ECL Gaming (the “Company”) complies 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. 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
Company approved responsible gaming collateral and Problem Gaming brochures (e.g., Problem Gambling Information and Resources brochure or other Company approved problem gambling collateral) will be displayed at all property locations and cash access devices.
Company approved responsible gaming collateral and Problem Gambling brochures will be made available upon request.
The Company 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 will 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 will be made available at the corporate office and in employees only areas of the casino locations.
Gaming-related websites will include information describing responsible gaming, policies and practices related to responsible gaming and where to find assistance (See Appendix A).
The Company maintains a self-limit policy and procedures 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, complimentaries and gambling promotions).

The Company will make reasonable efforts (i.e., flagging a patron’s account) to honor a patron’s written request to be self-limited from gaming activities. The Company reserves the right to exclude a patron from gaming without a request from the patron.
Newly hired employees will receive training on the Company’s responsible gaming program during New Hire Orientation. This general training will 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 will be conducted by individual departments.
Gaming employees will be trained on responsible gaming and provided periodic refresher training that highlights the differences between responsible gaming and problem gambling. Periodic refresher training will be performed via department pre-shift meeting, Responsible Gaming Week, and/or online training modules (position specific). During periodic refresher training, employees will receive responsible gaming materials (e.g., brochures, policies, Marketing).
Underage Gambling and Unattended Minors in Casino
The Company will 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 are addressed in the Company’s Underage Gaming Policy.
The Company will 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 will take reasonable steps to locate a parent or responsible third party (e.g., police department) for transfer of children/minors.
Training is 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
The Company maintains 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 will be trained in the Responsible Beverage Service Policy at the time of hire and will receive periodic refresher training.
Responsible Advertising
For the purposes of this Policy, 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 will:
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 will 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 Company will conduct annual reviews of its Responsible Gaming Policy.

APPENDIX A
RESPONSIBLE GAMING INFORMATION – GAMING RELATED WEBSITES STATEMENT
ECL Gaming complies 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 patrons, and the community is to make responsible gaming an integral part of our daily operations.
You 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, complimentaries, and gambling promotions. We reserve the right to exclude a patron from gaming without a request from a patron.
We provide current education to new employees on responsible gaming and provide periodic refresher training.
We advertise responsibly by including a responsible gaming message and/or a toll-free help line number in advertising messaging where practical. We place media where most of the audience is reasonably expected to be above the legal age to participate in gaming activity. We do 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.