Game Play By Gaming Vendors PROHIBITED

Any individual who is directly or indirectly involved in hardware or software development, engineering, maintenance, repair, installation, or any activity that relates to the functionality of a gaming machine, gaming software, or gaming device is PROHIBITED from all game play or promotions at any casino owned or operated by the Citizen Potawatomi Nation.

Shipping and Control Requirements for Gaming Machines or Software

Vendors are required to follow specific requirements when shipping gaming-related hardware or software to or from a Citizen Potawatomi Nation (CPN) gaming facility. A CPN gaming facility is defined as any licensed gaming facility, storage facility, or training facility owned or operated by the Citizen Potawatomi Nation where the facility is used in the gaming enterprise. This section will establish shipping and control requirements for the geographical movement of gaming machines and software. This section does not apply to internal movements within the gaming facility, but does apply to movement of gaming machines or software from one CPN facility to another or shipments from or to vendors or manufacturers. Forms for shipment notifications are available on our Vendor Downloads page or by clicking on the links in the Notification Requirements section. To ensure that the proper form is used, please download the form from this WEB site for each use.

1.Notification Requirements

a. Machine shipment notification by vendors or manufacturers will be made to the Citizen Potawatomi Nation Gaming Commission (CPNGC) using a CPNGC Gaming Machine Shipment Notification form or in a submission format preapproved by the CPNGC. Shipment of software by vendors or manufacturers shall meet the same notification requirements using the CPNGC Software Shipment Notification form or in a submission format preapproved by the CPNGC. The notifications, regardless of submission format, must be complete and meet the established time-line requirements. Manufacturers or vendors must FAX, email, or mail (via certified mail) the notification to the CPNGC prior to shipment using the established time line. Failure to notify the CPNGC as required, using the established time-line, will result in a notice of violation and the possible imposition of a fine not to exceed $5000.00 per instance of violation. Movement of gaming machines from one CPN facility to another requires the use of the CPNGC Gaming Machine Activity Request Form using the same time line, but may be delivered directly to the CPNGC. Incomplete forms may be considered invalid and shipment or movement may be rejected and the vendor will receive a notice of violation and the possible imposition of a fine not to exceed $5000.00 per instance of violation. Internal movement or movement of software from one CPN facility to another is accomplished by the CPNGC and only requires that the Gaming Commissioner or the CPNGC Agent authorized by the CPN Gaming Commissioner, be notified of such movement. The Gaming Commissioner or CPNGC Agent authorized by the CPN Gaming Commissioner may waive in writing any section or requirement in this policy.

1. Notification Requirements
1. Machine shipment notification by vendors or manufacturers will be made to the Citizen Potawatomi Nation Gaming Commission (CPNGC) using a CPNGC Gaming Machine Shipment Notification form or in a submission format preapproved by the CPNGC. Shipment of software by vendors or manufacturers shall meet the same notification requirements using the CPNGC Software Shipment Notification form or in a submission format preapproved by the CPNGC. The notifications, regardless of submission format, must be complete and meet the established time-line requirements. Manufacturers or vendors must FAX, email, or mail (via certified mail) the notification to the CPNGC prior to shipment using the established time line. Failure to notify the CPNGC as required, using the established time-line, will result in a notice of violation and the possible imposition of a fine not to exceed $5000.00 per instance of violation. Movement of gaming machines from one CPN facility to another requires the use of the CPNGC Gaming Machine Activity Request Form using the same time line, but may be delivered directly to the CPNGC. Incomplete forms may be considered invalid and shipment or movement may be rejected and the vendor will receive a notice of violation and the possible imposition of a fine not to exceed $5000.00 per instance of violation. Internal movement or movement of software from one CPN facility to another is accomplished by the CPNGC and only requires that the Gaming Commissioner or the CPNGC Agent authorized by the CPN Gaming Commissioner, be notified of such movement. The Gaming Commissioner or CPNGC Agent authorized by the CPN Gaming Commissioner may waive in writing any section or requirement in this policy.
2. Gaming machine or software shipment from the manufacturer requires five (5) business days notification sent to the CPNGC. This notification must be made using established guidelines prior to shipment.
3. Gaming machine or software shipment from the manufacturer requires five (5) business days notification sent to the respective facility. This notification must be made using established guidelines prior to shipment.
4. Gaming software must be received by the Gaming Commission a minimum of five (5) business days prior to the scheduled installation date.
5. Gaming machine movement by a manufacturer or vendor from one CPN facility to another CPN facility requires five (5) business days notification sent to the CPNGC. This notification must be made using established guidelines prior to movement.
6. Gaming machine movement by a manufacturer or vendor from one CPN facility to another CPN facility requires five (5) business days notification sent to the respective facility. This notification must be made using established guidelines prior to movement.
7. Gaming machine movement by the Casino Networking Group or other CPN employees from one CPN facility to another CPN facility requires five (5) business days notification sent to the CPNGC. This notification must be made using established guidelines prior to movement.
8. Gaming machine movement by the Casino Networking Group or other CPN employees from one CPN facility to another CPN facility requires five (5) business days notification sent to the respective facility. This notification must be made using established guidelines prior to movement.
2. Physical Shipment or Movement of Gaming Machines and Software
   

   Adherence to physical security procedures is required for all shipments or movements of gaming machines and software. Shipment refers to transportation of gaming machines or software to or from a vendor or manufacturer. Movement refers to transportation of gaming machines between CPN facilities.

