals be reviewed and 

approved by the Chairman. 

Thank you for submitting the amendments for review and approval. The NIGC staff and I look 

forward to continuing to work with you and the Ho-Chunk Nation on future gaming issues. 

Sincerely yours, 

Montie R. Deer 

chaikan 

1441 L STREET, N.W. 9TH FLOOR WASHINGTON, D.C. 20005 TEL.: 202-632-7003 FAX: 202-632-7066 
HO-CHUNK NATION LEGISLATURE 

Governing Body of the Ho-Chunk Nation . 

HO-CHUNK NATION LEGISLATURE 

AMENDMENTS TO AMENDED & RESTATED GAMING ORDINANCE 

RESOLUTION 5-1 1-99 L 

WHEREAS, on November 1, 1994, the United States Secretary of Interior approved a new Constitution for the 

Ho-Chunk Nation, formerly known as the Wisconsin Winnebago Nation; and 

WHEREAS, the Legislature of the Ho-Chunk Nation is the duly constituted governing body of the Ho-Chunk 

Nation, organized and established pursuant to the Indian Reorganization Act of 1934, and given 

certain powers pursuant to the Constitution and By-laws of the Ho-Chunk Nation; and 

WHEREAS, Article V, Section 2 (a) and (x) grants power to the Legislature to make laws, including codes, 

ordinances, resolutions and statutes and to enact any other laws, ordinances, resolutions and 

statutes necessary to exercise its legislative power delegated by the General Council pursuant to 

Article 111; and 

WHEREAS, the Ho-Chunk Nation, pursuant to Article I11 of the Constitution of the Ho-Chunk Nation has 

adopted the Ho-Chunk Nation Amended and Restated Gaming Ordinance ("Ordinance"); and 

WHEREAS, there is a need to revise and update said Ordinance. 

NOW, THEREFORE BE IT RESOLVED, that the Ordinance amended on 09/06/96 and any subsequent 

Amendments of said Ordinance is hereby revised to reflect the following Amendment(s) attached hereto as 

Exhibit(s) A, B, C, D, E , F, G, H & I: 

NOW THEREFORE BE IT RESOLVED that the above Amendment(s) A, B, C, D, E, F, G, H & I are to become 

effective immediately upon adoption of this Resolution. 

CERTIFICATION 

I, the undersigned, as Secretary for the Ho-Chunk Nation Legislature, hereby certify that the Legislature of the HoChunk Nation, composed of 11 mcmbers, of whom 10 constituting a quorum were present at a meeting duly called 

and convened and held on the 1lth day of May, 1999, that the foregoing resolution was adopted at said meeting by 

an affirmative vote of 8 members, 0 opposed, and 2 abstaining, pursuant to the authority of Article V, Section 2(a) 

and (x) of the Constitution of the Ho-Chunk Nation approved by the Secretary of the Interior on November 1, 1994, 

and that said resolution has not been rescinded or amended in any way. I further certify that this is a verified copy 

of said resolution. 

~arlenekamroth, ~e~isfaTrGe Secretary 

W9814 Airoort Road 

Executive Offices 11 li i! 

I I (715') 284-9343 

DEPT. OF \ 

--- E' JUSTICE lb: L{L\ I 
AMENDMENT A 

DEFINITIONS: 

Amend Section 209. "Gaming Facilities" means the buildings and associated real property 

within which the Nation conducts Class 11 and Class I11 gaming, but shall not include any 

adjacent or attached non-gaming enterprises such as hotels, retail shops and eating 

establishments. 

Amend Section 230. "Vendors" means any person, corporation, sole proprietorship, partnership 

or any individual, including but not limited to. a merchant. retail dealer, supplier, importer, 

wholesale distributor who tsanstess property, goods or other services by sale to a gaming 

facility, whether gaming or non-gaming related. 

Add Section 231. "Wisconsin Gaming Commission" means the State of Wisconsin Gaming 

Commission its successor. and its authorized officials, agents or representatives. 
AMENDMENT B 

Sec. 104. The regulations and rules set forth in this Ordinance shall govern all gaming operations 

conducted on the Nation's Land. To the extent that the Nation's existing or subsequently adopted 

personnel manuals, policies and procedures are inconsistent with this Ordinance. this Ordinance 

shall supersede such personnel manuals, policies and procedures. 
AMENDMENT C 

Sec. 502. Class I1 names. The Legislature sliall adopt standards of operation and management 

for bingo and other Class I1 games and, pe~iding such adoption. niay impose such interim 

standards as it may determine necessary to protect the integrity of such games. The standards of 

operation and management for Class 11 games shall provide, at a rninin~un~. that: 

(a) No person under the age of 18 shall be permitted to participate in 

any non-charitable Class I1 gaming as a player or contractor, 

provided, that all persons may participate in charitable Class I1 

gaming approved by the Gaming Commission of the Ho-Chunk 

Nation and any person may be employed by any Class I1 gaming 

operation. if at least 16 years of age. 
AMENDMENT D 

Sec. 807. Powers and duties of Commission. The Commission shall be responsible for enforcing 

this Ordinance and shall ensure compliance with this Ordinance, IGRA and the Compact, any 

licenses issued, and any Resolutions of tlie Legislature specifically enforceable by the 

Conimission. In addition to other duties specitically delegarecl to the Conimission in this 

Ordinance, the Commission shall have the following powers and duties: 

(a) The Co~ilmission may recolnmend policies and gi~idelines relating to 

gaming, including any amendments to the Ordinance. to the Legislature. 

