Casino Standards Policies And Procedures

Glossary of Casino Terms

1. Organizational Standards Policies And Procedures
2. Data Policies And Standards
3. Policies And Procedures Template
4. Standard Company Policies And Procedures

Policy: A formal, brief, and high-level statement or plan that embraces an organization's general beliefs, goals, objectives, and acceptable procedures for a specified subject area. Policies always state required actions, and may include pointers to standards. Policy attributes include the following: Require compliance (mandatory). Niagara Casinos’ policies and practices are intended to build an inclusive and accessible work environment free from discrimination and harassment. RELATED POLICIES AND PROCEDURES Accessibility Standards for Customer Service Policy REFERENCES AND FORMS Ontario Human Rights Code. Casino standards policies and procedures concept of personalized gaming to a whole new level. Now you can play on the casino standards policies and procedures go 24×7 regardless of where you are. All you need casino standards policies and procedures is a smartphone that gives you Internet access via 3G, 4G, LTE, or Wi-Fi.

B comp. Free beverage comp
Big. A term for $100, as in five 'big' = $500
Beans. Slang for cheques
Bet spread. The difference between a player's lowest and highest wagers
Bird dog. See 'Shill'
BFA. Black female adult
Black Book. See Excluded List
Bleed. The slow draining of the float or cheques tray by an advantage player
Bleeder. A winning player suspected of being an advantage player
BMA. Black Male Adult
Body talk. Non-verbal communication used by counting teams
Bone. A term used to describe a $1 value cheque, usually white in color
Brush. See 'scratch'
Bullet. An ace card
Burn card. The first card off the top of a new shuffle that is sacrificed and not played (goes straight to the discard rack)
Burn joint. A casino where, due to the game rules or reputation of the dealers, a player should expect to get burned (get a bad game or run into cheaters)
Bust-out man. A dealer who cheats
Camouflage. An act to appear less of an intelligent player so as to remain welcome at a casino’s tables
Candy Store. A casino that tolerates advantage players due to ignorance or open-minded executives
Case bet. A last big bet in which a player bets all his remaining chips on a hand in an attempt to come back from losses
CC. Card counter
Cheques play. What's said by a dealer to the pit boss when a player wagers black cheques or higher.
Clay. A chip or cheque
Curfew. An agreed-upon time for team players to end a play session
Dame. A card of the rank of queen
Daub. A foreign substance used to mark cards, can be anything from professionally-made color tinge to human body oil to ashes from the ash tray
Dead hand. A round called dead by a pit boss due to a complaint, misdeal, etc.
Deal me out. A term used to tell the dealer that you do not wish to play this round, as in 'Deal me out this round.'
Decisions per hour (DPH). The number of decisions (win, lose, or tie) that a player makes during 60 minutes. DPH x # of players = HPH (hands per hour for a casino)
Defensive wager. A wager to reduce one's potential loss
Desirability index. Win rate divided by the standard deviation x 100 = The D.I.
Discard rack. Plexiglas housing (usually smoke or red in color) used to hold discards
Double down. A blackjack play in which the player may bet an additional amount up to his initial wager to receive one, and only one, more card on his initial two-card hand
Double up. To increase your wager to twice the previous amount
Drop. The total funds removed from the table games' drop boxes
Drop box. A self locking box locked to a games table that the dealer places all incoming funds into (outside cheques, cash, fill slips)
Drummer. A player who is tight with his or her money
Duffer. An inexperienced player, a.k.a. a ploppy
Dummy up. What pit bosses used to tell dealers when they wanted them to be quiet and deal
Dump. Said of a dealer who pays losing hands or gives away the hole card or hit card (intentionally). Also a term used by players to describe a table that is losing money to the players
Edge. The percent advantage, either for the player or the house. That is, the percentage of the amount wagered that the player or house can expect to win or lose, over time
EOR. Effects of removal
Even money. An offer of insurance from a dealer when a player has a blackjack and the dealer has an ace showing. Not always a sound wager. Also, a wager that pays 1:1.
Excluded list. The 'black book,' maintained by the state, of players who are not permitted to enter or play in a casino in that state
Eye. A respectable term used to describe the surveillance department or surveillance camera
F comp. Free food comp
Face chaser. Said by casino personnel of a player who increases his wager after numerous small cards (non-tens) have been dealt. Also a term used by advantage players to describe Griffin agents
Fade. Slang for covering action or accepting a bet, as in to 'fade' a bet
False cut. When a dealer falsifies a cut to cheat a player
False shuffle. When a dealer mimics the motions of a real shuffle but retains a clump or the entire preshuffle composition of the cards
Fill. The act of replenishing the cheque rack on a table game with more cheques
Fill slip. The paperwork that must accompany the above-mentioned fill
First base. The first spot (furthest seat on the right) on a blackjack table
Fish. A ploppy or someone easily 'hooked.' A patsy
Fixed limit. The max wager a casino will allow or book on that game. Most states require casinos to post the table minimums and the fixed maximums.
Flagged. A player who is suspected of advantage play is 'flagged' to be watched whenever he returns
Flasher. Said of a dealer who exposes his or her hole or hit card, sometimes on purpose to an agent
Flat store. A casino that cheats
Float. Cheque tray on a table game
Floor supervisor. A person placed in charge of a certain game area. Usually monitors four table games
Fluctuation. A term used to describe the roller coaster ride one's bankroll may experience during a session or multiple sessions
Foul hand. A misdealt round that gets called off
Front loader. A dealer that exposes her hole card when burying it beneath the top card
Front loading. A play that takes advantage of a front loader dealer
Gallery. Non-playing spectators
Gambler. A player willing to wager without an advantage
Garbage. The discards
GCB. Gaming Control Board.
Gorilla. A 'big player,' a.k.a. 'money man'
Grand. Slang for $1000
Grave. The first shift of the day for casinos (starts at the end of the previous day, usually around 4:00 a.m.)
Gravy. A team's or player's overall winnings
Green. A $25 value cheque
Grifter. A term used to describe a cheater
Grift sense. That sixth sense good crossroaders have as to whether to continue with a plan or abandon it
Grind. Winning in a slow, small incremental manner so as not to draw any attention and make a profit over time
Gross revenue. Net win
Hand. The cards held by a player in one round of play
Handle. Total amount wagered in a casino
Hands per hour (HPH). The number of hands that a dealer can deal in 60 minutes, including to herself. HPH divided by (# of players + dealer) = DPH
Hard hand. A hand that can have only one total value, for example, a ten and a 7 = hard seventeen
Harrigan shoe. A shoe with a shield or horse-hair (bristle) covered opening
Heads up. Playing one on one with the dealer