1. Gaming Machines
1. Shipment of gaming machines to or from a vendor or manufacturer shall be made with all devices in tamper proof sealed containers and shall have complied with all applicable shipping requirements contained in the Shipping and Control Requirements for Gaming Machines or Software.
2. Movement of gaming machines between CPN facilities shall be made with all devices in tamper proof sealed containers or as directed by the CPNGC with the gaming software removed and shall have complied with all applicable shipping requirements contained in the Shipping and Control Requirements for Gaming Machines or Software.
3. Upon delivery of any gaming devices to any CPN facility, no one shall break the seal of any delivery, nor shall any device be removed from the shipping container without the physical presence and authorization of a CPNGC agent.
4. Upon delivery of any gaming devices to any CPN facility, the devices shall be staged in a quarantined area where the following procedures will apply prior to movement of the devices to the gaming floor or storage area:
1. A CPNGC Agent shall take possession of all keys to all locks on all devices.
2. If locks are already installed on devices upon delivery, a CPNGC agent shall take possession of all keys as the devices are removed from the container.
3. If locks are installed after delivery, a CPNGC agent shall be present at the time of lock installation and collect all keys at that time.
4. CPNGC Agents or Operational Compliance Officers designated by the CPNGC shall maintain secured possession of all keys that control access to the logic board areas or areas where programmable storage media are located or areas which control the game or payouts.
5. Keys that control access to the logic board areas or areas where programmable storage media are located or areas which control the game or payouts may be issued to designated personnel for specific tasks using approved key controls. Keys must be returned, to the CPNGC or Operational Compliance, by the person that was issued the keys, once the specific task has been completed or prior to the end of shift for the person who was issued the key set.
6. Keys that control access to the logic board areas or areas where programmable storage media are located or areas which control the game or payouts will not be issued to non-CPN employees or Vendors.
7. Non-CPNGC controlled keys shall be verified to the proper locking mechanism, logged, and issued to Operational Compliance where proper key controls shall be implemented.
8. Any area where programmable storage media is located with or without separate locking mechanisms, CPNGC Agents shall seal the compartment or the individual programmable storage media with a pre-numbered tamper resistant seal that is controlled by the CPNGC.
9. The CPNGC shall apply a permanent serialized identification label to the exterior of the gaming device.
5. Logic boards with programmed storage media or programmed storage media not installed on a logic board must be shipped separately from the gaming machine. Software will not be shipped preinstalled in a gaming machine without written preapproval of the CPNGC. Upon delivery of gaming devices shipped with software preinstalled, the gaming device shall be opened upon delivery in the quarantined area and a CPNGC Agent shall remove the installed software.
2. Software
1. All software shipments must be received by the Gaming Commission a minimum of five (5) days prior to the scheduled installation date.
2. All ESD sensitive devices shall be shipped in ESD protective containers. An ESD sensitive device is defined as the device itself or any circuit board containing ESD sensitive devices. Proper handling of ESD sensitive devices must be maintained at all times.
3. Programmed storage media must be shipped separate from the gaming machine and any subsequent shipments of programmed storage media including upgrades or replacements shall be shipped from the manufacturer or supplier directly to the CPNGC. Software will not be shipped preinstalled in a gaming machine without written preapproval of the CPNGC.
4. Programmed storage media shall be secured by the Gaming Commission Information Systems Security Administrator or by an authorized CPNGC Agent upon receipt by the CPNGC.
5. Prior to live patron play; the programmed storage media shall be tested, validated, and compared to the checksum results obtained by an independent testing lab approved by the CPNGC.
6. Upon testing and validating the programmed storage media, a CPNGC Agent shall:
1. Witness the installation of the media on the logic board or in the microprocessor compartment and shall date, initial, and secure the logic area or the individual programmable storage media with a CPNGC pre-numbered tamper resistant seal that is controlled by the CPNGC at all times.
2. Issue the programmable storage media to a Manager-level employee of the Slot Department. The programmable storage media shall be identified and sealed, with a CPNGC pre-numbered tamper resistant seal that is controlled by the CPNGC, by a CPNGC Agent, on the logic board subsequent to the media installation.
7. The logic compartment on all progressive gaming machines shall be sealed with a CPNGC pre-numbered tamper resistant seal that is controlled by the CPNGC at all times.
3. PAR Sheets

   PAR Sheets must be submitted with and in the same manner as the software shipment notification. The PAR sheets must be received by the Gaming Commission a minimum of five (5) days prior to the scheduled installation date.