Casino Licensee’s organization

(1) Each Casino Licensee shall have a system of internal control that includes the following– (a) administrative controls which include, but are not limited to, the plan of organization and the procedures and records of decision processes leading to management’s authorization of transactions; and (b) accounting control which includes the plan of organisation and the procedures and records that are concerned with the safeguarding of assets and the reliability of financial records and are consequently designated to provide reasonable assurance that– (i) transactions are executed in accordance with the management’s general and specific authorization which shall include the requirements of these Regulations; (ii) transactions are recorded as necessary to permit preparation of financial statements in conformity with generally accepted accounting principles and with 148 Gaming Control Regulation 7 above, and to maintain accountability for assets; (iii) access to assets is permitted only in accordance with management’s authorization which shall include the requirements of these Regulations; and (iv) the recorded accountability for assets is compared with existing assets at reasonable intervals and appropriate action is taken with respect to any differences. (2) The Casino Licensee’s system of internal control shall provide for– (a) competent personnel with integrity and an understanding of prescribed procedures; and (b) the segregation of incompatible functions so that no employee is in a position to perpetrate and conceal errors or irregularities in the normal course of his duties. (3) Each Casino Licensee shall, at a minimum, establish the following departments with respect to the casino operation– (a) a Surveillance Department supervised by a Director of Surveillance who shall co-operate with, yet perform independently of all other departments and shall report directly to the managing authority of the Licensee or its audit committee or equivalent regarding matters of policy, purpose, responsibilities and authority and indirectly to the Chief Operating Officer for daily operations. The Director of Surveillance shall be responsible for, but not limited to, the followingGaming Control 149 (i) the clandestine surveillance of the operation and conduct of the table games; (ii) the clandestine surveillance of the operation of the slot machines; (iii) the clandestine surveillance of the operation of the cashier’s cage; (iv) the audio-video taping of activities in (v) the detection of cheating, theft, embezzlement, and other illegal activities in the casino, count rooms, slot booths, and cashier’s cage; (vi) the video taping of illegal and unusual activities monitored; and (vii) the notification of appropriate casino supervisors, and the Board upon the detection and taping of cheating, theft, embezzlement, or other illegal activities; (b) an Internal Audit Department supervised by an executive officer who shall perform independently of all other departments and shall report directly to the managing authority of the licensee or its audit committee or equivalent regarding matters of policy, purpose, responsibilities and authority and indirectly to the Chief Operating Officer for daily operations. Such department shall be responsible for, but not limited to, the following150 Gaming Control (i) the review and appraisal of the adequacy of internal controls; (ii) the compliance with internal control (iii) the reporting of instances of non- compliance with the System of Internal (iv) the reporting of any material weaknesses in the system of internal (v) the recommendation of procedures to eliminate any material weaknesses in the system of internal control; (c) a Casino Department supervised by a Casino Manager who shall perform independently of all other departments and shall report directly to the Chief Operating Officer. The Casino Manager shall be responsible for the operation and conduct of the following games– (i) Craps; (ii) Blackjack; (iii) Baccarat; (iv) Roulette; (v) Big Six; and (vi) Wheel of Fortune; (d) a slot Machine Department supervised by a Slot Machine Department Manager who shall Gaming Control 151 perform independently of all other departments and shall report directly to the Chief Operating Officer. The Slot Machine Department Manager shall be responsible for the operation of the slot machines; (e) a Credit Department supervised by a Credit Manager who shall co-operate with, yet perform independently of all other departments and shall report directly to the Chief Operating Officer. The Credit Manager shall be responsible for the credit function including, but not limited to, the following– (i) the verification of references; (ii) the establishment of patron credit limits; (iii) the maintenance, review and update of the patron’s credit lines; (f) a Security Department supervised by a Director of Security who shall co-operate with, yet perform independently of, all other departments and shall report directly to the Chief Operating Officer or his equivalent. The Director of Security shall be responsible for the overall security of the establishment including, but not limited to, the following– (i) the enforcement in the establishment of all relevant laws; (ii) the physical safety of patrons in the establishment; 152 Gaming Control (iii) the physical safety of personnel employed by the establishment; (iv) the physical safeguarding of assets transported to and from the casino slot and cashier’s cage departments; (v) the protection of the patron’s and the establishment’s property from illegal activity; (vi) the detainment of persons that may be involved in illegal acts for the purpose of notifying the law enforcement or Board authorities; and (vii) the recording of any and all unusual occurrences within the Casino for which the assignment of a Security Department employee is made. Each incident, without regard to materiality, shall be assigned a sequential number and, at a minimum, the following information shall be recorded in indelible ink in a bound notebook from which pages cannot be removed and each side of each page of which is sequentially numbered– (a) the assignment numbers; (b) the date; (c) the time; (d) the nature of the incident; (e) the person involved in the incident; and Gaming Control 153 (f) the security department employees assigned; viii) verification of jackpot payouts and hopper refills; (g) a Casino Accounting Department supervised by a Director of Casino Accounting who shall report directly to the Chief Financial Officer. The Director of Casino Accounting shall be responsible for, but not limited to, the following– (i) (ii) the preparation and control of records and data required by these Regulations; (iii) the control of stored data, the supply of unused forms, the accounting for and comparing of forms used in operating the Casino and required by these Regulations; and (iv) the control and supervision of the (h) a Cashier’s Cage supervised by a Cage Manager who shall supervise cage and slot cashiers and change persons and co-operate with, yet perform independently of, the Casino, Slot and Security Departments and shall be under the supervision of, and report directly to, the Director of Accounting. The Cashier’s Cage shall be responsible for, but not limited to, the following154 Gaming Control (i) the custody of currency, coin, patron cheques and markers, gaming chips and and normally associated with the operation of a Cashier’s Cage; (ii) the approval, exchange, redemption and consolidation of patron cheques and markers received for the purpose of gaming in conformity with these Regulations; (iii) the receipt, distribution and redemption of gaming chips and plaques in conformity with these Regulations; and (iv) such other functions normally associated with the operation of a (4) The Casino Licensee’s personnel shall be trained in all accounting and internal control practices and procedures relevant to each employee’s individual function. Special instructional programs shall be developed by the Casino Licensee in addition to any on-the-job instruction sufficient to enable all members of the departments required by this Regulation to be thoroughly conversant and knowledgeable with the appropriate and required manner of performance of all transactions relating to their function. (5) Functions described in this Regulation shall be performed only by persons licensed to the particular position, or persons licensed to supervise that particular position under the Act and any Regulations made thereunder. (6) No person shall transfer from the Surveillance Department within the same Casino without the prior approval of the Board. Gaming Control 155