Heat. Extra unwanted attention from a pit boss to a player who appears to be winning by means of advantage play
Heel peak. A method by which the dealer can peek the top card
HFA. Hispanic female adult
HMA. Hispanic male adult
High roller. A premium player, a.k.a. a 'whale'
Hit. To request or deal another card to a hand. Also see 'scratch'
Hold out. To hold out a card, a.k.a card mucking. Means to withhold a card illegally
Hold out device. A mechanical cheating device
Hold percentage. A casino's table games' win divided by the drop (buy-in) = hold
Hole card. The dealer's face down card
Hop. A cheating method in which cards are cut in such a way as to return them to their original pre-cut state
Hot hand. A run of high valued cards
House. Another term for the casino
Humps. A.k.a. 'belly strippers,' cards that have been altered by shaving the edges. Used in cheating to find specific cards
Hustle. Said of a dealer who solicits tips
Independent. A lone or solo card counter
Index. The printed values on the playing cards (2, 3, 4, 5, etc). Card counters also use this term to denote the count at which their playing strategy for a given hand changes
Index number. Card counter jargon used to identify the count for specific strategy deviations.
Insurance. A side bet that the dealer has a 10-value card in the hole when showing an ace for a top card. Pays 2:1
Jog. A method in which a cheating dealer marks a position in the deck or shoe; used to guide an agent to the place to cut
Juice. A term used to describe a casino employee who carries political weight or influence within the organization, as in 'That boss has a lot of juice. ' Also used as a verb, as in 'He was juiced into his job.'
K. Slang for thousand
Key card. A playing card used to predict an upcoming card or slug of cards, such as an Ace or clump of 10's
Key employee. A casino executive
Kibitzer. A non-stop talking spectator
Knave. A Jack
Knock off. A playing card marked by sandpaper (for cheating purposes)
Lammer. A chip used to identify the dollar amount given to a player under credit conditions for taking or paying back markers
Large. A term for $1000; ten large = $10,000
Layout. The green felt cover on the table made of a nylon weave with a silk screened custom monogram showing the casino’s name, rules, etc.
Limit. The maximum wager a casino is willing to book. Usually displayed on the table game plaque.
Locator. One who plays to the 'Key Card,' a.k.a. location play
Lock it up. Placing the cheques from a player’s lost wager into the tray.
Longevity. The amount of time measured in minutes, hours, days, weeks, or years before a casino gets wise and bars you
Luminous reader. Cards marked by special ink or substance that can only be seen with special glasses or contact lenses. Cheating
Marked cards. Cards that have been altered from factory standards in order to aid a cheater
Marker. A counter check made payable to the casino in exchange for cheques. Used for 'playing' credit
Marker play. A player who plays against his own front money or previously established credit arranged at the cage
Martingale. A very old method of progression betting. A systems player.
Master report. The 'rip sheet,' or summary sheet, of all wins, drops, fills, markers, etc. per table. This report includes a report on each individual game
Mechanic. A dishonest dealer
Milker. A tight wad player
Money man. See B.P., a.k.a. Big Player
Money manager. A player who makes calculated wagers according to bankroll size, edge, etc.
Monkey. An Asian term for a 10 card
Mucker. A player who switches cards on a table--a cheating move
Mug shot. A picture of a suspected advantage player, shot taker, or cheater, maintained in a file by casinos and official authorities
Multi-deck. A blackjack game that has more than 1 deck in play at the same time, as in double deck, 6 deck, 8 deck
Mystic. An irrational, unreasonable player
Natural. A two card total of 21 in blackjack
Negative deck/shoe. A deck or shoe with extra high cards depleted so that the count has swung below neutral
Negative swing. A losing period
Nickel. A $5 value cheque, a.k.a. red cheque
No dice. Casino term for No Deal, no way, not going to happen, etc.
Nurser. A player who 'sweats' his cards; a card fondler
Nut. The casino's overhead
Odds. A probability ratio, as in your odds of liking the movie 'Stacey's Knights' are slim to none at best!
Office. A signal given by a cheat to his partner
OMA. Oriental male adult
On the square. On the up and up, fair, honest. Not crooked or flat
Opener. A table card used to counter/verify the cheque inventory when the table was closed. The opener and the closer should match
Original. The first two 'original' cards dealt to a player
O.T.T. Off the Top, the first round after a shuffle
Our cheques. Said of a player who is wagering with money he or she won from the casino, as in 'She's playing with 'our cheques'
Outsider. A non-employee that works with an employee to embezzle/steal cheques from the table
No peek reader. An electronic card-reading device mounted on a blackjack table so that a dealer can check for an ace or ten hole card without seeing the actual value of the card
Pack. Deck of cards
Paddle. The clear plexiglas device used to push the currency (from buy ins and lost cash wagers) and fill slips into the drop box
Paint. Face card
Palming. Another term for mucking, mucker
Pan handler. A dealer who attempts to embarrass a player into toking
Partial insurance. To insure your bet for less than the full amount
Past post. To make a wager after the conclusion of the event wagered upon. Illegal cheating move
Pat. A strong two card total of 17(hard) or better, as in 'a pat hand'
Payoff. The monetary amount one expects to receive upon winning the bet
PC. Hold percentage
Peek. To view the top card of the deck prior to dealing it. A cheating move
Pen. The area of the deck or shoe where the 'sweat' or shuffle card is placed, a.k.a. penetration
Picture card. Face card
Pigeon. A sucker, easy mark
Pincher. Player who removes cheques from his wager after losing but before the dealer can pick up the lost bet. A cheat move
Pips. The spots on the face of the cards indicating their value
Pit. The area in which gambling is conducted; a.k.a. the Arena
Pit boss. An employee entrusted to oversee numerous Floor Supervisors in a pit
Pit clerk. Data entry clerk in charge of printing fill slips for the supervisors, marker input, player rating input, etc.
Ploy. A system or stratagem
Plus count. A term used to indicate that the composition of the deck favors the player due to an excess of ten value cards
Policy. A casino’s way of doing things: 'It's not our policy to take personal checks'
Power of the pen. Having the authorization to comp at the expense of the department or the casino
Press it up. To increase your wager, a.k.a. double your wager
Presser. Player who adds cheques to his/her winning wager after knowing the outcome is in their favor
Procedure. A casino’s written rules that employees must adhere to
Progression. A playing system that entails increasing or decreasing your wager after winning or losing a hand
Prove hand. An action requested by a floor supervisor (or higher) for the dealer to 'back out' the cards from the discard rack and restore them to the correct players
Pull through. A false shuffle
Punter. An Australian term for a player
Puppy print. The Ace of clubs
Quarter. A $25 cheque. Also see 'green'
Quitter. A player who loses and leaves
R comp. Free room comp