(b) The Commission shall monitor all Class 1, Class 11 and Class 111 gaming 

on the Nation's Lands and all monthly reports and annual audits of such 

activities to insure that such activities conforn~ to the provisions of this 

Ordinance, IGRA and the Compact. 

(c) Except as otherwise provided. the Commission shall issue and deny 

gaming licenses in accordance with Chapter 12 of this Ordinance. 

(d) The Comlliission or the Legislature shall refer any apparent violations of 

this Ordinance, IGRA, tlie Compact, or violations of License conditions to 

the Department of'Justice for investigation as provided under Sec. 1803 of 

this Ordinance. 

(e) The Comnlission may refer any apparent violations of the Nation's laws of 

general applicability, such as the Nation's Personnel Policies and 

Procedures and the Nation's Budget Process and Appropriations Act, in 

the Operation of the Nation's Gaming 1-acilities to thc Office of the 

President and Executive Director of Business for their consideration and 

action as they may determine appropriate. 

(0 The Conimission or Legislature may impose penalties for violations of this 

Ordinance. any Order of the Commission, or any License condition in 

accordance with Chapter 18 of this Ordinance. The Commission may 

rejoin or otherwise prevent any violation of this Ordinance, any Order of 

the Commission, any license condition or other laws relating to gamin2 on 

the nation's Lands. 

(g) The Comnlission shall prepare and recommend an annual budget for the 

purpose of allocating fi~nds to tlie Comn~ission for its necessary activities 

and expenses, which must be approved by the Legislature. The 

Commission may in accordance with any approved budget employ such 

staff from time to time as it deems necessary to tilltill its responsibilities 

under this Ordinance. 
(h) The Commission shall use the Department'ol'.lustice as its counsel, or 

such other counsel to wllom the Department of Justice may refer such 

matters. 

(i) The Commission shall have the authority and responsibility to interpret 

this Ordinance and its rules in proceedings beforc it. 

(j) The Comn~ission shall have such other powers as are delegated to it from 

time to time by the Legislature. 

(k) Except as otllerwise provided in this Ordinance or any Management 

Contract, the Co~~in~issio~i sl~all comply with all policies, guidelines, laws, 

resolutions and regulations of the Legislature. 

(k) Nothing in this section shall prevent the Commission from attempting to 

obtain voluntary compliance through warning, conference or any other 

appropriate means. 

Sec. 8 10. Commission Hearings. 

(a) The Commission shall afford an Applicant an opportunity for a 

hearing prior to any final action by the Con~mission denying a 

license application. 

(b) The Conlnlission shall afford a Licensee the opportunity for a 

hearing prior to taking final action resulting in the in~position of 

any penalties which the Cornmission is authorized to impose 

pursuant to this Ordinance or the Conlmission's Rules of Practice 

and Procedure. In the case of a proposed penalty of $250 or less 

which does not involve any suspension or revocation of a license, 

the Commission shall notify the Licensee of the proposed penalty 

and the basis therefore and allow the Licensee the option of paying 

the penalty without a hearing or contesting the basis for imposing 

the penalty at a hearing following a notice to the Commission 

requesting a hearing. 

(c) Notlling ill this section shall limit the Comn~ission's authority _to 

suspend a License sum~l~arily without a hearing pursuant to this 

Ordinance 

(d) The burden of proving kitness and suitability for a License shall be 

on the Applicant. 

(e) Where a person or entity is charged with violation of this 

Ordinance, a decision of the Commission pursuant to this 

Ordinance, a License condition. the Compact, the IGRA or any 

other applicable laws, regulations or agreements concerning the 
'regulation of gaming. i~icluding but 1101 I iniited to any agreement 

relating to gaming with the tlo Cliunlc Nation. the party alleging 

the violation shall carry an initial burden of establishing a prima 

facie case violation. If the Con~mission finds that prima facie case 

has been established, the burden to rebut the charge shall shift to 

the person or entity. 

Sec. 820. Determination bv the Commission 

(a) The Comniission slinll make all deteniiinations ol'iss~les before it by a 

nmjority vote of at least a cli1orum of the Comniissio~i. 

(b) All signific~int derer~ninatio~is made by the Commission shall be 

documented in a written resolution. Significant determinations include the 

grant. denial or cancellation 01- a License. a tinding ol'a violation of the 

Ordinance, the Conlpact, the IGRA, tlie conditions of any license issued 

by tlie Commission. any decision rendered by the Colnmission pursuant to 

this Ordinance, or any other applicable laws, regi~latio~is or agreements 

regulating gaming, including, but not limited to, any agreement with the 

Ho Chunk Nation. and tlie in~position of any sanctions or penalties. 

(c) A copy of any resolution reached pilrsuant to this section shall be served 

upon tlie Applicant or Respondent be registered or certified mail, or may 

be served personally. 

