ECL Development, LLC (the “Company”) supports compliance with the American Gaming Association’s (“AGA”) Code of Conduct for Responsible Gaming (the “Code”) as well as regulations issued by the Nevada Gaming Commission.


Our pledge to our employees, our patrons, and the community is to make responsible gaming an integral part of our daily operations and encourage our partners to do the same throughout their projects. The AGA’s Code addresses employee assistance and training, alcohol service, casino games in person and online, advertising and marketing of casino gambling, underage gambling and unattended minors in casinos.



 

Guidelines



 

Responsible Gaming Communications


The Company encourages our partners and properties with which we do business to provide approved responsible gaming collateral and Problem Gaming brochures (e.g., Problem Gambling Information and Resources brochure or other Company approved problem gambling collateral) on display at all property locations and cash access devices.


Approved responsible gaming collateral and Problem Gambling brochures should be made available upon request.


Approved responsible gaming collateral and Problem Gaming brochures include the toll-free help line number for the Nevada Council on Problem Gambling, 1-800-522-4700.


The Problem Gambling brochure includes the nature and symptoms of problem gambling.


Responsible Gaming signage or other suitable display bearing the Nevada Council on Problem Gambling toll-free help line number should be posted at a visible place where employees congregate to include the employee dining room, near employee entrances, employee break areas, and the employee service center.


Problem Gambling brochures should be made available at the corporate office and in employees only areas of the casino locations.


Gaming-related websites should include information describing responsible gaming, policies and practices related to responsible gaming and where to find assistance.


Properties should maintain a self-limit policy and procedure that will allow patrons to request in writing the revocation of their privileges for specific services (e.g., casino-issue markers, player club/card privileges, on-site check-cashing, complementaries and gambling promotions).


Properties should make reasonable efforts (i.e., flagging a patron’s account) to honor a patron’s written request to be self-limited from gaming activities and reserve the right to exclude a patron from gaming without a request from the patron.


Newly hired employees should receive training on responsible gaming programs during new hire orientation. This general training should include the difference between responsible gaming and problem gambling, as well as the nature and symptoms of problem gambling. Additional training based on the department and job function should be conducted by individual departments. Gaming employees should be trained on responsible gaming and provided periodic refresher training that highlights the differences between responsible gaming and problem gambling. Periodic refresher training should be performed via department pre-shift meeting, Responsible Gaming Week, and/or online training modules (position specific). During periodic refresher training, employees should receive responsible gaming materials (e.g., brochures, policies, Marketing).


Underage Gambling and Unattended Minors in Casino


Properties should make diligent efforts to prevent underage individuals from participating in any gambling, loitering in the casino, or from gaining access to online or mobile gambling opportunities. Policies and procedures specifically related to underage gambling should be addressed in the properties’ Underage Gaming Policy.


The properties should post notices stating the legal age to gamble at or near the casino entrances.


Where reasonable, any gambling related messaging (online or print) should include a notice of the legal age to gamble.


If a child appears to be unsupervised or in violation of local curfews and other laws, casino staff should contact management to handle children/minors, and security personnel should take reasonable steps to locate a parent or responsible third party (e.g., police department) for transfer of children/minors. Training should be provided to relevant employees related to underage gambling, minor identification, and unattended minors, and the purchase and consumption of alcohol and tobacco by minors. Responsible Service of Alcoholic Beverages


Properties should maintain a separate Responsible Beverage Service Policy that in includes, at a minimum employees are prohibited from: (1) knowingly serving alcoholic beverages to a minor; (2) knowingly servicing alcoholic beverages to a visibly intoxicated patron; and (3) knowingly permitting a visibly intoxicated patron to gamble.


Employees in relevant positions should be trained in the Responsible Beverage Service Policy at the time of hire and will receive periodic refresher training.


Responsible Advertising


Advertising and marketing includes, among other media: radio, television and print ads, direct mail, social media, billboards, and internet promotions.


Casino gambling advertising and marketing should:


Contain a responsible gaming message and/or a toll-free helpline number where practical.


Reflect generally accepted contemporary standards of good taste.


Strictly comply with all state and federal standards to make no false or misleading claims or create a suggestion that the probabilities of winning or losing at the various games offered by the casino, or by betting on sports contests, are different than those actually experienced.


Casino gambling advertising and marketing should not:


Contain images, symbols, celebrity/entertainer endorsements, and/or language designed to appeal specifically to children and minors.


Feature anyone who is or appears to be below the legal age to participate in gambling or sports betting activity or imply that underage persons engage in casino gambling or sports betting.


Depart from contemporary standards of good taste that apply to all commercial messaging, as suits the context of the message or the medium utilized.


Be placed with such intensity and frequency that they represent saturation of that medium or become excessive.


Contain claims or representations that gambling activity will guarantee an individual’s social, financial, or personal success.


Be placed before any audience where most of the audience is ordinarily expected to be below the legal age to participate in gambling or sports betting activity.


Imply or suggest any illegal activity of any kind.


Be placed in media specifically oriented to children and/or minors.


Oversight, and Review


The properties should conduct annual reviews of its Responsible Gaming Policy.


RESPONSIBLE GAMING INFORMATION – GAMING RELATED WEBSITES


STATEMENT


ECL Development, LLC supports compliance with the American Gaming Association’s (“AGA”) Code of Conduct for Responsible Gaming as well as regulations issued by the Nevada Gaming Commission. Our pledge to our employees, our partners and properties with which we do business, and the community is to make responsible gaming an integral part of property daily operations.


Patrons may request at any time to be removed from any promotional mailings and for revocation of casino-specific privileges such as access to markers, player card privileges, on-site check cashing, complementaries, and gambling promotions. Properties should reserve the right to exclude a patron from gaming without a request from a patron. Properties should provide current education to new employees on responsible gaming and provide periodic refresher training.


Our partners should advertise responsibly by including a responsible gaming message and/or a toll-free help line number in advertising messaging where practical. Our partners should place media where most of the audience is reasonably expected to be above the legal age to participate in gaming activity. Properties should not feature collegiate athletes or persons designed to appeal to those under the age of 21.


If you or anyone you know may have a problem gaming responsibly, please call the 24-hour Problem Gamblers Help-Line at 1-800-522-4700. The Company provides this policy as a guideline with which it supports for each of the property projects it may be involved in. The Company is not responsible for any properties’ compliance and cannot require its partners or property owners to comply; however, the principles and guidelines set forth above are important and necessary and we encourage all of the entities with which we do business to establish a robust Responsible Gaming program. Any partner, property owner, or contractor with which we do business agrees to indemnify and hold the Company harmless for violations or loss from failure to abide by the guidelines set forth herein.