Rabbit hunting. Part of the procedure a dealer goes through to check new cards prior to putting them in play--to check the front and back of new cards
Rag, or rags. To a card counter, low cards
Rail thief. Someone who steals cheques from casino players at the tables
Rat holer. A player who secretly pockets chips in order to hide his winnings from a casino
Readers. Marked cards
Red. A $5 cheque, also see 'nickel'
RFB comp. Free room, food, and beverage comp
RFBA Comp. Room, food, and beverage unlimited
Rider. A player who stands behind a seated player and wagers on the same spot. In some countries, the larger bettor controls the decisions on the hand
Rim. Slang for a marker or credit player
Rim Card. An index card used to track a premium player's 'rim' play
Ring In. To introduce an unfair deck into play to aid the casino, a.k.a. a 'ringer'
Rip off. Slang for a ruse or sting
Risk of ruin. The risk or likelihood of a player losing all of his or her bankroll
Rolling. An expression called out by a dealer before turning a freshly shuffled deck on its side for squaring, as in 'rolling the deck'
ROS. 'Rule of Six.' Applies to single-deck games. Dealer will deal 5 rounds to 1 player, 4 rounds to 2 players, etc. Always adds up to 6.
Rover. A player who roams around looking for an empty seat so that he can play
Rummy. An inebriated player tolerated only because he has funds
Run. A long or unusual winning streak
Run up. Any type of deck stacking (cheating)
Runner. A cheater who fails to execute his move correctly and therefore must make a run for it
Running count. A count of the card values as the cards fall before converting to a true count
Ruse. A plan or means of deception
Sanded deck. A deck that has been marked with sandpaper for cheating purposes
Sawbuck. A $10 bill
Scratch. An old term used to describe the action that a player performs to request a hit
Second base. A term used to indicate the playing position at the center of the table. There is a difference between a base and a spot.
Shaved deck. A deck of cards that has been altered for cheating purposes
Shift boss. A key employee in charge of all pit activity during his or her shift. The shift boss reports to the casino manager
Shill. A player who is paid by the casino and bankrolled by the casino to play at empty games in order to attract others into playing
Shiner. A mirror like device used by a player to catch the image of the dealer's hole card. Illegal under the device law
Shoe. A device used to hold multiple decks of freshly shuffled cards for dealing
Short lived play. Same as 'short ‘n sweet' except that the player wins and then departs rather quickly. Also see the surveillance glossary at this Web site
Short ‘n sweet. A term used to describe the play session of a player who loses a lot of money rather quickly
Single Deck. A game dealt from only one deck
Snake bend. A card that has been marked for cheating purposes by quickly bending it from the upper left corner to the lower right corner
Snapper. In blackjack, any two card combination that equals 21
Soft double. A two card total that includes an ace that is doubled down on
Split. A rule option afforded by some casinos in which a player may take two identical value cards and split them into two hands (and wagers)
Spooking. Two players gaining an edge by having one see the dealer hole card (usually from behind the dealer) when the dealer peeks, then communicating the info to the other player.
Spot. The betting area or box in front of a player. First spot is to the dealer's left; then go clockwise to spot 6 (or more)
Spotter. A member of a count team who grinds away at a table and signals in the Big Player when the count is high
Stand. To refuse any further hits on your blackjack hand.
Standard deviation. A mathematical term for describing the variance of a game
Steamer. A player who is chasing his losses
Stiff. In blackjack, a two-card hard total from twelve to sixteen
Stiff sheet. A folded up sheet carried by the CSM (Casino Shift Manager) showing his or her shift's totals. Also see 'Master'
Sting. See Ruse
Store. A casino
Stuck. To have lost money gambling, to be down, as in 'We’ve got him stuck for $20K'
Suit. Slang for a casino pit employee
Sweat card. A plastic red, green, yellow, purple, or other color card used to mark the end of the portion of cards to be dealt in a deck or shoe. Indicates the 'penetration'
System. To casinos, wagering or money management patterns erroneously employed by players to gain an advantage, in contrast with legitimate methods like card counting (casinos love systems players)
Table hopper. A player who hops from table to table to play fewer hands at a disadvantage
Tapped off. A dealer gets 'tapped out' when relieved for a break
Tapped out. To have lost all your money
Tell. A facial expression (face dance) or gesture that gives a clue to an opponent
Theoretical hold. Percentage of wagering buy-ins that the house expects to keep on any given game or machine based on the house's mathematical advantage and game speed. Always an estimate
Third base. The last possible spot to the dealer's right on a blackjack table, a.k.a the last spot, or anchor
Tip. See toke
Toke. A tip (token of appreciation)
Tray. The float or tray on the table in front of the dealer that holds the house cheques
True count. Running count divided by the number of undealt decks
Truncating. To remove the decimal portion that follows an integer
TTO. This Trip Only is said when a player asks for an extension on a maxed out account. The casino may agree, but TTO
Turn. An action performed by a player to distract (turn) a casino employee. 'Turning' is used for both legal and illegal purposes
Underdog. A player with a very small starting bankroll who builds it up to a small empire
Unit. Another term used for cheques or chips; 5 units could be 5 red, green, black, etc.
Vigorish. Slang for 'commission,' a percentage of a win that the house takes to get its advantage in some games
Walk. To leave a table game
Walked with. Said of the amount a player leaves a gaming table with, part of a dealer's report to a pit manager or higher, as in 'He walked with $5K'
Warp. Cards that show a distinctive bend due to the dealers having to manually peek the hole card
Wash. A procedure that requires the dealer to 'pizza wash' cards newly introduced to a game. The act of mixing the cards before shuffling by spreading and smearing them around on the table
Wave. The hand motion a dealer makes to offer insurance or the chance to wager prior to dealing a round
Wave off. A hand motion a player is required to make to show that he or she wishes to stand and wants no more cards
WFA. White female adult
Whale. Term for a premium player, a.k.a. high roller
Whiz machine. A fill, credit, and marker slip dispenser. It's like a Pez dispenser, except it dispenses casino documents
Whole 9 yards. A slang term for a 'case' bet
Win. Gross revenue, also see 'net win'
Win rate. The amount the house or a player expects to win per hour, based on game speed, dollars wagered, and advantage
WMA. White male adult
X-Ray. Said of a player (cheater) who can read the cards from the backs, based on such marks as lime shade, nicks, etc.
Yard. A $100 bill, also see Benji, C-Note
Zebra. Radio call sign for the surveillance department, as in 'Security Officer Williams to Zebra One'
Zoo lander. Also a 'Lookie Lou,' that is, a non-playing, non-drinking, aisle-blocking, over-the-shoulder player who thinks he knows it all and tries to help you play your hand
Zuke. A tip, a.k.a. a 'toke' ♠

