Gibraltar Regulatory Authority Gambling Division
Exhibit 99.3
The UK Gambling Commission is the main regulatory body for online gambling in the United Kingdom. It was established following the Gambling Act of 2005 and assumed its full power two years later. Gibraltar Gambling Division and Spelinspektionen (The Swedish Gambling Authority) 1 Objectives 1. The delivery of online gambling services is increasingly global in nature with operational infrastructure (including cloud and other technology services), management control and other core services increasingly dispersed. When the country first started regulating gambling, the Gibraltar Regulatory Authority (known as the GRA) was initially responsible for the regulation. Later down the line, the GRA was then incorporated into the Gambling Division of the Government of Gibraltar – the same body that today, is responsible for online gambling regulation. Gambling and Lottery Supervision Department Ministry of the Czech Republic. DENMARK Danish Gambling Authority. ESTONIA Tax and Customs Board. Ministry of Finance. FINLAND Ministry of the Interior. GERMANY Gambling Supervision Authority. Gibraltar Regulatory Authority. Gambling Commission. GREECE Hellenic.
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:
Similarly, the Gibraltar Regulatory Authority strives to stand as the pillar of trust, endurance, security, and support in the world of gambling and casinos. Considered to be one of the pioneers among the top gaming authorities of the world, Gibraltar Regulatory Authority holds an eminent place in the entire betting industry.
• | Establish and maintain responsible accounting practices and procedures; |
• | Maintain effective controls over their financial practices, including establishment of minimum procedures for internal fiscal affairs and thesafeguarding of assets and revenues; |
• | Maintain systems for reliable record keeping; |
• | File periodic reports with gaming regulators; and |
• | Maintain strict compliance with various laws, regulations and required minimum internal controls pertaining to gaming. |
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:
• | Adopt rules and regulations under the implementing statutes; |
• | Make appropriate investigations to determine if there has been any violation of laws or regulations; |
• | Enforce gaming laws and impose disciplinary sanctions for violations, including fines and penalties; |
• | Review the character and fitness of participants in gaming operations and make determinations regarding their suitability or qualification forlicensure; |
• | Grant licenses for participation in gaming operations; |
• | Collect and review reports and information submitted by participants in gaming operations; |
• | Review and approve transactions, such as acquisitions or change-of-control transactions of gaming industry participants, securities offerings and debttransactions engaged in by such participants; and |
• | Establish and collect fees and/or taxes. |
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:
• | The financial stability, integrity and responsibility of the applicant, including whether the operation is adequately capitalized in the jurisdictionand exhibits the ability to maintain adequate insurance levels; |
• | The quality of the applicant’s casino facilities; |
• | The amount of revenue to be derived by the applicable jurisdiction through operation of the applicant’s gaming facility; |
• | The applicant’s practices with respect to minority hiring and training; and |
• | The effect on competition and general impact on the community. |
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.
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:
• | pay that person any dividend or interest upon our voting securities; |
• | allow that person to exercise, directly or indirectly, any voting right conferred through securities held by that person; |
• | pay remuneration in any form to that person for services rendered or otherwise; or |
• | fail to pursue all lawful efforts to require such unsuitable person to relinquish his voting securities including, if necessary, the immediate purchaseof said voting securities for cash at fair market value. |
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:
• | pay to the unsuitable person any dividend, interest or any distribution whatsoever; |
• | recognize any voting right by the unsuitable person in connection with those securities; |
• | pay the unsuitable person remuneration in any form; or |
• | make any payment to the unsuitable person by way of principal, redemption, conversion exchange, liquidation or similar transaction. |
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
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
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
• | a percentage of the gross revenues received; |
• | the number of gaming devices and table games operated; |
• | franchise fees for riverboat casinos operating on certain waterways; and |
• | admission fees for customers boarding our riverboat casinos. |
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.
Indian 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:
• | is an elected member of the Native American tribal government which owns the facility purchasing or leasing the games; |
• | has been or is convicted of a felony gaming offense; |
• | has knowingly and willfully provided materially false information to the NIGC or the tribe; |
• | has refused to respond to questions from the NIGC; or |
• | is a person whose prior history, reputation and associations pose a threat to the public interest or to effective gaming regulation and control, orcreate or enhance the chance of unsuitable activities in gaming or the business and financial arrangements incidental thereto. |
• | adequate accounting procedures and verifiable financial reports, which must be furnished to the tribe; |
• | tribal access to the daily operations of the gaming enterprise, including the right to verify daily gross revenues and income; |
• | minimum guaranteed payments to the tribe, which must have priority over the retirement of development and construction costs; |
• | a ceiling on the repayment of such development and construction costs; and |
• | a contract term not exceeding five years and a management fee not exceeding 30% of net revenues (as determined by the NIGC); provided that the NIGC mayapprove up to a seven year term and a management fee not to exceed 40% of net revenues if NIGC is satisfied that the capital investment required, and the income projections for the particular gaming activity require the larger fee and longer term. |
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.
Gibraltar Regulatory Authority Gambling Division Address
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
Gibraltar Regulatory Authority Gambling Division Form
Internet
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.
Nov 2006
Guidelines for Parties Requesting Formal Complaint
Resolution Intervention
1. To expedite resolution of your complaint via our formal complaint resolution process may we ask you to fully comply with the prescribed format attached.
2. Please ensure that the request for complaint resolution is signed and dated.
3. Particular attention should be paid to ensuring that where confidential information is provided in support of this request that such information is clearly marked and contained in a separate annex to this document.
4. The contact name provided will normally be the only contact used by this office for the duration of the process. Should this contact name be changed the onus is on the complainant to inform the GRA of this in writing.
5. Requests for formal complaint resolution should be addressed to:
Gibraltar Regulatory Authority
Gambling Division
Complaints
Suite 811 Europort
Gibraltar
Or
Via e-mail to complaints@gra.gi
6. The GRA reserves the right to deal with any request for assistance on a complaint in a manner which is outside the formal complaints procedures provided for in the GRA Complaints Resolution Procedures Document. Complainants will be informed prior to any such complaint resolution procedure.