Sec. 82 1. Sanctions If any party or its attorney fails to comply with any 

provision of this Ordinance, the Commission's Rules of Practice and Procedure, the Compact, the 

IGRA, the conditions of any license issued by the Commission or the Legislature, any decision 

by the Commission rendered pursuant to this Ordinance or Resolution of the Legislature, or the 

tribal court or any other applicable laws, regulatiolis or agreements regulating gaming, including, 

but not limited to, any agreement with the 110 Chunk Nation. regardin? any matter, including, 

but not limited to. discovery niatters and tlic thilurc lo appear at a hearing at the scheduled time, 

the Commission, Legislature, or tribal court upon tiiotion or upon its own initiative, may in its 

discretion impose upon such party 01. attorney. or both. appropriate sanctions in regard to the 

failure(s) as are just, including, but not limited to, the following: 

(a) An order prohibiting tlie use of any witness, document or tangible thing 

which should have been disclosed, produced. Exhibited or exchanged -. pursuant this Ordinance, tlie Commission's Rules of' Practice and 

Procedures, or any order of the Cornn~ission; 

(b) An order that designated facts shall be taken as established; 

(c) An order that the disobedient party may not support or oppose designated 

claims or defense; 
(d) An order striking pleadings or parts thereof, or staying further proceedings 

or dismissing the proceeding or any part thereof. or entering a judgement 

by default against the disobedient party; 

(e) A tinding against the disobeclicnt pasty: or 

Any penalty provicled for in cliapter 18 of'tliis Ordinance 

(ii) Trial Court Review of the Record. Upon receiving a petition of 

review which confor~i~s to the requirements of this Section, the 

Commission shall have forty-five (45) days to transmit the record 

of its decision and to respond to the petition. The court shall 

schedule a hearing within thirty (30) days alter receipt of the 

Comniissions record and response to the petition to consider the 

appeal. pThe trial court judge shall preside at the meeting on the 

appeal. The court, in its discretion, may deny the appeal on the 

record and any written statements submitted. or it may grant the 

petition for review. 
AMENDMENT E 

CHAPTER 12. LICENSING PROCEDURES. 

Section 1203. Annlication for License. 

(b) No License shall be issued to any Applicant who has been determined by the 

Legislature or the Commission to be a person whose prior activities. criminal record, if any, or 

reputation, habits and associations pose a threat to the public interest or to the effective 

regulation and control of gaming. or create or enhance the dangers of unsuitable, unfair, or illegal 

practices, methods, or activities in the operation ot'gaming or the carrying on of the business and 

financial arrangements inciden~al thereto. Thc allegcd violation of Nation's law of general 

application not principally enacted to regulate gaming, such as the Nation's Personnel Policies 

and Procedures and the Nation's Buclget Process and Appropriations Act shall not be the basis of 

non-suitability unless such conduct is part of a pattern of consistent disregard for the Nation's 

law. 

Section 1208. Term of License; License Fee. 

(a) Licenses shall be t'os a term ~~'IIIV) years, and shall espise on the anniversary of 

the date of issue. 

Add Section 1208. (b) 

(iv) Every gaming licensee has the responsibility during the term of 

each licensing term to assure that there exists a continued 

disclosure of facts and information relating to his or her suitability 

to hold a gaming license. Failure to disclose pertinent information 

as to suitability, pursuant to Section 1203 (a) (iv) and Chapter 15 

in its entirety on a contin~~ing basis shall be cause for revocation 

or suspension of a gaming license. 
AMENDMENT F 

CHAPTER 13. VENDOR LICENSING. 

Section 130 1. Vendor License. 

(a) Vendors. All vendors. whether classified as gaming or non-gaming shall be 

subject to licensing and registration by the Commission as a condition precedent to conducting 

business with the Ho-Chunk Nation Gaming Facilities. 

(i) Any classitiecl non-gaming vendor, supplier. or general contractor who 

conducts business with the Nation's gaming facilities in an amount equal to or exceeding 

$100,000.00 in any yeas shall register with the Ganiing Comniissiori and pay a bi-annual 

administrative fee ot' $100.00. Non-gaming vendors who conduct business with the 

Nation's gaming facilities in amounts less than $100.000.00 and exceeding $10,000.00 

shall register with the Ganiing Commission and pay a bi-annual administrative fee of 

$50.00. Any classified lion-gallling contract below $10,000.00 in any year shall be 

exempt from any registration and the payment of any bi-annual administrative fees. 

Section 1303. Term of License: License Fees. 

(a) Licenses shall be for a term of two (2) years, and shall expire on the anniversary 

of the date of issue. 

(i) All vendor licenses must be renewed by written notice to the Commission 

by the vendor of their intent to renew said license with the required license fee. 

(ii) Failure to tile a written notice of intent to renew the vendor license, 60 

days prior to the date ol'expiration by a vendor licensee, shall cause the Commission to 

issue a letter of expiration. The letter of expiration shall be sent, certified mail to the last 

known address of the vendor on the bi-annual due date of the license. 

(iii) Failure to renew an existing vendor license may delay subsequent reissuing of a vendor license to sarne vendor by the Commission. 

- 

(b) In order to recover the costs to the Nation of complying with the federal, tribal, 

and state regulatory processes applicable to Class I1 and Class I11 gaming, bi-annual license fees 

shall be imposed upon tlie filing of any application for a gaining vendor license, and upon every 

license renewal thereafter. The amount shall be a set fee of 250.00 per license renewal period. 