[For a book with more information on casino personnel and procedures, see The Card Counter's Guide to Casino Surveillance by D.V. Cellini, an Arnold Snyder Professional Gambling Report.]

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Exhibit 99.3

GAMING REGULATORY OVERVIEW

General

The ownership and operation of casino entertainment facilities are subject to pervasive regulation under the laws, rules and regulationsof each of the jurisdictions in which we operate. Gaming laws are based upon declarations of public policy designed to ensure that gaming is conducted honestly, competitively and free of criminal and corruptive elements. Since the continued growthand success of gaming is dependent upon public confidence, gaming laws protect gaming consumers and the viability and integrity of the gaming industry, including prevention of cheating and fraudulent practices. Gaming laws may also be designed toprotect and maximize state and local revenues derived through taxation and licensing fees imposed on gaming industry participants and enhance economic development and tourism. To accomplish these public policy goals, gaming laws establish proceduresto ensure that participants in the gaming industry meet certain standards of character and fitness, or suitability. In addition, gaming laws require gaming industry participants to:

Typically, regulatory environments in the jurisdictions in which we operate are established by statute and are administered by aregulatory agency or agencies with interpretive authority with respect to gaming laws and regulations and broad discretion to regulate the affairs of owners, managers, and persons/entities with financial interests in gaming operations. Among otherthings, gaming authorities in the various jurisdictions in which we operate:

Licensing and Suitability Determinations

Gaming laws require us, each of our subsidiaries engaged in gaming operations, certain of our directors, officers and employees, and insome cases, our stockholders and holders of our debt securities, to obtain licenses or findings of suitability from gaming authorities. Licenses or findings of suitability typically require a determination that the applicant qualifies or issuitable. Gaming authorities have very broad discretion in determining whether an applicant qualifies for licensing or should be deemed suitable. Subject to certain administrative proceeding requirements, the gaming regulators have the authority todeny any application or limit, condition, restrict, revoke or suspend any license, registration, finding of suitability or approval, or fine any person licensed, registered or found suitable or approved, for any cause deemed reasonable by the gamingauthorities. Criteria used in determining whether to grant a license or finding of suitability, while varying between jurisdictions, generally include consideration of factors such as:

In evaluating individual applicants, gaming authorities consider the individual’s reputation for good character and criminal andfinancial history and the character of those with whom the individual associates.

Many jurisdictions limit the number oflicenses granted to operate gaming facilities within the jurisdiction, and some jurisdictions limit the number of licenses granted to any one gaming operator. For example, in Indiana, state law allows us to only hold two gaming licenses. Licensesunder gaming laws are generally not transferable unless the transfer is approved by the requisite regulatory agency. Licenses in many of the jurisdictions in which we conduct gaming operations are granted for limited durations and require renewalfrom time to time. In Iowa, our ability to continue our casino operations is subject to a referendum every eight years or at any time upon petition of the voters in the county in which we operate; the most recent referendum occurred in 2010. Our NewOrleans casino operates under a contract with the Louisiana gaming authorities which extends until 2014, with a ten-year renewal period. There can be no assurance that any of our licenses or any of the above mentioned contracts will be renewed, orwith respect to our gaming operations in Iowa, that continued gaming activity will be approved in any referendum.