However, any actual costs and expenses associated and incurred with additional background and 

suitability investigations shall be assessed tlie vendor as per an actual cost billing. Vendors 

classified under Section(s) 1303 (b)(i)(g) will upon any renewal be assessed the regular fee of 

$50.00. The schedule of fees for initial licensing of gaming vendors shall be as follows: 
(i) Existing vendors and those applying for new licenses sliall be assessed a 

non-refundable license tee based on the amount of busincss with the Nation's gaming 

facilities and those fees will be fill-tlier based on tlie gross dollar amount received from 

the previous fiscal year: 

a. Vendors conducting business with the Nation's gaming facilities in 

an amount equal to or exceeding $1.000,000.00 shall be assessed a flat fee of 

$10,000.00; 

b. Vendors co~iclucting business with the Nation's gaming facilities in 

an amount between 15500.000.00 to $999,999.99 sliall be assessed a flat fee of 

$5,000.00; 

c. Vendors conducting business with the Nation's gaming facilities in 

an amount between $100.000.00 and $499.999.99 sliall be assessed a flat fee of 

$2,500.00; 

d. Vendors conducting business with the Nation's gaming facilities in 

an amount between $50,000.00 and $99,999.99 shall be assessed a flat fee of 

$1,500.00; 

e. Vendors conducting business with the Nation's gaming facilities in 

an amount between $25.000.00 and $49,999.99 sliall bc assessed a flat fee of 

$750.00; 

f. Vendors conducting business with the Nation's gaming facilities in 

an amount between $10.000.00 and $24,999.99 sliall be assessed a flat fee of 

$250.00; 

g. Vendors conducting business with the Nation's gaming facilities in 

an amount less than $10,000.00 shall be assessed a flat fee of $50.00. 

(ii) Classified gaming vendors who have not previously conducted business 

with the Nation's gaming facilities will be assessed a fee according to the aboveindicated fee scale as to the gross dollar a~iiount of the initial proposal of business with 

tlie Nation's gaming facilities. 

- 

(iii) In addition to any non-refi~ndable license fee paid, tlie Ho-Chunk Nation 

Gaming Commission may require a vendor to pay such supplementary investigative fees 

and costs as may be incurred additionally by the Nation with respect to the actual 

background investigation of said vendor. 

(a) The Ho-Chunk Nation Attorney General, and I~isll~er designee, shall 

itemize the supplen~entary investigative fees and costs and submit a billing to the Gaming 

Commission for the purpose of a supplemented billing to the licensee. 
(b) The Gaming Commission will not take any tinal action to approve any 

vendor license application. unless all lice~~sc and investigative fees and costs have been 

paid in full. 
AMENDMENT G 

CHAPTER 15. CONFLICTS OF INTEREST PROHIBITED 

Sec. 1502. Except as provided in secs. 1504. 105, 1506 and 1507, no Primary 

Management Official or employee of the Nation in any of its Gaming Opcsations shall: 

(a) Participate as a player tll~~.in,q 1.1:or.king hours in any Class I1 or Class I11 

games conducted pursuant to this Ordinance, except: 

Sec. 1508. Any elnployee upon separation from employment with any of the Nation's 

gaming facilities shall observe a fifteen (1 5) day cooling off period and shall not be allowed to 

participate in any gaming at the gaming facility from which the employee was released from 

employment during this period of time: provided, further that any out-going gaming 

commissioners, legislators and any surveillance and blackjack employees shall not participate in 

any gaming activity at any gaming facility for a period of thirty (30) days fro111 the date of their 

separation from employment. 
AMENDMENT H 

CHAPTER 17. MISCELLANEOUS PROVISIONS 

Sec. 1701. Right to Exclude Any Person from Premises at Anv Time. Any person 

may be excluded from the Premises at the discretion of tlie General Manager or an appointed 

designee of the General Manager. 

(a) No person under the age of 21 years of age will be allowed to be on any of 

the Ho-Chunk Nation's Class 111 facility gaming tloor at anytime during 

which alcol~olic beverages are being sold or distributed. EXCEPT, those 

agents. employees. or contractors 01' tlie I-lo-Chi~nli Nation who are 

actively engaged in employment duties, or arc performing authorized 

services tbl or on beliall'ol' tlie I-lo-CIiunl< hation (Iormerly known as the 

Wisconsin W innebago Nation). 

(b) No person under of the age of 21 years of age will be allowed to be on 

any of the Ho-Chunk Nation's Class I11 gaming floor at anytime, provided, 

that any person under the age of 2 1 years may pass to and from any of the 

Nation's Class I1 and Class 111 gaming facility hotels, retail shops and 

eating establishments on premises when accompanied by a supervising 

adult. 
AMENDMENT I 

CHAPTER 18. ENFORCEMENT AND PENALTIES FOR VIOLATIONS 

Amend Section 1801 Enforcement. Any person who: 

(e) Fails to observe the Commission's Rules of Procedure and Practice, 

License conditions imposed by the Commission or Legislature, or 

decisions ol'tlie Commission rendered pursuant to this Ordinance. 

Resolutions of the Legislature. or tribal court decisions shall be subject to 

civil penalties as provided in Sec. 1802. 

Amend Section 1803 Investigations. 

(d) No applicant or licensee shall neglect or refuse to produce records or 

evidence or to give information upon written demand by the Department 

of Justice within seven (7) days of receipt of such request. No applicant 

or licensee sliall interfere with any proper and lawful efforts by the 

Department of Justice to obtain such information. Every applicant, 

licensee, and all licensed manufacturers, distributors and vendors shall 

make their business offices. books and records available for inspection by 

the Department of Justice for purposes of conducting its investigation. 

Failure of any person or entity to comply with this Section may result in a 

denial of a license application, cancellation of a license, or the imposition 

of other penalties and sanctions. 
HO-CHUNK NATION LEGISLATURE 

Governing Body of the Ho-Chunk Nation 

HO-CHUNK NATION LEGISLATURE JdN - 7 ;gC& 

NDMENTS TO THE INTERNAL CONTROL MANUAL 

RESOLUTION 5-1 1-99 M 

WHEREAS, on November 1, 1994, the United States Secretary of Interior approved a new Constitution for the 

Ho-Chunk Nation, formerly known as the Wisconsin Winnebago Nation; and 

WHEREAS, the Ho-Chunk Nation ("Nation") is a federally recognized Indian Tribe, 

organized pursuant to the Indian Reorganization Act of 1934; and 

WHEREAS, the Legislature of the Ho-Chunk Nation ("Legislature") is the duly 

constituted governing body of the Ho-Chunk Nation pursuant to the 

C:onstitution of the Nation; and 

WHEREAS, Article V, Section 2 (a) of the Ho-Chunk Nation Constitution ("Constitution") 

authorizes the Legislature to make laws, including codes, ordinances, 

resolutions, and statutes; and 

WHEREAS, Article V, Section 2 (x) of the Constitution authorizes the Legislature to enact any other laws, 

ordinances, resolutions, and statutes necessary to exercise its legislative powers; and 

WHEREAS, under Section 503 of the Nation's Amended and Restated Gaming Ordinance the Legislature is to 

approve of Standards of Operation and Management for the Nation's Class 111 Gaming Facilities; 

and 

WHEREAS, on January 14, 1997 the Nation's Legislature approved an Internal Controls Manual for the 

Nation's Class 111 Gaming Facilities; and 

WHEREAS, the Legislature desires to make the amendments to the Internal Control Manual indicated in the 

attached pages. 

NOW, THEREFORE, BE IT RESOLVED that the amendments to the Internal Controls manual indicated on the 

attached pages: A-27, A-29, C-8, C-12, C-49, D-5, D-24, E-6, E-8 and 1-4, are hereby adopted and approved. 

CERTIFICATION 

1, the undersigned, as Secretary for the Ho-Chunk Nation Legislature, hereby certify that the Legislature of the HoChunk Nation, composed of 11 members, of whom 10 constituting a quorum were present at a meeting duly called 

and convened and held on the 11'~ day of May, 1999, that the foregoing resolution was adopted at said meeting by 

affirmative vote of 10 members, 0 opposed, and 0 abstaining, pursuant to the authority of Article V, Section 2(a) 

and (x) of the Constitution of the Ho-Chunk Nation approved by the Secretary of the Interior on November 1, 1994, 

and that said resolution has not been rescinded or amended in any way. I further certify that this is a verified copy 

of said resolution. 

\_c\c.\q 

 ate\, I .--. . - -....-.-...,- -..- . - ,; -- r, :-I' 7 $ Legislative Secretary ;. ,.; ;; .r . , . : I: i . 

:. -: . . ', 

Executive Offices . r 

W9814 Airport Road P.O. Box 667 Black River Falls, WI 54k' 

(715) 284-9343 Fax (715) 284-3172 (800) 294-9343 . 
Subsection 12 Gaming Integrity 

A. General 

. ' 1. Corrections to Written Documentation - Corrections to written documentation is 

made by crossing out the error with one thin line only. Where initials are required, 

the initials shall not cover or merge with aiiy recorded numbers or document 

numbers. 

- 2. Mechanical Stamp - All forms used to document Casin~transactions (i.e. fill 

requests, fill slips, jackpot slips, exchange slips, etc.) will be mechanically stamped 

with the time and date upon preparation of the form and/or upon completion of 

transaction by the cage. 

3. Posting of Game Rules - The casino' shall conspicuously post game play procedures 

that are significant to patrons. The casino shall conspicuously post a notice that 

gaming is conducted and regulated by the Tribe, and the procedures that customers 

can follow to resolve player disputes. 

5. Photos or video can not be takediihed or commercially used without the prior . . written permission of management 

6. Casino patrons, guests or employees are not allowed to bring electronic devices into 

the Casino without proper approval. 

7. Casino Lighting must not reflect off the cards, chips or tokens in a way that would 

impede recording and viewing by surveillance cameras. 

8. Count rooms, vaults and cashier cages must have room lighting hard wired. There 

may be no ability to turn off the lights from inside the room or near the doors. 
9. Personnel (i.e. cashiers) in the case and slot booths, will place cqrency, filVcredit 

documents, etc. witkin the identifying marks placed on the counters by Surveillance. 

10. Elevators used for transporting drops, cash and people at the same time must have 

video surveillance inside the elevator and at each opening on the floors. Elevators 

which do not carry people need not have surveillance inside the elevator but must 

still have surveillance at each opening on the floors. 

11. The casino shall have a minimum of one alarm button per customer transaction area 

(i.e. each cashier station in the czge and slot booths). i 1 . . .. - 

12. Counterfeit Currency Procedures - Procedures are developed and implemented for 

the handling of counterfeit curreicy. These procedures shall be approved by the HoChunk Nation Gaming Commission prior to implementation. 

. . > -- , -. I ... 

B. Employee Requirements 

1. Age Requirement - No person under 18 years of age may be employed in the direct 

conduct of gaming. 

2. Gaming by Key Persons - The Ho-Chunk Nation Gaming Ordinance (Chapter 15) 

designates who may or who may not play at the Casinos. 