Mostjurisdictions have statutory or regulatory provisions that govern the required action that must be taken in the event that a license is revoked or not renewed. For example, under Indiana law, a trustee approved by gaming authorities will assumecomplete operational control of our riverboat in the event our license is revoked or not renewed, and will be authorized to take any action necessary to sell the property if we are unable to find a suitable buyer within 180 days.

In addition to us and our direct and indirect subsidiaries engaged in gaming operations, gaming authorities may investigate anyindividual or entity having a material relationship to, or material involvement with, any of these entities to determine whether such individual is suitable or should be licensed as a business associate of a gaming licensee. Certain jurisdictionsrequire that any change in our directors or officers, including the directors or officers of our subsidiaries, must be approved by the requisite regulatory agency. Our officers, directors and certain key employees must also file applications withthe gaming authorities and may be required to be licensed, qualified or be found suitable in many jurisdictions. Gaming authorities may deny an application for licensing for any cause which they deem reasonable. Qualification and suitabilitydeterminations require submission of detailed personal and financial information followed by a thorough investigation. The burden of demonstrating suitability is on the applicant, who must pay all the costs of the investigation. Changes in licensedpositions must be reported to gaming authorities and in addition to their authority to deny an application for licensure, qualification or a finding of suitability, gaming authorities have jurisdiction to disapprove of a change in a corporateposition.

If gaming authorities were to find that an officer, director or key employee fails to qualify or is unsuitable forlicensing or unsuitable to continue having a relationship with us, we would have to sever all relationships with such person. In addition, gaming authorities may require us to terminate the employment of any person who refuses to file appropriateapplications.

Moreover, in many jurisdictions, any of our stockholders or holders of our debt securities may be required tofile an application, be investigated, and qualify or have his, her or its suitability determined. For example, under Nevada gaming laws,

each person who acquires, directly or indirectly, beneficial ownership of any voting security, or beneficial or record ownership of any non-voting security or any debt security in a publiccorporation which is registered with the Nevada Gaming Commission (the “Commission”), such as Caesars Entertainment Corporation, may be required to be found suitable if the Commission has reason to believe that his or her acquisition ofthat ownership, or his or her continued ownership in general, would be inconsistent with the declared public policy of Nevada, in the sole discretion of the Commission. Any person required by the Commission to be found suitable shall apply for afinding of suitability within 30 days after the Commission’s request that he or she should do so and, together with his or her application for suitability, deposit with the Nevada Gaming Control Board (the “Board”) a sum of moneywhich, in the sole discretion of the Board, will be adequate to pay the anticipated costs and charges incurred in the investigation and processing of that application for suitability, and deposit such additional sums as are required by the Board topay final costs and charges.

Furthermore, any person required by a gaming authority to be found suitable, who is foundunsuitable by the gaming authority, shall not be able to hold directly or indirectly the beneficial ownership of any voting security or the beneficial or record ownership of any nonvoting security or any debt security of any public corporation whichis registered with the gaming authority, such as Caesars Entertainment Corporation, beyond the time prescribed by the gaming authority. A violation of the foregoing may constitute a criminal offense. A finding of unsuitability by a particular gamingauthority impacts that person’s ability to associate or affiliate with gaming licensees in that particular jurisdiction and could impact the person’s ability to associate or affiliate with gaming licensees in other jurisdictions.

Many jurisdictions also require any person who acquires beneficial ownership of more than a certain percentage of our votingsecurities and, in some jurisdictions, our non-voting securities, typically 5%, to report the acquisition to gaming authorities, and gaming authorities may require such holders to apply for qualification or a finding of suitability. Most gamingauthorities, however, allow an “institutional investor” to apply for a waiver that allows the “institutional investor” to acquire, in most cases, up to 15% of our voting securities without applying for qualification or a findingof suitability. An “institutional investor” is generally defined as an investor acquiring and holding voting securities in the ordinary course of business as an institutional investor, and not for the purpose of causing, directly orindirectly, the election of a majority of the members of our board of directors, any change in our corporate charter, bylaws, management, policies or operations, or those of any of our gaming affiliates, or the taking of any other action whichgaming authorities find to be inconsistent with holding our voting securities for investment purposes only. An application for a waiver as an institutional investor requires the submission of detailed information about the company and its regulatoryfilings, the name of each person that beneficially owns more than 5% of the institutional investor’s voting securities or other equivalent and a certification made under oath or penalty for perjury, that the voting securities were acquired andare held for investment purposes only. Even if a waiver is granted, an institutional investor generally may not take any action inconsistent with its status when the waiver was granted without once again becoming subject to the foregoing reportingand application obligations. A change in the investment intent of an institutional investor must be reported to certain regulatory authorities immediately after its decision.

Notwithstanding, each person who acquires directly or indirectly, beneficial ownership of any voting security, or beneficial or record ownership of any nonvoting security or any debt security in ourcompany may be required to be found suitable if a gaming authority has reason to believe that such person’s acquisition of that ownership would otherwise be inconsistent with the declared policy of the jurisdiction.

Generally, any person who fails or refuses to apply for a finding of suitability or a license within the prescribed period after beingadvised it is required by gaming authorities may be denied a license or found unsuitable, as applicable. The same restrictions may also apply to a record owner if the record owner, after request, fails to identify the beneficial owner. Any personfound unsuitable or denied a license and who holds, directly or indirectly, any beneficial ownership of our securities beyond such period of time as may be prescribed by the applicable gaming authorities may be guilty of a criminal offense.Furthermore, we may be subject to disciplinary action if, after we receive notice that a person is unsuitable to be a stockholder or to have any other relationship with us or any of our subsidiaries, we:

Although many jurisdictions generally do not require the individual holders of debtsecurities such as notes to be investigated and found suitable, gaming authorities may nevertheless retain the discretion to do so for any reason, including but not limited to, a default, or where the holder of the debt instruments exercises amaterial influence over the gaming operations of the entity in question. Any holder of debt securities required to apply for a finding of suitability or otherwise qualify must generally pay all investigative fees and costs of the gaming authority inconnection with such an investigation. If the gaming authority determines that a person is unsuitable to own a debt security, we may be subject to disciplinary action, including the loss of our approvals, if without the prior approval of the gamingauthority, we:

Certain jurisdictions impose similar restrictions in connection with debt securities and retain the rightto require holders of debt securities to apply for a license or otherwise be found suitable by the gaming authority.

UnderNew Jersey gaming laws, if a holder of our debt or equity securities is required to qualify, the holder may be required to file an application for qualification or divest itself of the securities. If the holder files an application forqualification, it must place the securities in trust with an approved trustee. If the gaming regulatory authorities approve interim authorization, and while the application for plenary qualification is pending, such holder may, through the approvedtrustee, continue to exercise all rights incident to the ownership of the securities. If the gaming regulatory authorities deny interim authorization, the trust shall become operative and the trustee shall have the authority to exercise all therights incident to ownership, including the authority to dispose of the securities and the security holder shall have no right to participate in casino earnings and may only receive a return on its investment in an amount not to exceed the actualcost of the investment (as defined by New Jersey gaming laws). If the security holder obtains interim authorization but the gaming authorities later find reasonable cause to believe that the security holder may be found unqualified, the trust shallbecome operative and the trustee shall have the authority to exercise all rights incident to ownership pending a determination on such holder’s qualifications. However, during the period the securities remain in trust, the security holder maypetition the New Jersey gaming authorities to direct the trustee to dispose of the trust property and distribute proceeds of the trust to the security holder in an amount not to exceed the lower of the actual cost of the investment or the value ofthe securities on the date the trust became operative. If the security holder is ultimately found unqualified, the trustee is required to sell the securities and to distribute the proceeds of the sale to the applicant in an amount not exceeding thelower of the actual cost of the investment or the value of the securities on the date the trust became operative and to distribute the remaining proceeds to the state. If the security holder is found qualified, the trust agreement will beterminated.

Additionally, following the Reclassification, the Certificates of Incorporation of CEC and CEOC containprovisions establishing the right to redeem the securities of disqualified holders if necessary to avoid any regulatory sanctions, to prevent the loss or to secure the reinstatement of any license or franchise, or if such holder is determined by anygaming regulatory agency to be unsuitable, has an application for a license or permit denied or rejected, or has a previously issued license or permit rescinded, suspended, revoked or not renewed. The Certificates of Incorporation also containprovisions defining the redemption price and the rights of a disqualified security holder. In the event a security holder is disqualified, the New Jersey gaming authorities are empowered to propose any necessary action to protect the publicinterest, including the suspension or revocation of the licenses for the casinos we own in New Jersey.

Many jurisdictionsalso require that manufacturers and distributors of gaming equipment and suppliers of certain goods and services to gaming industry participants be licensed and require us to purchase and lease gaming equipment, supplies and services only fromlicensed suppliers.

Violations of Gaming Laws

If we or our subsidiaries violate applicable gaming laws, our gaming licenses could be limited, conditioned, suspended or revoked by gaming authorities, and we and any other persons involved could besubject to substantial fines. Further, a

supervisor or conservator can be appointed by gaming authorities to operate our gaming properties, or in some jurisdictions, take title to our gaming assets in the jurisdiction, and under certaincircumstances, earnings generated during such appointment could be forfeited to the applicable jurisdictions. Furthermore, violations of laws in one jurisdiction could result in disciplinary action in other jurisdictions. As a result, violations byus of applicable gaming laws could have a material adverse effect on our financial condition, prospects and results of operations.

Reporting and Recordkeeping Requirements

We are required periodically to submit detailed financial and operating reports and furnish any other information about us and our subsidiaries which gaming authorities may require. Under federal law, weare required to record and submit detailed reports of currency transactions involving greater than $10,000 at our casinos and Suspicious Activity Reports (“SARCs”) if the facts presented so warrant. Some jurisdictions require us tomaintain a log that records aggregate cash transactions in the amount of $3,000 or more. We are required to maintain a current stock ledger which may be examined by gaming authorities at any time. We may also be required to disclose to gamingauthorities upon request the identities of the holders of our debt or other securities. If any securities are held in trust by an agent or by a nominee, the record holder may be required to disclose the identity of the beneficial owner to gamingauthorities. Failure to make such disclosure may be grounds for finding the record holder unsuitable. In Indiana, we are required to submit a quarterly report to gaming authorities disclosing the identity of all persons holding interests of 1% orgreater in a riverboat licensee or holding company. Gaming authorities may also require certificates for our stock to bear a legend indicating that the securities are subject to specified gaming laws. In certain jurisdictions, gaming authoritieshave the power to impose additional restrictions on the holders of our securities at any time.

Review and Approval of Transactions

Substantially all material loans, leases, sales of securities and similar financing transactions by us and oursubsidiaries must be reported to, or approved by, gaming authorities. Neither we nor any of our subsidiaries may make a public offering of securities without the prior approval of certain gaming authorities if the securities or the proceedstherefrom are intended to be used to construct, acquire or finance gaming facilities in such jurisdictions, or to retire or extend obligations incurred for such purposes. Such approval, if given, does not constitute a recommendation or approval ofthe investment merits of the securities subject to the offering. Changes in control through merger, consolidation, stock or asset acquisitions, management or consulting agreements, or otherwise, require prior approval of gaming authorities incertain jurisdictions. Entities seeking to acquire control of us or one of our subsidiaries must satisfy gaming authorities with respect to a variety of stringent standards prior to assuming control. Gaming authorities may also require controllingstockholders, officers, directors and other persons having a material relationship or involvement with the entity proposing to acquire control, to be investigated and licensed as part of the approval process relating to the transaction.