3. hcornpatible Gaming Positions amons Gaming Employees - The casino shall 

develop procedures to ensure the segregation of duties among incompatible positions 

for immediate family members (i.e. immediate family members do not participate in 

the same transactions such as Nldcredits). 

4. Criminal and Background Restrictions - The Ho-Chunk Nation Gaming Ordinance 

designates the procedures to make determinations of suitability for persons employed 

in the conduct of gaming in accordance with applicable Federal and Tribal laws. 

5. All pockets on casino uniforms will be sewn shut on all cash handling (or 

cash equivalant) employees. 
C. Surveillance 

General 

a. The casino must have a sweillance system that covers the entire casino 

. ' including the cage, count areas and gaming areas. Monitors and controls for 

the su~eillacequipment are located in a surveillance room which cannot be 

obsemed by persons on the gaming floor. 

b. Access - The surveillance room must be separate from other functions of the 

casino md shall remain locked. Access shall be limited to Surveillance 

personnel&Tribal Znspectors Office personnel and the General Manager 

of the Gaming Facility. 

c. Surveillance cameras will be in the sweillance rooms and should provide 

views of the general area includi~g~the work stations and the entry door, and - .:' 

will provide audiolvideo coverage. Video tapes of the surveillance rooms are to 

be sealed and forwarded to the Tribal Lnspector's oflice. These tapes are to be 

viewed by the Tribal Inspector's office only. 

d. Personnel - The surveillance room is to be staffed to provide coverage of all 

shifts and activities in the casino. 

e. Logs - Authorized surveillance personnel shall maintain the following logs: 

(1) Sign-in logs for nonsurveillance authorized personnel. 

(2) Daily activity logs. 

(3) Video library logs. 

In addition, a reportnog is prepared for any unusual items noted or possible 

i&actions of procedures and is forwarded to the appropriate personnel. 

f. Equipment - The observation equipment shall be a matrix-type switching 

system with the capabilities of pan-tilt-zoom (PTZ) or have the capability to 

bring up any camera throu~~hout the casino to a designated monitor. The 
Subsection 1 Table Games Department Overview 

A. The table games area consists of one or more pits throuoJlout the casino. Each pit generally 

consists of a group of twelve tables or less made up of various table limits. 

B. ' Personnel assigned 

1. The following personnel will be used to operate and conduct the table games: 

a. Shift supervisor -Minimurn of one per shift when two or more pits are open. 

b. Pit boss - Minimum of one per open pit. 

c. Floor Person - Minimum of one for every four open tables or fraction thereof. .. - -. -..-. 

d. Dealer - Minimum of one per open table. 

C. For all computerized table games systems, a personnel access listing will be m~ntained 

which includes at a minimum: 

1. Employee name; 

.2. Employee identification number (or equivalent); 

3. Listing of functions employee can perform or equivalent means of identifying same. 

C-1 

Approved October 14, 1996 by -ing Commission I.. t , . f. P ..,, ' . ' 
NOTE: In emergency situations which require drop box access at other than 

scheduled count times, at lest three persons from separate departments, 

including management, must participate in these situiiions. The reason for 

zccess must be documented with signatures of all participants and 

observers. 

E. . . Count Room Keys 

1. At least three count team members are required to be present at the time count room 

and other soft count keys are issued for the soft count. 

F. Chip Rack Keys 

1. Chip rack keys can only be checked out from the cage by a pit executive (Table 

Games Director, Shift ~u~ervisor)*~~r ease of shift change, a continuous contro1)qg , 

of these keys can be kept with Security stationed at the cage entrance. * or Pit BOSS .-'- - r. . 

2. The keys to the locked chip racks containing the table inventories will be maintained 

and controlled by the Shift Supe~sorPit Boss in a secure place during the shift (see 

Key Conbol Section), and at no time be made accessible to any cashiers cage 

~ersonnel or to any person responsible for transporting such table inventories to or 

fiom the gaming tables. 

G. Toke-Box Keys 

1. Toke box keys can only be checked out from the cage by the Toke Committee with 

Security present. 

H. Duplicate Keys 

1. All duplicate keys are maintained in a manner which provides the sake degree of 

control over drop boxes as is required for the. original keys. . . . ." 

I. The involvement of at least two individuals independent of the cage department is required 

to access stored empty drop boxes. 

Approved October 14, 1996 by Gaming Commission 

Approved January 14, 1997 by HoShunk Nation Legislmrc 
Subsection 7. Table Lnventories 

A. Whenever a gaming table in the casino is opened for gaming, operations will commence 

with an amount of gaming chips, to be known as the "table inventory", and there will be no 

additions or deletions during the gaming day except: 

1. In exchange for cash and chips presented by casino patrons. 

2. In payment of winning wagers and coliections of losing wagers made at such gaming 

table. 

3. In conformity with the fill and credit slip procedures. 

4. In the removal of defective chips. 

4. 

Z I.' 

B. Each table inventory and its corresponding table inventory slip ("opener"), prepared in 

conformity with procedures set forth, will be stored during non-gaming hours in a separate, 

locked chip rack which includes a clear lid. The chip rack will be clearly marked on the 

outside with the gaming table number to which it corresponds. 

1. The information on the opener will be visible fiorn the outside of the locked chip 

rack. 

2. Security will provide the necessary protection to insure the integrity of table 

inventories during non-gaming hours. 