Certain gaming laws and regulations in jurisdictions we operate in establish that certain corporate acquisitions opposed by management,repurchases of voting securities and corporate defense tactics affecting us or our subsidiaries may be injurious to stable and productive corporate gaming, and as a result, prior approval may be required before we may make exceptional repurchases ofvoting securities (such as repurchases which treat holders differently) above the current market price and before a corporate acquisition opposed by management can be consummated. In certain jurisdictions, the gaming authorities also require priorapproval of a plan of recapitalization proposed by the board of directors of a publicly traded corporation which is registered with the gaming authority in response to a tender offer made directly to the registered corporation’s stockholdersfor the purpose of acquiring control of the registered corporation.

Because licenses under gaming laws are generally nottransferable, our ability to grant a security interest in any of our gaming assets is limited and may be subject to receipt of prior approval from gaming authorities. A pledge of the stock of a subsidiary holding a gaming license and the foreclosureof such a pledge may be ineffective without the prior approval of gaming authorities. Moreover, our subsidiaries holding gaming licenses may be unable to guarantee a security issued by an affiliated or parent company pursuant to a public offering,or pledge their assets to secure payment of the obligations evidenced by the security issued by an affiliated or parent company, without the prior approval of gaming authorities. We are subject to extensive prior approval requirements relating tocertain borrowings and security interests with respect to our New Orleans casino. If the holder of a security interest wishes operation of the casino to continue during and after the filing of a suit to enforce the security interest, it may requestthe appointment of a receiver approved by Louisiana gaming authorities, and under Louisiana gaming laws, the receiver is considered to have all our rights and obligations under our contract with Louisiana gaming authorities.

Some jurisdictions also require us to file a report with the gaming authority within a prescribed period of time following certainfinancial transactions and the offering of debt securities. Were they to deem it appropriate, certain gaming authorities reserve the right to order such transactions rescinded.

Certain jurisdictions require the implementation of a compliance review and reporting systemcreated for the purpose of monitoring activities related to our continuing qualification. These plans require periodic reports to senior management of our company and to the regulatory authorities.

Certain jurisdictions require that an independent audit committee oversee the functions of surveillance and internal audit departments atour casinos.

License Fees and Gaming Taxes

We pay substantial license fees and taxes in many jurisdictions, including the counties, cities, and any related agencies, boards, commissions, or authorities, in which our operations are conducted, inconnection with our casino gaming operations, computed in various ways depending on the type of gaming or activity involved. Depending upon the particular fee or tax involved, these fees and taxes are payable either daily, monthly, quarterly orannually. License fees and taxes are based upon such factors as:

In many jurisdictions, gaming tax rates are graduated with the effect of increasing as gross revenues increase. Furthermore, tax ratesare subject to change, sometimes with little notice, and we have recently experienced tax rate increases in a number of jurisdictions in which we operate. A live entertainment tax is also paid in certain jurisdictions by casino operations whereentertainment is furnished in connection with the selling or serving of food or refreshments or the selling of merchandise.

OperationalRequirements

In many jurisdictions, we are subject to certain requirements and restrictions on how we must conduct ourgaming operations. In many jurisdictions, we are required to give preference to local suppliers and include minority-owned and women-owned businesses in construction projects to the maximum extent practicable.

Some jurisdictions also require us to give preferences to minority-owned and women-owned businesses in the procurement of goods andservices. Some of our operations are subject to restrictions on the number of gaming positions we may have, the minimum or maximum wagers allowed by our customers, and the maximum loss a customer may incur within specified time periods.

Our land-based casino in New Orleans operates under a contract with the Louisiana Gaming Control Board and the Louisiana EconomicDevelopment and Gaming Act and related regulations. Under this authority, our New Orleans casino is subject to not only many of the foregoing operational requirements, but also to restrictions on our food and beverage operations, including withrespect to the size, location and marketing of eating establishments at our casino entertainment facility. Furthermore, with respect to the hotel tower, we are subject to restrictions on the number of rooms within the hotel, the amount of meetingspace within the hotel and how we may market and advertise the rates we charge for rooms.

In Mississippi, we are required toinclude adequate parking facilities (generally 500 spaces or more) in close proximity to our existing casino complexes, as well as infrastructure facilities, such as hotels, that will amount to at least 25% of the casino cost. The infrastructurerequirement was increased to 100% of the casino cost for any new casinos in Mississippi.

To comply with requirements of Iowagaming laws, we have entered into management agreements with Iowa West Racing Association, a non-profit organization. The Iowa Racing and Gaming Commission has issued a joint license to Iowa West Racing Association and Harveys Iowa ManagementCompany, Inc. for the operation of the Harrah’s Council Bluffs Casino, which is an excursion gambling boat that is now permanently moored, and issued a license for the Horseshoe Council Bluffs Casino at Bluffs Run Greyhound Park which is a fullservice, land based casino and a greyhound racetrack. The company operates both facilities pursuant to the management agreements.

The United Kingdom Gambling Act of 2005 which became effective in September 2007, replaced the Gaming Act 1968, and removed most of the restrictions on adverting. Though the 2005 Act controlsmarketing, advertising gambling is now controlled by the Advertising Standards Authority through a series of codes of practise. Known as the CAP codes, the codes offer guidance on the content of print, television and radio advertisements.

Indian Gaming

Organizational Standards Policies And Procedures

The terms and conditions of management contracts and the operation of casinos and all gaming on Indian land in the United States are subject to the Indian Gaming Regulatory Act of 1988, (the“IGRA”), which is administered by the National Indian Gaming Commission, (the “NIGC”), the gaming regulatory agencies of tribal governments, and Class III gaming compacts between the tribes for which we manage casinos and thestates in which those casinos are located. IGRA established three separate classes of tribal gaming-Class I, Class II and Class III. Class I includes all traditional or social games solely for prizes of minimal value played by a tribe in connectionwith celebrations or ceremonies. Class II gaming includes games such as bingo, pulltabs, punchboards, instant bingo and non-banked card games (those that are not played against the house) such as poker. Class III gaming includes casino-style gamingsuch as banked table games like blackjack, craps and roulette, and gaming machines such as slots and video poker, as well as lotteries and pari-mutuel wagering. Harrah’s Ak-Chin Phoenix and Rincon provide Class II gaming and, as limited by thetribal-state compact, Class III gaming. The Eastern Band Cherokee Casino currently provides only Class III gaming.

IGRAprohibits all forms of Class III gaming unless the tribe has entered into a written agreement or compact with the state that specifically authorizes the types of Class III gaming the tribe may offer. These compacts may address, among other things,the manner and extent to which each state will conduct background investigations and certify the suitability of the manager, its officers, directors, and key employees to conduct gaming on tribal lands. We have received our permanent certificationfrom the Arizona Department of Gaming as management contractor for the Ak-Chin Indian Community’s casino, a Tribal-State Compact Gaming Resource Supplier Finding of Suitability from the California Gambling Control Commission in connection withmanagement of the Rincon San Luiseno Band of Mission Indians casino, and have been licensed by the relevant tribal gaming authorities to manage the Ak-Chin Indian Community’s casino, the Eastern Band of Cherokee Indians’ casino and theRincon San Luiseno Band of Mission Indians’ casino, respectively.

IGRA requires NIGC approval of management contractsfor Class II and Class III gaming as well as the review of all agreements collateral to the management contracts. Management contracts which are not so approved are void. The NIGC will not approve a management contract if a director or a 10%stockholder of the management company:

Data Policies And Standards

In addition, the NIGC will not approve a management contract if the management company or any of its agents have attempted to unduly influence any decision or process of tribal government relating togaming, or if the management company has materially breached the terms of the management contract or the tribe’s gaming ordinance, or a trustee, exercising due diligence, would not approve such management contract. A management contract can beapproved only after the NIGC determines that the contract provides, among other things, for:

Management contracts can be modified or cancelled pursuant to an enforcement action taken by the NIGC basedon a violation of the law or an issue affecting suitability.

Indian tribes are sovereign with their own governmental systems, which have primaryregulatory authority over gaming on land within the tribes’ jurisdiction. Therefore, persons engaged in gaming activities, including the company, are subject to the provisions of tribal ordinances and regulations on gaming. These ordinances aresubject to review by the NIGC under certain standards established by IGRA. The NIGC may determine that some or all of the ordinances require amendment, and that additional requirements, including additional licensing requirements, may be imposed onus. The possession of valid licenses from the Ak-Chin Indian Community, the Eastern Band of Cherokee Indians and the Rincon San Luiseno Band of Mission Indians, are ongoing conditions of our agreements with these tribes.

Riverboat Casinos

Inaddition to all other regulations applicable to the gaming industry generally, some of our riverboat casinos are also subject to regulations applicable to vessels operating on navigable waterways, including regulations of the U.S. Coast Guard. Theserequirements set limits on the operation of the vessel, mandate that it must be operated by a minimum complement of licensed personnel, establish periodic inspections, including the physical inspection of the outside hull, and establish othermechanical and operational rules.

Racetracks

We own a full service casino which includes a full array of table games in conjunction with a greyhound racetrack in Council Bluffs, Iowa. The casino operation and the greyhound racing operation areregulated by the same state agency and are subject to the same regulatory structure established for all Iowa gaming facilities. A single operating license covers both parts of the operation in Council Bluffs. We also own slot machines at athoroughbred racetrack in Bossier City, Louisiana, and we own a combination harness racetrack and casino in southeastern Pennsylvania in which the company, through various subsidiary entities, owns a 95% interest in the entity licensed by thePennsylvania Gaming Control Board. Generally, our slot operations at the Iowa racetrack is regulated in the same manner as our other gaming operations in Iowa. In addition, regulations governing racetracks are typically administered separately fromour other gaming operations (except in Iowa), with separate licenses and license fee structures. For example, racing regulations may limit the number of days on which races may be held. In Kentucky, we own and operate Bluegrass Downs, a harnessracetrack located in Paducah, and hold a one-half interest in Turfway Park LLC, which is the owner of the Turfway Park thoroughbred racetrack in Boone County. Turfway Park LLC also owns a minority interest in Kentucky Downs LLC, which is the ownerof the Kentucky Downs racetrack. These Kentucky racetracks are licensed and regulated by the Kentucky Horse Racing Commission and are subject to the same regulatory structure established for all Kentucky racing facilities. As of July 27, 2010,we also own and operate Thistledown Racetrack, a thoroughbred racetrack located in Cleveland, Ohio, which is regulated by the Ohio State Racing Commission and subject to the same regulatory structure established for all Ohio racing facilities.

Policies And Procedures Template

Internet

Standard Company Policies And Procedures

Anaffiliate of the Company, Caesars Interactive Entertainment, Inc., engages in lawful online internet gaming activity in the United Kingdom through two outside third party operators. This internet gaming is offeredto residents of the United Kingdom by the third party operators pursuant to licenses issued to these operators by the Gibraltar Regulatory Authority. Gibraltar is a United Kingdom “white listed” jurisdiction whichallows operators to legally advertise online gaming services in the United Kingdom. To date, the key gaming regulatory authorities governing online internet gaming are the Gibraltar Regulatory Authority, the Alderney Gambling ControlCommission and the Isle of Mann Gambling Supervision Commission. Italy and France recently legalized online internet gaming by private companies and, in June 2010, Denmark passed legislation legalizing online internet gaming. CaesarsInteractive Entertainment, Inc., recently entered into agreements with third parties for the use of the World Series of Poker brand on online gaming websites in Italy and France. We own an online gaming business, providing for real money casino,bingo, and poker games in the United Kingdom, alliances with online gaming providers in Italy and France, “play for fun” offerings in other jurisdictions, social games on Facebook and other social media websites, and mobile applicationplatforms.