C. Key Control 

1. Chip rack keys can only be checked out from the cage by a pit executive (Table 

Games Director, Shift Supervisor)*For ease of shifi change, a continuous control log 

of these keys can be kept with Security stationed at the cage enhance.* Or Pit Boss 

Approved October 14, 1996 by Gsmiog Commission 

Approved January 14. 1997 by Ho5hunk Nation Legislature 
4. . Opening of Table for Cram. 

a. Prior to use at the table, $&.&-=4 . a-- decks of card? will bi sorted and inspected 

by a dealer and the Floor Person assigned to the table will verify the 

inspection. * that will be put into play at the table 

b. After the cards are inspected, the cards shall be sorted into sequence and into 

suit by deck and spread out face upwards on the table, for visual inspection by 

the first player or players to arrive at the table. 

c. On the arrival of the first player, the dealer announces "shuffle" and waits for 

an affirmative response fiom the Floor Person. The dealer then proceeds to 

pick up the decks one at a time beginning with the outside rows first. Each 

deck will be placed into the shoe in a staggered fashion. 

d. Taking one deck fiom the shoe, riffle once and then spread them face down on 

the layout horizontally from right to left. Taking a second deck fiom the shoe, 

riffle once and then spread them face down on the layout horizontally fiom left 

to right. Wash the two decks together by mixing in a circular manner and then 

gather the cards and place them in the discard rack. Repeat the process until all 

the decks have been washed. 

e. Proceed to the house shuffle. 

f. After the initial shuffle, if the cards are not in use (dead game table) they will 

be sorted into sequence and into suit by deck and spread face upwards on the 

table. The first player or players to anive at the table will be given the 

opportunity to visually inspect the cards before the opening shuffle procedure 

is initiated. 

5. House Shuffle and Cut of the Card$. 

a. Immediately prior to commencement of play and after any round of play as 

may be determined by the Tribe, the dealer will shuffle the cards so that they 

are randomly intermixed. 

C-49 

APpmvcd Oaobcr 14, 1996 by Gaming cbmmission 

A39mvcr 1- -I, u., IWIT -v u--c- - r 'r', #',-I- re'. - . .- 
(10) Number of times cash compartment has been opened. 

(1 1) The number of times the cabinet has been opened. 

c. Electronic games of chance utilizing coin drop hoppers are permitted, provided 

they are monitored by an on-line electronic game minagementfreporting 

system which has been approved by the independent gaming test laboratory. 

d. The terms "error condition" as used in this subdivision includes: - - .. 

(1) Cabinet door open 2nd cash compartment door open. 

(2) Coin-in tilt and reverse coin-in tilt. . .; 

(3) ' Hopper empty, hopper jam,gr hopper runaway/malfunction. -. . 

8. Repairs and service: 

a. A casino slot technician or authorized casino slot person may open the gaming 

cabinet to effect repairs Ad senice but shall do so only in the presence of 

security department personneFIf the on-line electronic game 

managementlreporting system is equipped with player tracking (with the 

appropriate security levels as approved by the HCGC) and the casino personnel 

have been assigned an individual access card; a licensed key gaming employee 

of the casino may be substituted for the security department personnel. Each 

slot floorperson or slot tech must insert their individual access card into each 

slot machine containing player tracking to proceed with opening the slot 

machine for repairs or service. 

b. Each he a slot machine is opened, a machine maintenance card is updated. 

The machine maintenance card contains the machine number, location, date, 

time and reason the machine was opened, and is signed by the individual 

opening the machine. 

* orxnder specifically verified observation by Surveillance which shall act 

as the presence of a second employee as required by the Compact. 
D. Access to the triplicates shall be maintained and controlled at all times by the revenue audit .-- 

department, or the security department if revenue audit is not present, who is responsible 

for controlling and accounting for the unused supply of payouts, placing payouts in the 

dispenser and removing from the dispenser each day the triplicates remaining therein. 

E. The pre-numbered three-part jackpot slip form (for manual jackpots), and the pre- 

. . numbered two-part jackpot slip form (for automated jackpots), includes the following 

information: 

The casino number of the slot machine on which the jackpot was registered. 

2. The winning combination of reel characters (game outcome) constituting the jackpot 

(including reel symbols, card values and suits, etc.). 

3. The date and time during which the jackpot occurred. 

--- : 

4. The dollar amount to be paid from the cLge. 

5. The slot booth number, if applicable, from which the dollar amount is to be paid. 

6. The signatures of the preparer, at least two employees verifying and witnessing the 

payout, and the patron after receiving the payout. 

7. The time of preparation of the jackpot on the original and duplicate. 

F. AU jackpot payouts must be in the form of tokens, cash, currency or check and will be 

disbursed by the slot attendant/flooqerson dkectly to the patron; or 

if the jackpot is $1,200 or more, by the slot attendantffloorperson 

afier approval by the slot shift supervisor or casino shift oficer (CSO) directly to the , 

patron. 

D-24 

Approved October 14, 1996 by Gaming Commission 

Approved Jmuq I 4, 1997 by HoCh~k Nation LegisI~m~~ 
2. The dzte and time during which the tokenslcoins are distributed. . 

3. The denomination of tokenslcoins to be distributed. 

4. The dollar amount of tokenslcoins to be distributed. 

5. The signatures of at least two employees verifying and witnasing the hopper fill. . . 

NOTE: When the above information has been completed, the cashier or cage 

supervisor will sign the hopper fill slip while it is in the dispenser. The slot 

- 

floorperson will sign the original and duplicate before the hopper fill is 

issued. 

The duplicate is maintained by the cash while the triplicate remains in the dispenser. 

The cashier then issues the- hopper fill to the slot floorperson who takes the hopper fill 

dd the original copy of the hopper fill slip to the slot . . . . -.-'- machine. -<.. 

. - 

F. The slot floorperson unlocks the machine with their key, fills the hopper and relocks the i 

machine under the observation of sec,uriq personnel. 

G. The observer then signs the original hopper slip documenting that the tokenslcoins were 

placed in the appropriate machine and the machine was reiocked. The complete original 

hopper slip is then placed into the accounting/security box (boxes may be located 

throughout the Casino) by the slot floorperson member. 

H. Hopper Slips 

1. The duplicate copy of the hopper fill slip is maintained by the cashier and is used as a 

balancing item for the cashier. 

2. At the end of each shift, the cashier will transfer the .. duplicate . hopper fill slips to the 

vault for exchange, and the vault will forward the hopper fill sLips to revenue audit at 

the end of each day. 

D-28 

Approved October 14, 1996 by Gaming Commission 

Approved Januvy 14, 1997 by Ho5hunk Nation Legulanuc 
Subsection 3 Preparation of Daily Deposit 

A. Once a day, the daily bank deposit from the casino will be prepared by a vault cashier and 

held until picked up by the armored car service. The amount of the deposit will be 

. . determined by a formula set forth by the casino's Chief Financial Officer and approved by 

the Legislative Finance Sub-Committee. 

B. The Cage Shift Supervisor will agree the total amounts to be deposited to the daily deposit 

slip. 

1. The cage shift supervisor will date and initial the deposit slip to indicate this . . agreement 

2. The daily bank deposit will remain in the .... sealed deposit bag in the vault until the 

armored car representatives have identified themselves to the vault e+&ye- supervisor 

responsible for the contents of the vault and has signed a receipt acknowledging the ! 

transfer of the deposit bag and its contents. 

C. Once the deposit has been processed by the bank, the validated deposit slips will be 

forwarded by mail directly to the attention of the accounting depment to be dated and 

initialed after ageement with the invalidated deposit slip verified by the accounting 

department. 

NOTE: If the validated deposit slip is not received within seven (7) days of the deposit 

being picked up by the armored car carrier, the casino CFO will contact the bank 

to begin investigating why a validated deposit slip has not been received by the 

casino. A report regarding the £indings of the CFO will be forwarded to the HoChunk Nation Gaming Commission. 

E-6 

Approved October 14, 1996 by -ing Cornmirsion 

Approved Januq 14. 1997 by HoChunkNdon Legislam 
Subsection 5 Accounting Controls for TokenICoin Exchange 

A. A change bank is an imprest value of tokedcoins and currency to be exchanged by a 

cashier with a patron for currency or coin or chips. 

B. Change banks will be constructed to provide maximum security of the contents maintained 

therein. 

- 

C. Key Control 

1. Each bank will have a separate lock and each will be keyed differently with a master 

key for all banks. 

cashier 

2. Keys to the banks will be maintained by . .the -cage -and issued to the cashier -5:: 

assigned to the change bank. 

key cahiq 3. The cashier and the-wil sign a key log acknowledging the cashiers i' 

receipt of the keys. 

ke cashier 4. At the end of the cashier's shift th; keys are to be returned to the h. 

ke cahsier 5, The cashier and thb will sign the key log achowledging the return 

of the keys. 

D. A slot change booth/bank will have the ability to complete jackpots and hopper fills in the 

same manner as the main cage as defined in Section D (Jackpot Payouts and Procedure for 

Filling Hoppers). 

1. All documents will be recorded on a separate controlled document log sheet. 

2. At the end of the shift, the slot change booth cashier will add up the to&l ofjackpots 

and hopper fills and sign the controlled document log sheet. 

E-8 

Appmved October 14, 1996 by Gaming Commission 

Approved January 14. 1997 by Ho-Chunk Nation Leg&lvurc 
Subsection 3 Replacement or Duplication of keys 

THE CAGE MANAGEFUDIRECTOR OF CAGE OPERAnONS AND THE DIRECTOR OF 

SECURI~~IN CONnTC.iCTION, ARE THE ONLY PERSONNEL AUTHORIZED TO 

ORDER NEW KEYS AND LOCKS OR THE DUPLICATION OF KEYS. 

* . . (or in the event of absence of either of them, his or her designee) 

A. Supply request will be generated ad fomarded to the Cage ManagerDirector Of Cage 

Operations. 

B. A purchase order will be generated and the order will be placed by the Cage 

Manager/Director Of Cage Operations and the Director Of Security. The purchase order 

must also be signed by the Chief Financial Officer (CFO) or the General Manager. .-. 

C. When the locksmith arrives at the Casino, they shall be accompanied by security, who will 

monitor the work being done. .-.- 

. - . . 

D. When the work is completed, the locksmith will deliver all keys to the Cage where they 

will be placed in the appropriate Key Control Box for issuance. Security and cage 

personnel will sign the Key Log as recipients of the new keys. 

E. Locksmith will supply certificate of what locks were changed andlor what keys were made 

by identifying by manufacturer and key number. This documentation will be maintained by 

the Cage in the appropriate Key Control files. 

F. Appropriate documentation will be forwarded to receiving/purchasin,o for accounting 

purposes. 

Approved Ocmber 14, 1996 by king Commission 

Appmved January 14, 1997 by HoChunk Notion Legislaml~